Fashion has a habit of leaving the hardest operational work until the pressure becomes impossible to ignore. That instinct will be expensive when it comes to the Digital Product Passport.
Too many brands still treat DPP as something off in the distance: another Brussels acronym, another regulatory file, another issue for sustainability, legal or compliance to decode later. But that reading is already outdated. The Digital Product Passport is not just another reporting exercise, and it is not only relevant to European brands. It is fast becoming a market-access requirement for any company that wants to sell into the EU.
That changes the conversation. This is no longer about whether a brand is “following” regulation. It is about whether it is preparing for the next operating conditions of one of the world’s most important consumer markets.
Over the past year, we have had more than 800 conversations with fashion brands across categories, price points and geographies. The same pattern keeps appearing: awareness is rising, but action is lagging. Most leadership teams now recognize the acronyms (ESPR, DPP) and understand that something significant is coming. But in too many companies there is still no clear owner, no implementation plan, no cross-functional coordination and no real sense of timing.
That may not feel urgent yet. Inside a fashion business, there is always something louder: demand fluctuations, margin pressure, sourcing volatility, late deliveries, seasonal deadlines, inventory risk. Against that backdrop, DPP can still look like a future compliance issue. In reality, it is a current infrastructure issue.
Iris Skrami
The Digital Product Passport is not a marketing extra and it is not another ESG talking point. It is part of the EU’s Ecodesign for Sustainable Products Regulation and will require products sold into the single market to carry structured, standardized digital information. In practice, that means data on materials, origin, manufacturing, care, repair and end-of-life, accessible through a QR code or NFC tag.
In other words, the product label is being rewritten for a digital, traceable market.
For textiles, rollout begins from 2027. On paper, that may still sound manageable. In practice, anyone who works in fashion knows that timelines are never as generous as they look. By the time a product reaches the shop floor, critical decisions have already been made across design, development, sourcing, production, compliance and logistics. Supplier data is often incomplete. Systems are rarely connected cleanly. Accountability is spread across functions. None of that gets fixed in the final stretch before enforcement.
The brands making the fastest progress are not necessarily the biggest or the loudest. They are the ones treating DPP for what it is: infrastructure. They understand that supplier data cannot be cleaned up overnight, and that traceability cannot be improvised a season before enforcement.
Others are still moving in fragments. One team explores traceability. Another looks at claims. Another discusses product data. Vendors pitch solutions. Pilot projects pop up. Internally, it can look like momentum. In reality, it often produces duplication, confusion and false comfort.
The issue is rarely total inaction. It is partial action without operational ownership: enough activity to create the impression of progress, not enough alignment to deliver readiness.
That matters because waiting comes at a cost.
Eva Kruse
Waiting until every delegated act is finalized may sound prudent. In practice, it means compressing years of operational groundwork into one or two buying cycles. That is when supplier gaps surface, systems get rushed, teams scramble and products are ready physically but not legally. It is also when the cost of delay becomes painfully visible.
For non-EU brands, this is particularly easy to underestimate. The law may be European, but the impact is not. If Europe is a sales market, then DPP becomes part of the cost of serving that market, just like customs documentation, safety requirements or fiber labeling rules. Europe is too important a consumer market for global brands to treat this as someone else’s problem.
And Europe will not be the end of it. Momentum is building globally toward more transparent, traceable and digitally accessible product information. DPP is not a niche compliance exercise. It is the next evolution of how products are documented, verified and trusted.
That makes this a leadership question, not just a compliance one.
Yes, the timing feels brutal. Demand is uneven. Margins are under pressure.
The industry has absorbed wave after wave of new requirements, and there is understandable fatigue attached to the prospect of another one.
But delay is not a relief strategy. It is usually the most expensive option on the table.
So what should CEOs do now?
Start by treating DPP as a core business issue. Not a sustainability initiative. Not a legal footnote. Not a pilot. A business issue.
Second, map where the real gaps are — in supplier data, systems, internal accountability and product processes. Most companies do not need another workshop. They need a clear picture of what is missing and how long it will take to fix.
Third, start building the infrastructure before every final detail is settled. Waiting for complete certainty is a recipe for compressed timelines, higher costs and avoidable disruption.
This is no longer a question of whether the Digital Product Passport is coming. It is a question of who will be ready when it does.
This is where leadership matters. Because the cost of delay is not theoretical. It shows up in rushed implementation, avoidable complexity and lost room to act strategically.
The brands that act now will not just be more compliant. They will be more prepared, more resilient and more competitive in the market ahead.
Iris Skrami is cofounder and CEO of Renoon, a European Digital Product Passport and product data infrastructure company working with brands on ESPR and DPP implementation.
Eva Kruse is founder and former CEO of Copenhagen Fashion Week and Global Fashion Agenda and a long-standing adviser to fashion leaders, institutions and policymakers globally.
