The digital product passport (DPP) serves as a structured digital data set within the framework of the Ecodesign Regulation for Sustainable Products (ESPR). These passports do not replace the duty of care. Rather, they function as “structured containers” for the data necessary to support them. Catherine Lomonaco, founder of GoTrace, emphasized this in a webinar on February 10th.
The OECD Forum’s side session on due diligence in the clothing and footwear sector highlighted a key shift in the textile and clothing industry. This change is moving away from pure self-reports towards verifiable data. Lomonaco emphasized the need to go beyond superficial claims. “Duty of care is not about claims, but about evidence, traceable information and ongoing risk management,” she explained.
The need for open data
For this information to be meaningful and accessible, it must be open. Nathalie Grillon, Chief Executive Officer (CEO) of the Open Supply Hub, addressed the systemic fragmentation that currently hinders supply chain transparency. She found that siled, closed data creates a reporting burden for suppliers. They also lead to inconsistent records for brands. Grillon suggests a move toward open data. Production sites are assigned a unique, neutral identifier (OSID) to ensure interoperability between different systems. She noted that “identification of establishments can and should be open, free and accessible to all.” Grillon emphasized that treating this data as public infrastructure is the only way to effectively scale the DPP ecosystem.
By adopting an open data model, the industry can reduce costs for small and medium-sized enterprises (SMEs). A meritocratic system can also be promoted in which achievements, not relationships, determine market access. Grillon illustrated this with a collaboration with the World Wildlife Fund. Overlaying operational data with potential drought areas allowed brands to jointly invest in protective measures. “Due diligence and digital product passports will only work if we treat operational data as public infrastructure and not as private assets,” concluded Grillon. She calls on the industry to move away from viewing the locations of delivery companies as private competitive advantages.
Paradigm shift in traceability
Another problem is tracing from the finished product instead of starting directly with the fiber. Rhys Davis, Chief Operating Officer (COO) of Aware, questioned this traditional “backwards” approach to traceability. In this, brands try to reconstruct the history of a product from the finished garment. He argued that this method is inherently unreliable as it often leads to unintentional greenwashing as brands lose visibility after the first two stages. Instead, Davis advocated for “forward tracking” from the source, starting as early as the cotton farm or plastic recycling plant. “If the information on manufacturing establishments is incorrect or missing, the DPP is no longer credible and, frankly, irrelevant.”
Aware’s solution includes a digital registry to which data is added in real time as the fiber moves through the supply chain. This physical-digital connection ensures that impact metrics, such as carbon emissions or water consumption, are captured at the point of production rather than estimated later. Davis emphasized that this approach empowers producers: it gives them “verifiable evidence for their claims” and shifts the burden of preparation from brands to suppliers. He argues that for a truly reliable DPP, the data must be primary and come from the actors who physically handle the material.
Implementation of verification at product level
Maciej Bulkowski, CEO of Caruma, focused on the practical implementation of DPPs at the collection level. It was specifically about upcycling and vegan alternatives. He presented a framework of “assertion, evidence, connection and action.” He argued that a DPP without a link to prove it was simply a marketing tool. Bulkowski showed that brands can build real trust with consumers. This is achieved by leveraging blockchain for immutable event records while keeping sensitive business data off-chain. “Traceability without verification is just storytelling, it is not due diligence,” he warned, emphasizing the need for audit-ready documentation.
A standout case study presented by Buklowski was the “Material First” approach to vegan leather. In this model, a DPP is assigned to the material origin before the product is even manufactured. This allows the finished garment to automatically “inherit” the verified history of the material. This ensures that the chain of custody remains unbroken from the factory floor to the store shelf. This method simplifies compliance for designers. It ensures that circular economy initiatives are supported by high-quality data and not vague promises. This provides a clear roadmap for brands that need to navigate the new EU regulations.
Preparation for future regulatory standards
The final question and answer session addressed the practical concerns of clothing manufacturers and brands regarding the upcoming EU regulations for textiles. Presenters believed that companies should start centralizing “essential” data. This includes product identifiers, material composition and operational locations, although the exact data standards are still being developed. They agreed that a wait-and-see attitude was no longer acceptable. Aligning with existing frameworks such as the UN Transparency Protocol is a smart interim step. Bulkowski noted that the industry is in a learning phase, stating, “We are learning how to use this information and how to build information in the DPP.”
Ultimately, the transition to DPPs represents a fundamental change. It affects the way the textile and clothing industry manages risks and communicates values. Whether through open operational mapping, fiber-level ledger systems, or blockchain-powered product passports, the goal remains a “single source of truth.” This source must last throughout the entire life cycle of a garment. While the industry waits for the EU regulations to be finalized, the consensus among these experts is clear: the transparency infrastructure must be collaborative and scientifically based. Above all, it must be based on verifiable evidence at every production phase.
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