How to Prepare Your Brand for the EU Digital Product Passport, and Where to Start (3/3)
The delegated act isn't finalized. The compliance deadline is still a few years away. Neither of those facts means you should wait. Here's how the brands navigating this well are thinking about preparation right now.
The information in this post reflects our understanding of the EU Digital Product Passport regulation as of the date of publication. Requirements and timelines are subject to change as delegated acts are finalized. This post is for informational purposes only and does not constitute legal or compliance advice. Please consult a qualified professional before making business decisions based on this content. For the most current information, refer directly to official EU sources at eur-lex.europa.eu and ec.europa.eu.
By now — if you've read Parts 1 and 2 — you understand what the EU Digital Product Passport is, why it exists, and what it will require from your brand at a data level. This final part is about what to actually do with that information.
The honest answer is: start now, even without the final text. Here's why — and what starting actually looks like.
Why waiting for the final text is a mistake
One of the most common responses we hear from brands about the DPP is some version of: "We'll wait until the delegated act is confirmed and then figure out what we need to do."
This is understandable. Regulatory timelines are uncertain, requirements may shift, and investing in compliance infrastructure before the rules are finalized carries real risk. But the brands that participated in DPP pilots in 2024 and 2025 consistently discovered something important: the gaps they found in their supply chain data were not gaps that appeared because of the DPP. They were gaps that already existed — in how they collected supplier information, how they verified fibre content, how they tracked certifications, and how well they understood their Tier 2 and Tier 3 supply chain.
The DPP didn't create those problems. It revealed them. And the brands that found them early had time to fix them. The ones that wait until 2027 will be fixing them under a compliance deadline.
Step 1 — Audit what you actually have
Before you can build toward DPP compliance, you need an honest picture of where your current data stands. This audit doesn't need to be comprehensive immediately — start with the Phase 1 requirements, since those are the most clearly signaled.
For each of your current SKUs, ask:
Fiber composition: Do you have this at the SKU level, and is it backed by verified supplier documentation or lab testing — or is it a declaration on a purchase order?
Country of manufacture: Is this documented for every SKU, and does it reflect where the product was actually assembled?
Chemical compliance: Do you hold current, valid certifications from your suppliers? When were they last updated? Are they centrally stored or scattered across individual email threads?
Supplier traceability: Can you name your Tier 1 suppliers for every SKU? Your Tier 2? Do your Tier 1 factories even disclose who their fabric suppliers are?
Care and durability: Is care information standardized and documented consistently across your line?
For most brands, this audit produces a mixed picture: strong in some areas, with significant gaps in others. That's normal — and it's useful information.
Step 2 — Map your supply chain beyond Tier 1
This is the step most brands find most confronting — and most valuable. Tier 2 and Tier 3 visibility (fabric mills, dye houses, yarn spinners) is where DPP compliance gets genuinely difficult, and where the most common gaps appear.
Start by asking your Tier 1 factories to disclose their primary fabric suppliers. This conversation is often easier than brands expect — particularly if it's framed as a joint compliance effort rather than a surveillance exercise. Factories that supply brands with sustainability commitments have often already begun this work.
Where Tier 2 suppliers are resistant to disclosure — citing commercial confidentiality — it's worth understanding whether that resistance signals a genuine competitive concern or a reluctance to be audited. The DPP framework is going to require this transparency eventually. The supplier relationships that will be most valuable in 2028 are the ones being built on that foundation now.
Step 3 — Assess your data infrastructure
A compliant DPP requires structured, machine-readable, dynamically accessible data. If your product data currently lives in spreadsheets, disconnected PLM systems, or is held informally by individual members of your development team, that's the infrastructure problem that needs to be addressed before the DPP deadline arrives.
The technology stack that brands implementing DPPs typically need covers:
A product information management (PIM) or PLM system that holds accurate, current BOM data and can be connected to downstream DPP systems
A supply chain traceability platform capable of collecting and verifying data from suppliers across multiple tiers
Compliance automation to flag gaps and ensure required data fields are complete before a DPP is generated
A digital identity and tagging solution — the QR code, NFC tag, or RFID that connects the physical product to its digital record
You don't need to build this entire stack immediately. But you do need to understand which parts of it you already have, which parts you'll need, and what the integration path looks like.
Step 4 — Run a pilot on a small SKU range
The most practical way to understand your DPP readiness is to try to build one. Pick a small range of three to five SKUs — ideally from a single factory with strong existing documentation — and attempt to compile what a DPP would need to contain.
This exercise will reveal your real gaps faster than any theoretical assessment. Brands that went through the Trace4Value pilot with Marimekko and Kappahl reported that the process surfaced serialization gaps, supplier data maturity issues, and internal system disconnects that would have been significantly more costly to fix under a live compliance deadline.
A pilot on a small SKU range is relatively low cost. Finding those gaps late is not.
Step 5 — Build supplier data collection into your development process now
One of the most leveraged things an established brand can do right now is adjust what they ask for from suppliers as part of the standard development process. If fibre composition verification, current chemical compliance certifications, and supplier identity documentation become standard requirements in your tech pack and purchase order process today, you'll be building a DPP-ready data asset with every season — rather than having to go back and reconstruct it retroactively.
This is also the step that tends to surface which supplier relationships are genuinely built for the future and which ones will become liabilities as compliance requirements tighten.
A note on Phase 2 and carbon data
Phase 2 requirements — carbon footprint and water consumption data — are expected to phase in between 2027 and 2030. These are significantly more complex to collect than Phase 1 data, requiring lifecycle assessment methodologies and primary factory data rather than estimates.
The good news: the EU's framework initially allows brands to use industry-average secondary datasets for environmental footprint disclosure, rather than requiring primary data from day one. The expectation is that this "average data loophole" closes around 2033. So Phase 2 compliance can begin with estimates — but the direction of travel is clearly toward primary, verified lifecycle data. Starting to collect it now, even informally, builds a meaningful head start.
The opportunity inside the obligation
It's worth saying clearly: the DPP is a compliance requirement, and there's real work involved in meeting it. But for established brands that have genuinely invested in ethical sourcing, verified materials, and transparent supply chains, it's also an opportunity.
The DPP replaces marketing claims with verified data. Brands that have the data to back up their sustainability positioning will be able to demonstrate it in a way that's auditable, consumer-accessible, and structurally protected from greenwashing accusations. That's a competitive advantage — particularly as EU consumers and retail buyers increasingly make purchasing and stocking decisions on the basis of verified environmental credentials.
The brands that treat DPP preparation as a supply chain investment rather than a compliance burden are the ones that will arrive at 2028 in the strongest position.
At Guided Makers, we work with established apparel brands navigating operational decisions like this one. If you want to talk through what DPP readiness looks like for your specific supply chain, we'd welcome the conversation.
The information in this post reflects our understanding of the EU Digital Product Passport regulation as of the date of publication. Requirements and timelines are subject to change as delegated acts are finalized. This post is for informational purposes only and does not constitute legal or compliance advice. Please consult a qualified professional before making business decisions based on this content. For the most current information, refer directly to official EU sources at eur-lex.europa.eu and ec.europa.eu.