Digital Product Passports and the New Data Challenge for Vietnam’s Textile and Garment Industry

For many years, traceability in the textile and garment industry was generally understood as the ability to identify the supplier of yarn, fabric, accessories, or a production stage when requested by a customer. This approach is changing. With new regulations on ecodesign and product information in the European Union, data is no longer merely documentation for internal checks or export files. Data is becoming part of the product itself.

The concept frequently mentioned in this transition is the Digital Product Passport. This passport may contain information related to a product’s materials, origin, durability, repairability, recyclability, and environmental impacts, depending on the requirements applicable to each product group. For Vietnamese textile and garment enterprises, this is not a standalone software solution that must be purchased immediately, but rather a challenge of reorganizing data throughout the supply chain.

New requirements may affect many businesses at the same time, from export garment factories and fabric suppliers to dyeing and finishing facilities, yarn suppliers, and accessory providers. Enterprises that manage information only at the final stage will find it difficult to answer fully questions related to the product’s entire life cycle.

What policy changes are driving the development of Digital Product Passports?

On June 13, 2024, the European Union issued Regulation (EU) 2024/1781 establishing a framework for setting ecodesign requirements for sustainable products. This legislation expands the approach beyond focusing solely on the energy performance of certain product groups. Under the regulation, requirements may relate to durability, reusability, upgradability, repairability, maintenance, recyclability, resource use, and product information.

The regulation also provides a basis for establishing Digital Product Passports for selected product groups through specific implementing measures. A Digital Product Passport does not mean that a single label format will immediately apply to every product. The data content, responsible parties, access methods, and technical requirements will depend on the product group and subsequent implementing legislation.

For the textile and garment industry, this is significant because clothing, footwear, and related products often have multilayered supply chains. A shirt may use yarn from one source, be woven at another facility, dyed at a third location, cut and sewn at an export factory, and finished with multiple types of accessories. If information is stored separately for each order, compiling it to meet customer or regulatory requirements will take considerable time.

This is not only a requirement for the sewing stage

Garment factories are often the businesses that interact directly with international customers, so they can easily become the point where requests for information are received. However, much of the important data is located in earlier stages. Fiber composition, the proportion of recycled materials, yarn origin, dyeing processes, chemicals used, water consumption, and certification records often need to be provided by material and processing suppliers.

Therefore, garment enterprises cannot address Digital Product Passports simply by adding another QR code to the packaging. The access code is only the presentation layer. Behind it must be structured data, clearly assigned responsibility, verifiable evidence, and an updating process for when materials or suppliers change.

Which data could become a competitive requirement?

Not all information about a product necessarily needs to be made public to every audience. However, enterprises should classify data from the outset so they know which information serves customers, which serves regulatory authorities, and which needs to remain confidential because it relates to production know-how or commercial relationships.

The first data group is product identification information. This may include the product code, version, production batch, manufacturing facility, and production date. The second group concerns material composition, such as fiber type, blend ratios, raw material origin, and the proportion of recycled material, if any. The third group relates to the production process, including the main stages, participating facilities, and relevant certifications or inspection records.

The next data group is connected to the use and post-use stages. Durability, care instructions, repairability, disassembly capability, and sorting instructions for when a product is no longer used may become more important in business models that emphasize the circular economy. For retailers, this data also supports product explanations for consumers and the management of take-back programs.

In practice, environmental information is often the most difficult part to standardize. An enterprise may know how much electricity or water its own factory consumes, but it may not have consistent data from yarn, fabric, and accessory suppliers. If each partner uses a different calculation method, the figures are difficult to compare. This is why environmental data needs to be accompanied by measurement methods, calculation boundaries, and supporting records, rather than being presented merely as an isolated number.

Traceability does not mean making the entire supply chain public

A common concern among enterprises is that they will have to disclose the names of all suppliers, purchase prices, or production formulas. This is not the only way to build a traceability system. Enterprises can design role-based access rights, allowing consumers to receive suitable information to understand the product, customers to receive the necessary technical data, and assessment or regulatory authorities to inspect detailed records when there are grounds to do so.

What matters is that enterprises clearly determine where each piece of data is created, who has the right to edit it, who approves it, and how long it is retained. If an employee can change material information without leaving an audit trail, the system will be difficult to regard as reliable in an assessment.

Immediate impacts on Vietnamese textile and garment enterprises

The first impact is administrative cost. Enterprises that have long used separate spreadsheets, exchanged documents by email, or stored records by customer will need to standardize material codes, supplier codes, and document-naming conventions. This work does not generate revenue immediately, but it determines the ability to respond when traceability information is requested.

The second impact is a change in supplier relationships. Garment factories may need to include data requirements in purchasing contracts, supplier evaluation procedures, and acceptance conditions. A fabric batch will not be assessed only on color, weight, or shrinkage; records concerning composition and origin may also become part of the acceptance criteria.

The third impact concerns product design. As information about durability, repairability, and recyclability receives greater attention, design teams cannot focus solely on optimizing appearance and material costs. The use of multiple blended materials, difficult-to-remove accessories, or structures that make products difficult to repair may create additional problems in the post-use stage.

However, the level of impact will not be the same for every enterprise. Contract manufacturers may receive data requests from international brands before having direct obligations under a specific legal instrument. Enterprises selling products under their own brands, meanwhile, must address consumer-facing data, legal responsibility, and the consistency of information across multiple sales channels at the same time.

Opportunities for enterprises that have invested in production management

Digital Product Passports are often viewed from the perspective of compliance costs, but they can also create operational benefits. When material data, production batches, and defect rates are linked, enterprises can identify the causes of quality problems more quickly. When purchasing and production data are standardized, comparing suppliers or assessing the risk of material shortages also becomes easier.

A strong data system can also help enterprises limit unsupported environmental claims. Instead of using general descriptions such as “green” or “sustainable,” enterprises can explain specifically what materials a product uses, what records are available, the scope of the data, and which areas still need improvement. This cautious approach may reduce the risk of information being considered misleading.

Even so, data digitalization should not be viewed as a substitute for improving production. Software cannot turn materials with unclear origins into traceable materials. Similarly, attaching an identification code cannot by itself prove that a product is highly durable or has a low environmental impact. Technology only helps record and transmit information; the quality of that information still depends on actual processes.

Where should enterprises begin?

The first step is to map data for a specific product group instead of implementing a system across the board. An enterprise can select a key export product line, identify the stages from raw materials to finished goods, and list the records currently available. The gap between the data required and the data actually available will indicate whether the problem lies in the internal system or with suppliers.

The second step is to establish a common data dictionary. Concepts such as recycled yarn, organic materials, blended composition, production batch, or processing facility need to be clearly defined internally. If departments use the same term but understand it differently, the information uploaded to the system may still be inconsistent.

The third step is to build an evidence process. Each important piece of information should be linked to a corresponding document or source. When a material proportion is disclosed, the enterprise needs to know whether that proportion is based on supplier records, test results, or third-party certification. When information is changed, the system needs to retain a history so that the reason and timing of the update can be explained.

The fourth step is to test the process with suppliers. An enterprise will struggle to produce reliable data if partners in earlier stages cannot provide basic information. Instead of sending only a long list of requirements, the enterprise should define a minimum data set, provide instructions for completing it, and conduct a trial with several orders. The results will show which requirements are feasible and which need more time or technical support.

Do not wait until customers provide a form

Many enterprises only begin compiling data after receiving a questionnaire from a brand or importer. This approach helps address the immediate request, but it often means that the same information is provided through multiple forms. In the long term, employees have to re-enter data, the risk of discrepancies increases, and the enterprise finds it difficult to determine which version is official.

Early preparation does not mean investing immediately in a complex system. Small enterprises can start with standardized procedures, coded records, and clearly defined access rights. As the number of products, suppliers, and markets grows, the system can be expanded according to need. What should be avoided is digitalizing a process that already lacks control.

The outlook for textile and garment supply chains

Digital Product Passports may change how parties in the supply chain divide responsibility. Garment factories will no longer be the only parties under pressure to compile information. Yarn, weaving, dyeing, and accessory suppliers may have to provide more structured data, while brands and retailers will need to determine which information should be collected, verified, and disclosed.

This trend also raises questions about accessibility for small and medium-sized enterprises. If data requirements are designed to be overly complex, compliance costs may become a barrier for facilities with limited staff and no digital management system. Conversely, if the parties agree on a basic data set and use interoperable standards, small enterprises may be able to participate in supply chains at a more reasonable cost.

At the industry level, the advantage will belong to enterprises that regard data as a production capability rather than merely an external administrative procedure. Data helps prove origin, but it also helps enterprises understand their cost structure, their dependence on individual suppliers, and the points where errors are most likely to occur. This is intrinsic value even when a specific legal requirement does not yet apply to the enterprise’s products.

For Vietnam’s textile and garment industry, the biggest challenge does not lie in creating an attractive interface for a Digital Product Passport. The challenge is ensuring that information from raw materials to finished products can be verified, updated, and explained. Enterprises that begin by clarifying processes, standardizing records, and cooperating with suppliers will have a stronger foundation as market requirements continue to become more specific.