Fashion Law Journal
Currently, the European Union is aiming to reorganize the fashion sector with a green approach, providing new regulations, directives, and decisions as part of the Green Deal project.
In particular, with respect to fashion, the Ecodesign Regulation, within the framework of the Sustainable Product Initiative, establishes new rules regarding textiles and clothing. Among the most important provisions, it is noteworthy to mention those concerning the DPP (Digital Product Passport).
The DPP is a new mandatory tool designed to enhance transparency across product value chains by providing information about the product’s origin, materials, environmental impact, and disposal recommendations. It seeks to meet consumer demand for transparency and address the lack of reliable product data from companies.
The DPP is more than a simple label; it is a unique product identifier that contains all the most important information linked to a product—not only about materials but also user manuals, safety instructions, product disposal, and, of course, details about the product’s lifecycle.
Such information can be obtained via a QR code scan or RFID chip. As previously mentioned, this entails: increased transparency for consumers and stakeholders, offering clear and verifiable information about the product’s origin and production; the promotion of sustainable practices aimed at reducing the environmental impact and improving social conditions during production; the promotion of a circular economy, facilitating the recycling and reuse of materials and products.
Although the DPP is not yet technically defined, it is known that it will be necessary:
- To provide DPP information easily accessible directly from the product itself or its packaging, without the need to consult external sources or separate paper documents;
- The medium, whether physical or digital, used to store and present information about a product, as well as the unique product identifier (a specific code assigned to each product that uniquely distinguishes it globally from all others), must comply with the guidelines and requirements established by the ISO standard, ensuring global, unique, and traceable identification for products;
- The information in the DPP must follow publicly accessible and shared standards, be formatted in a way that different systems and platforms can use it without issues, and must be easily readable and searchable by users.
The DPP will be gradually introduced between 2026 and 2030 to allow businesses and EU Member States to progressively adapt to the new regulations and technical requirements.
This gradual introduction is necessary due to the complexity of the system, which requires the creation of digital infrastructures to store and share product information via reference standards for data collection and transmission.
In addition, companies will need to update their production and data management processes in the least economically impactful way possible, especially for start-ups and SMEs.
The DPP will first be mandatory for the product categories with the most environmental impact, including the textile industry, which will need to comply with the DPP starting from 2026.
Nevertheless, some fashion companies have already begun adopting the Digital Product Passport to benefit from the advantages of this tool, which allows for a strong connection with consumers who are increasingly focused on choosing brands that demonstrate social and environmental responsibility.
In the textile sector, the introduction of the DPP integrates with traditional product labeling to ensure complete traceability and improve the sustainability of products.
Indeed, labeling on textile products is already mandatory according to various laws in force at the European and international level, generally including information such as material composition, washing instructions, origin and manufacturing brand, as well as size, color, and other specific characteristics.
The physical label remains the most immediate tool for the consumer to view essential information quickly.
The DPP adds another layer of digital information to the product, as we mentioned, via a QR code or RFID chip, directly on the physical label or on the product itself. In addition to the physical label information, the digital passport may include more detailed and dynamic data not listed on the physical label, such as supply chain traceability (where and how the materials were produced), environmental footprint (e.g., CO2 emissions impact, use of natural resources), the entire product lifecycle (how to dispose of, recycle, or reuse it), and any sustainability or quality certifications.
Using open data principles, all the product information is publicly available, providing transparency and accessibility. This means that the DPP will drive transparency, accountability, and sustainability.
References
- European Union Regulation on ESPR (EU No 1781/2024)
- Sustainable Product Initiative https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12567-Sustainable-products-initiative_en
- European DPP Initiative https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14382-Digital-product-passport-rules-for-service-providers_en
- European Guidelines DPP in the textile sector https://www.europarl.europa.eu/RegData/etudes/STUD/2024/757808/EPRS_STU(2024)757808_EN.pdf
Authors:
Camilla Gentile
Camilla Gentile graduated in Law from the University of Brescia, with a thesis focused on the legal protection of intellectual and industrial property rights. Licensed to practice law, in 2022 she co-founded Close to Ius, a law firm distinguished by its modern and personalized approach to legal consulting, assistance, and training for professionals and businesses. The firm, already featured in the prestigious Forbes magazine, was also a finalist at the Legal Community Forty Under 40 Awards in the category Law Firm of the Year – IP & TMT. In addition to her legal practice, Camilla is a contributor to the legal magazine Ius in Itinere and a member of the editorial board of Fashion Law Journal, where she also teaches. With a particular focus on the evolving legal landscape of fashion law and intellectual property, she combines her legal expertise with ongoing academic research, enriching her knowledge with a keen analysis of the legal challenges in the world of innovation and creativity.
Isabella Carantani
Isabella Carantani earned her Law degree from the University of Brescia in 2019 and obtained her license to practice law in 2021 after completing training in civil and criminal law. In January 2022, she co-founded Close to Ius, a law firm known for its modern and personalized approach to legal consulting, assistance, and training for professionals and businesses. The firm has been featured in Forbes magazine and was a finalist at the Legal Community Forty Under 40 Awards in the category Law Firm of the Year – IP & TMT. Isabella Carantani is a senior contributor for the Fashion Law and Influencer Marketing section of the online legal magazine Ius in Itinere, where she writes articles on topics such as fashion law, sustainability, intellectual property, influencer marketing, artificial intelligence, and privacy. She also collaborates with the international Fashion Law Journal, bringing an international perspective to industry-related issues thanks to her expertise and the contributions of her law firm.
