Digital Product Passports: A New Step in Textile Traceability

For many years, traceability in the textile industry has focused mainly on identifying raw material suppliers, production facilities, and commercial documentation. This approach is changing as major markets move from requiring individual declarations to managing data throughout the product life cycle.

One policy that could have a significant impact is the European Union’s Ecodesign for Sustainable Products Regulation, commonly known as the ESPR. This regulation establishes a legal framework for digital product passports, in which data related to materials, durability, repairability, recyclability, and environmental impact can be linked to individual products or groups of products.

For textile companies, this is not simply a matter of placing a QR code on a label. The core issue is the ability to collect, verify, link, and share data from fibers, fabrics, dyeing, and finishing through garment production, distribution, and post-use treatment. Companies that view this as a data and supply chain governance project, rather than merely a compliance requirement, will have more opportunities to take the initiative as new regulations are implemented.

ESPR Places Life Cycle Data at the Center

The EU’s ESPR was issued in 2024 to create a common framework for improving the sustainability of many product groups. The regulation allows the EU to establish specific requirements for each product group through subsequent delegated acts. Textiles and footwear are among the product groups identified as priorities in the policy development process.

The digital product passport is an important component of this legal framework. Under the direction of the ESPR, the passport may provide essential information to many stakeholders across the value chain, from businesses, regulators, and buyers to repair, reuse, and recycling operators. The specific scope of the data will depend on the regulations applicable to each product group.

One notable point is that a digital product passport does not mean all commercial data will be made public to everyone. The regulation is expected to distinguish access rights among different groups of data users. Some information may be intended for consumers, while technical data or sensitive supply chain information may be provided only to competent authorities or appropriate partners.

From Shipment Records to Verifiable Data

In the textile supply chain, a product typically passes through many stages and businesses. Fibers may be spun into yarn in one country, woven or knitted in a second, dyed in a third, and cut and sewn somewhere else. If each stage uses a different coding system and recording method, consolidating the final data will be difficult, even when a company already has internal records.

Digital product passports therefore create a need for interoperability. Data must be linked to a stable identifier, capable of being updated as the product moves to the next stage, with a mechanism for identifying the responsible party. A standalone spreadsheet or a set of documents serving only one order may not be sufficient if it cannot be reconciled with input data and production results.

This also changes the meaning of traceability. Traceability is no longer only about answering the question “Where was the product manufactured?” It must also be able to explain “What materials was the product made from, what processes did it go through, and what data proves this information?”

Data Layers Textile Companies Need to Prepare

It is not yet possible to determine all the mandatory data fields for each textile product before the specific product regulations are issued. However, based on the direction of the ESPR and the EU Strategy for Sustainable and Circular Textiles, companies can begin preparing several foundational categories of information.

Product Materials and Composition

The first data category concerns fiber and material composition. Companies need to clearly distinguish the proportions of different fibers, the sources of raw materials, recycled materials where applicable, and additional components such as sewing thread, zippers, buttons, coatings, or composite materials. Recording information at the level of the finished product needs to be linked to supplier data, rather than relying only on general descriptions in sales records.

For recycled fibers, information about the source of input materials and the method used to verify the recycled content may become important factors. A claim about “recycled material” has limited value if the company cannot provide documentation, test results, or an appropriate control system to substantiate that claim.

In addition, companies need to be aware of the difference between product design data and actual data for each batch. A garment sample may be designed with a fixed composition, but substitute materials, differences among suppliers, or changes during production may cause the final information to vary. Management systems need to be able to identify these changes.

Durability, Repairability, and Post-Use Treatment

The EU’s sustainable textiles strategy emphasizes the goal of making textile products more durable, easier to repair, and more recyclable. As a result, product data may extend beyond the origin of the materials. Information related to care instructions, the replaceability of certain components, disassembly methods, or end-of-life treatment options may also become important.

For companies, this requires coordination among design, engineering, procurement, quality management, and production departments. A product declared to be easy to recycle but made with multiple combined material layers that are difficult to separate can create a gap between the published information and its actual processing potential.

Product design also needs to be considered earlier in the compliance process. If repairability or recyclability requirements are checked only after a sample has been completed, adjustment costs are generally higher and may affect delivery schedules. Conversely, incorporating these criteria into the product development stage helps companies identify areas of non-compliance early.

Direct Impacts on Vietnamese Companies

Vietnam is an important link in the international apparel supply chain, but domestic companies participate at different stages and have uneven levels of data control. Companies that own brands or work directly with international buyers may have greater responsibility for consolidating information. Meanwhile, contract manufacturers still need to provide accurate data to customers so that complete product records can be prepared.

The first impact is the cost of organizing data. Companies may need to review raw material codes, supplier standards, change-approval procedures, and methods for storing production records. If information is scattered across emails, spreadsheets, order management software, and paper files, reconciling it when requested will take considerable time.

The second impact relates to supplier relationships. At the garment manufacturing stage, a company cannot independently create reliable data about yarn or fabric if the raw material supplier cannot provide corresponding information. Therefore, the ability to meet new regulations will depend partly on the quality of governance across the entire supply chain, not only on the final garment factory.

The third impact is the requirement to control environmental claims. Terms such as “green,” “sustainable,” “environmentally friendly,” or “recycled” may face stricter scrutiny if they are not accompanied by clear criteria and evidence. Companies need to distinguish between verified data, information self-declared by suppliers, and marketing statements. These three types of information should not be used in the same way.

Small and Medium-Sized Companies Face Resource Constraints

Large companies generally have the resources to invest in management software, testing laboratories, and compliance teams. For small and medium-sized companies, the challenges may involve costs, personnel, and access to technical standards. However, being unable to implement a complex system immediately does not mean that all data standardization efforts can be postponed.

A practical roadmap could begin with mapping the supply chain for key export products. Companies need to know what data is available, what data is missing, who is responsible for updating it, and which information needs to be independently verified. They can then standardize basic data fields before selecting a technology solution.

It is important to avoid investing in software before processes have been agreed upon. An expensive system will not solve the problem if input data is incomplete, product codes are inconsistent, or departments lack clearly defined responsibilities. Technology should support governance processes, not replace process design.

Upgrading the Supply Chain Instead of Simply Meeting Regulations

Digital product passports may create additional pressure, but they also open up opportunities to improve how companies operate. When raw material, production, and quality data are linked, companies can reduce the time spent searching for records, quickly identify batch-related problems, and improve their ability to respond to customers.

Standardized data also helps companies assess suppliers based on more than price and delivery time. The ability to provide material information, maintain consistent quality, control chemicals, and ensure transparency may become part of the partner selection process.

From a design perspective, information about material proportions, product structure, and post-use treatment options can support companies in developing differentiated product lines. This does not guarantee that products will sell at higher prices, but it gives companies a more concrete basis for discussing technical and environmental requirements with customers.

In the long term, building reliable data can support circular business models such as repair, reuse, take-back, or recycling. These models can operate effectively only when the organization receiving the product knows what materials it contains, how it can be disassembled, and which treatment method is required.

What to Monitor in the Coming Period

The ESPR is a legal framework, while specific requirements for each product group will continue to be developed through the EU’s regulatory process. Therefore, companies should not treat a current set of forms as the final requirement. A more appropriate approach is to build a system that can be updated when data fields, verification methods, or disclosure requirements change.

Exporters also need to monitor requirements directly from buyers. In many cases, brands may request data before legal obligations fully apply to each product. These commercial requirements can serve as early preparation for mandatory standards in the future.

Three issues should be prioritized: the quality of supplier data, the ability to link records through product codes, and mechanisms for verifying claims about materials or environmental performance. If these three foundations are established early, companies will be better positioned when customers request deeper traceability or regulators introduce new requirements.

For Vietnam’s textile industry, digital product passports should therefore be viewed as part of a broader management transformation. Regulations may begin in export markets, but data capabilities, circular design, and supply chain control will increasingly affect companies’ competitiveness across many different markets.