Circle Economy’s recommendations for an effective Digital Product Passport for textiles

Our detailed responses on data point disclosure, granularity levels, access rights, and traceability requirements are included in our full questionnaire response, co-submitted with the European Environmental Bureau. We highlight the need for clarity on how different levels of data access will work in practice and stress that NGOs, trade unions, recyclers, repair operators, and consumer organisations should all be recognised as legitimate interest actors with appropriate access to relevant information. While recognising the limitations of the Product Environmental Footprint (PEF) methodology, we support the use of harmonised and comparable methodologies to ensure a level playing field in the European market.

Circle Economy brings practical experience from across textile value chains. Through our Global Value Chain and Textile programmes, we work with suppliers in South-East and South Asia to prepare for sustainability requirements and support sustainable production, while collaborating with end-of-life actors in the Netherlands and across Europe. This provides us with comprehensive insight into the practical implementation of the DPP.

As the European Commission develops the delegated act for textiles under the Ecodesign for Sustainable Products Regulation (ESPR), our recommendations are threefold:

1. Realise the full potential of the DPP

The DPP should be designed to deliver value beyond compliance. The data collected can strengthen value chain collaboration, support public authorities in monitoring market flows, and enable consumers to make more informed purchasing decisions. To achieve this potential, access should extend beyond economic operators. NGOs, trade unions, PROs, recyclers, repair operators, and consumer organisations should have appropriate access to relevant data as legitimate interest vendors. We also recommend including information on the number of products placed on the market

per model, enabling PROs to use this information when setting eco-modulated fees.

2. Support value chain actors during preparation and implementation

The complexity of collecting and managing DPP data should not be underestimated. Beyond Tier 1 suppliers, textile supply chains often lack transparency, while relevant information is frequently dispersed across multiple departments and not stored digitally. Building up the data collection, storage and verification process is costly, and usually borne by manufacturers alone.

The EU, together with brands and local development organisations in producing countries, should provide technical assistance, capacity building, and knowledge-sharing platforms to support DPP implementation. This will be essential to ensure that all actors can prepare effectively for compliance and avoid shifting compliance burdens down the supply chain in an industry where margins are already under pressure.

3. Ensure reliable and verifiable data

The success of the DPP will depend on the reliability of the information it contains. The JRC recommendations provide limited attention to how data accuracy will be ensured, despite this being a longstanding issue. Our 2020 study ‘Clothing labels: Accurate or not?’ highlighted that product information provided to consumers is often inaccurate. For sorters and recyclers, unreliable DPP data creates operational and financial risks, as they require accurate information on product composition and characteristics to ensure the quality of recycled outputs. Effective verification systems must therefore be developed alongside the rollout of the DPP.

Reliance on conformity certification alone is unlikely to be sufficient. Structural links between data points and traceable product units will be essential to ensure the integrity, credibility, and practical value of the DPP.

The Digital Product Passport is a first-of-its-kind traceability tool that reflects significant ambition. Circle Economy urges the European Commission to consider these recommendations, alongside those from other civil society organisations working towards a circular textile sector, to ensure the DPP delivers meaningful impact across the value chain.