A guest article by Camilla Mjelde (Trimco Group) and Cyrus Gilbert-Rolfe (Kezzler).
Over the past two months we’ve published nine episodes of The DPP Minute, sixty seconds each, with one job: turn every new piece of Digital Product Passport news into something an apparel brand can act on. This article pulls those episodes into a single picture, and adds two topics we haven’t covered on screen, recyclability and recycled content.
If you take one thing from it, take this. The direction of travel is clear enough to plan around. Brands that start structuring their data this year will find the deadline calm. The ones waiting for the final text won’t.
Where we actually are
The Joint Research Centre, the European Commission’s science and knowledge service, does the technical work behind the ecodesign rules for textiles. It has now published its third milestone report, and it marks a real change of direction.
The timing first. The textiles delegated act is expected in 2027, with roughly eighteen months to comply after that. On paper it reads like generous runway. In practice it isn’t. Choosing a data carrier, getting it onto the product, and pulling every data point into one place all take time, and none of that work starts on the day the act lands.
It’s worth being precise about what is and isn’t live today, because the coverage keeps blurring it. The EU’s DPP Registry went live in July 2026. That is the infrastructure: a directory that says where a passport is hosted, not the passport itself. No textile or apparel product carries a DPP obligation yet. What you can do today is prepare, and most of the template is already visible. Waiting for the delegated act before you begin is the one avoidable mistake.
▶ Watch Episode 1: Where are we?
The big reset: 15 to 7 to 3
The most useful thing the JRC has done is cut. A long list of candidate data categories came down to seven core assessment areas, then grouped into three possible design options, each weighed on environmental benefit against cost. The most complex option carries four DPP data points. The simplest carries one, recycled content. The Commission still has to choose which of the three becomes law.
Our advice hasn’t changed: build flexibly. Put a data model in place that works whichever option the Commission lands on, and that’s ready for the rules taking shape outside Europe too. You shouldn’t have to rebuild because a decision went one way rather than the other.
▶ Watch Episode 2: When 15 became 7 · Episode 7: The three design options
Product information, not producer information
One scope note before we go through the areas. The major changes in this third JRC report relate to product information: what a garment is, how it performs, and what it’s made of. Our DPP minute series focuses on these key areas of change. This does not mean producer information is “out of scope”; identifying who your suppliers are and where they are based, using identifiers such as a GLN. That silence isn’t a signal that producer information or supply chain traceability has fallen out of the DPP. It hasn’t. Both remain firmly in scope. They simply weren’t the subject of this particular DPP Series.
The seven areas, one by one
Here is where each area stands, and what it actually asks of you. Five we’ve covered on screen. The last two, recyclability and recycled content, we haven’t, and commercially they’re the most interesting of the set.
1. Robustness, formerly durability
Durability was too hard to measure objectively, so the JRC replaced it with robustness, a category that rests on standardized test reports the industry already produces. Garments are scored against those tests. For most brands this isn’t new data to gather, it’s existing data to structure, with a gap check to run well before the deadline.
▶ Watch Episode 3: From durability to robustness
2. Maintenance
On maintenance, the report simply points to the ongoing revision of the Textile Labelling Regulation. Anything to do with fibre content and care icons will follow whatever that revision finalizes. That’s good news, because it means one source of truth rather than two.
3. Repair
Repair is lighter still. The JRC recommends dropping it as a regulatory requirement and leaving it to the brand as a commercial decision. That turns care and repair information into something more interesting than a compliance box. It becomes a free, low pressure channel straight to your customer. Our take is simple. Lean in.
▶ Watch Episode 4: Maintenance and repair
4. Environmental impact
This one narrowed sharply. The scope moved from a product’s full lifecycle down to the manufacturing stage, then down again to the carbon emissions of that stage, reported as information against a baseline rather than as a performance target.
The practical consequence matters. This is a supply chain data problem, not a PIM or a DAM problem. The number you need usually sits in a procurement contract. If it isn’t in yours yet, add the clause, start collecting now, and open the conversation with your suppliers early.
▶ Watch Episode 5: Environmental impact
5. Substances of concern
Substances of concern is a major theme across the ESPR as a whole, but for textiles much of it is already regulated through REACH and the incoming PFAS rules. The DPP will largely surface testing and certification data that most brands already hold.
So the challenge here isn’t collection, it’s format. If your chemical compliance data is a PDF on someone’s hard drive, that’s the problem to solve. It needs to live somewhere the passport can call.
▶ Watch Episode 6: Substances of concern
6. Recyclability
Not covered in the video series
The JRC proposes an information requirement on recyclability, expressed as a single score built from a point system. How easy or hard an item is to recycle is measured across four things: whether it’s recyclable at all, with elastane below 15 percent as one example; whether it’s easy to sort, such as the same composition inside and out; whether it’s easy to pre-treat, meaning free of coatings, prints, sequins and problematic dyes; and whether it suits recycling techniques that already work at operational scale, mechanical recycling among them.
The total score is what a manufacturer would have to disclose in the DPP. Trimco Group and Kezzler are already expanding our DPP data package to capture these fields, either directly from vendors or through a brand’s existing tech stack.
7. Recycled content
Not covered in the video series
Recycled content is the exception in this list, because it’s the one area the JRC frames as a performance requirement rather than an information one. There’s a number to hit, not just a number to report. The definition is deliberately broad: the proportion, by mass, of recycled fibres from post-industrial, pre-consumer and post-consumer waste in a textile product.
That breadth is intentional. The shared goal is still fibre-to-fibre, closed-loop recycling, but the industry isn’t ready for it, so open-loop recycling, PET bottles turned into polyester polymer for example, is allowed as a transitional phase.
The thresholds depend on the product. Denim carries a proposed 20 percent recycled cotton requirement. Woven and knitted items carry proposed material-specific targets: recycled polyester at 15 percent, wool at 10 percent, and nylon at 5 percent. Alongside the threshold sits an information requirement too, covering the weight of recycled material used and the type of feedstock waste it came from. The Trimco Group and Kezzler solution already collects recycled content by weight, and we’re expanding the package to meet the rest.
Why recycled content is a traceability problem
A performance requirement changes the burden. Information asks you to disclose a number. Performance asks you to hit one, and a number you have to hit is a number someone will eventually check.
That makes recycled content a traceability question before it’s a reporting one. A figure averaged across a season says nothing about the garment in a regulator’s hand, or in a customer’s. Item level identity closes that gap. Serialise the product and the claim stops being a statement about a style: it becomes evidence attached to a specific item, with the supplier declaration, the feedstock type and the certificate sitting behind it, at the granularity the claim was actually made at.
That’s the difference between a claim you assert and a claim you can prove, and only one of the two survives being checked.
The question the JRC leaves to you: granularity
One decision the JRC deliberately doesn’t make for you is granularity: model, batch, or item. The design options point towards style and model level data, but that isn’t the whole story. Some areas, chemical compliance among them, point towards serialisation instead.
And the moment a brand wants real value from the DPP rather than treating it as another tax, the useful questions lead back to item level anyway. Is this authentic? Who bought it? Has this product been sold? Answering those means serialisation, usually for a smaller incremental cost than brands expect.
▶ Watch Episode 8: Granularity, model, batch or item?
It isn’t only an EU story: China
The DPP isn’t a European project alone. China is developing its own digital product passport for textiles and apparel, with the same underlying aim of understanding and regulating what crosses its borders. It may well be published before the European version.
We’d like the two frameworks to align. That’s also why we keep returning to the same principle across this series. Build flexibly, not just for the EU.
▶ Watch Episode 9: DPP in China
What to do now
None of this requires waiting.
- Robustness and substances data mostly exists already. Structure it, and find the gaps.
- Environmental impact and recycled content are supplier conversations. Start them now, and get the right clauses into your procurement contracts.
- Granularity is a strategic choice. Decide it on the value you want from the passport, not on compliance alone.
- Underneath all of it, build a flexible data model, so that whichever design option the Commission picks, and whatever China lands on, you’re ready.
Watch the full series
The DPP Minute, sixty seconds an episode.
About the authors
Camilla Mjelde (Trimco Group) and Cyrus Gilbert-Rolfe (Kezzler) host The DPP Minute, a weekly sixty second series breaking down Digital Product Passport developments for apparel and textile brands. Trimco Group and Kezzler together help brands kickstart their DPP journey.
