The upcoming Delegated Acts under the Ecodesign for Sustainable Products Regulation (ESPR) will define the data requirements for all Digital Product Passports (DPP) including textiles and footwear—yet, this piece of legislation remains unpublished. With official guidelines anticipated in late 2025, businesses must prepare now for the inevitable shift towards traceability, transparency, and circularity. At TrusTrace, we’ve proactively built a robust DPP data protocol in collaboration with the Trace4Value working group, ensuring alignment with existing industry standards and best practices.
This article gathers commonly asked questions about the ESPR and its Delegated Acts, explores data transparency expectations, and highlights how companies can stay ahead of compliance. For a deeper dive, download our Unlocking DPP Playbook or DPP Data Protocol.
The data requirements of the Digital Product Passports for fashion and textile are officially imposed by the Delegated Acts for Textiles, but this piece of legislation has yet to be published. They are anticipated to be announced in the second half of 2025. What do we know is that a DPP is comprised of three components:
See our previous article on the data and technical requirements of the DPP.
Image of the QR codes which will redirect to the digital product passports created for the specific garments, one from Kappahl and another from Marimekko, used in the Trace4Value pilot project.
Our team has been researching and developing our data platform over the last two years in preparation for ESPR and DPP together with the Trace4Value working group. After rigorous effort, the work group reached consensus with the 125 data points published in the Trace4Value DPP Data Protocol, and have worked under the assumption these will remain valid. The chosen parameters are backed with confidence by various data standards and fashion experts including GS1 Sweden, Swedish Institute of Standards and Kappahl.
With the backing of prominent experts in Sweden, we’ve seen increased interest and adoption of the Trace4Value data protocol into supply chain initiatives by Swedish and Scandinavian brands.
However, the true test will come once the ESPR Delegated Acts (DAs) for Textiles and Footwear are officially published in the second half of 2025. Whilst we are confident in the foundational data infrastructure, we remain ready for anything to happen. If amendments are required, we anticipate minor adaptions and prompt adjustments to our DPP solution to ensure compliance and efficiency.
Many actors in the value chain are concerned about the data accessibility, plus the implications for circular economy models. From what we gather, there’s a common anticipation for the QR code to be the main data carrier method and accessibility point for anyone seeking the data at point-of-sale. Moreover, anyone involved in repairing an item will need access to add information about the item's state at the time of repair or eventual recyclability.
While the exact details for circularity actors are still pending, the European standardisation organisations CEN and CENELEC are developing eight harmonized standards for DPP, expected to be adopted by the end of 2026. TrusTrace is closely monitoring the process as delegates in the Swedish Institute of Standards and associated working groups developing these standards.
It’s still too early to determine the exact level of data transparency required for DPP. However, a dedicated working group is developing standards on Business Responsibility, Data Authentication, Reliability, and Integrity, alongside standards on Data Security and Interoperability between technologies. These standards are expected to be finalized by the end of 2025. We anticipate that the amount of data displayed will vary between end consumers and actors in the value chain.
Under ESPR guidelines, every product must carry a persistent unique product identifier – a permanent, machine-readable marker designed to ensure traceability and power circularity – to access the DPP record. This identifier, typically a serialized Global Trade Identification Number (GTIN) following GS1 standards, must remain attached to the garment throughout its lifecycle, guaranteeing seamless data access. While multiple carrier formats exist, industry consensus points to QR codes as the most viable standard, offering scalability, interoperability, and ease of implementation. In the Unlocking DPP playbook, we explore different options, but the technical requirements of the DPP is expected to be announced with the Standards.
Start your Digital Product Passport (DPP) journey with a proven end-to-end solution from TrusTrace. Over the past two years, TrusTrace has led the way in creating a complete DPP solution as the technology partner for Trace4Value.
Partnering with other standards leaders like GS1, we have developed a proven solution for DPP to help your business start today. See the DPP Solution from TrusTrace.