The rules are not out yet, but Fusion, a sportswear company in Denmark, is already a year and a half into its preparations for its digital product passports (DPPs). But after thousands of hours crunching data about every product it sells, challenges remain in chasing down the most granular of insights.
Take for example its large black long-sleeve shirt, made entirely out of polyester and designed for running at lower temperatures. With 3.4 kilograms of carbon dioxide equivalent, its carbon footprint is about three times smaller than the industry average, thanks in part to a dyeing process that used a lower temperature to reduce energy consumption.
The bulk of its carbon impact could be attributed to two factors: the materials it used (34.9 percent) and how it processed them into the components that made up the shirt (36 percent). Its DPP showed that the textile was prepared, colored and finished in Fusion’s manufacturing facility in Denmark. To knit the polyester together, it sourced yarns from Turkey. But it was missing data: Where were the raw materials for the yarns sourced from?
“That shows how hard it is to collect all data for a certain product,” said Troels Vest Jensen, Fusion’s chief commercial officer, in an interview with Sourcing Journal. He said no one asked the brand to prepare this early, but as a premium sports brand, it knows that the real race began during preparations — way before the starting gun. “We want to be front-runners in this,” he said. “We are not waiting until it’s a law.”
Armedangels, a fashion company in Germany, faces a similar issue. It, too, is preparing early, with each of its products already having some publicly available form of DPP. The brand is working on adding more data, such as carbon footprint, but can only fully account for up to Tier 2 of its products, or its suppliers’ suppliers. Only around 33 percent of its products have full transparency from final manufacturer to raw material, according to Julia Aruni Kirschner, Armedangels’ director of impact and innovation.
All this for a law that has not yet been finalized. This specific law, which would detail what should be inside the DPP in the textile industry, is expected sometime in late 2027. It is an ambitious undertaking that would almost definitely change the way European governments and consumers expect transparency from the fashion industry. If everything goes according to plan, in 2030, the European Union will require each garment that enters the bloc to come with its own DPP, a unique digital footprint that would not only track the entire life cycle of the product, but account for its environmental impact and end-of-life instructions.
The task is nothing short of herculean. Fusion has around 170 product lines, but like any other fashion brand, they come in various materials, colors and sizes — variables that affect a product’s carbon footprint. A large shirt, for example, would have a different carbon impact from one that is extra-large. A black shirt, too, would be different from another shirt with a darker shade of black. Each variant would need its own DPP, he said. In total, he said this brings Fusion to around 2,000 DPPs for its entire stock keeping units. Jensen said the company is already 95 percent done with its DPPs, and it is planning to publish the data on its website.
“No matter how you look at it, that is a taxing undertaking on any company, and that’s OK,” Jonathan Davies, product marketing and content lead at Carbonfact, told Sourcing Journal. The company, which started in 2021 as a carbon accounting firm, has also been setting up DPP infrastructures for brands, including Fusion, after receiving a lot of client requests.
While a DPP also involves other components, he said Carbonfact focuses on environmental impact data “because that’s the hardest data to get right” given how complex the fashion supply chain is. “Most brands don’t know, down to Tier 4 (which refers to raw materials), who their actual suppliers are.”
Every brand, regardless of size, has its own mountain to climb for its products to even step foot in the EU, one of the world’s largest apparel markets in terms of revenue and imports. But the level of preparation differs across the global industry, with some further behind than others. This is particularly true for textile-producing countries in the Global South.
For example, China, EU’s top import source of textiles and apparel, reported no awareness whatsoever of this legislation, according to a 2025 survey by the United Nations Industrial Development Organization, which polled 200 companies in textile-producing countries. Bangladesh and Turkey, which followed China as top import sources for the EU, reported a moderate legal comprehension of 3 and 10 percent, respectively.
Even then, action does not always come after awareness. Although the final requirements will not come out until next year, the DPP initiative has been a hot topic since it was brought forth as a core initiative in 2024 by EU’s Ecodesign for Sustainable Products Regulation, a landmark law designed to eventually normalize sustainable and circular products in the bloc. But despite the gargantuan task ahead, or perhaps because of it, not everyone is preparing yet. Iris Skrami, who heads Renoon, a start-up she cofounded that provides DPPs for fashion brands, said they thought the ESPR law would prompt a lot of companies to prepare in advance. But instead, she said it had “the opposite effect.”
“This is because a lot of the legislation and regulatory events that have been happening in recent years have also created a lot of fatigue within companies,” she told Sourcing Journal. She said even progressive enterprises that had invested in technologies to be more transparent felt “regulatory fatigue” from other proposals that were put forward and then later, for one reason or another, scaled back or softened, such as the EU’s Corporate Sustainability Reporting Directive. So now they’re just waiting for the final law to come out.
Even the proposal for the DPP law is showing signs of softening. Raw materials, which generally account for the largest share of carbon emissions in any value chain, have been excluded from DPPs, according to the latest DPP recommendations by the EU’s Joint Research Committee. “All intermediate products, such as fabrics, yarns, fibers, are excluded from this scope,” the document, which is not adopted yet and may change, read.
The JRC said this was because including them would have created a “structural challenge” even for companies that do reasonable due diligence in obtaining information about their supply chains. “According to the current normal practices, most of the companies in the value chain can get information from their immediate suppliers, but usually information is lost about suppliers further upstream,” the JRC said.
With all the changes that happened and the changes that will likely come, it is easy to view DPP as an issue of compliance as opposed to the bigger issue of sustainability. It boils down to a question that many might not be able to admit out loud: Why are we doing this? Carbonfact’s Jonathan Davies has an answer: Just do it. Lay down the data foundation. It will matter regardless.
“You’re seeing this with consumer demand. You’re seeing this with brands evolving in the market. That demand for transparency is only increasing, be that regulatory or from consumers themselves voting with their wallets,” he said.
