Digital Product Passports and New Challenges for Vietnam’s Textile and Apparel Enterprises

For many years, environmental requirements for textile and apparel enterprises have focused primarily on issues visible within factories: water consumption, chemicals, energy, wastewater treatment, and waste management. However, new regulations in Europe are expanding the scope of oversight to cover the entire product life cycle. For exporters, the question is no longer simply whether a product meets technical requirements, but also whether the enterprise can prove its origin, composition, and production process through reliable data.

One of the important tools in this trend is the Digital Product Passport, commonly referred to as a digital product passport. This tool is established within the framework of the European Union’s Ecodesign for Sustainable Products Regulation, or ESPR. Although specific requirements for each product group still need to be set out in sector-specific legal documents, the policy direction is already quite clear: product data will become part of competitiveness in the supply chain.

From Product Standards to Life-Cycle Data Management

On July 18, 2024, Regulation (EU) 2024/1781 establishing a framework for setting ecodesign requirements for sustainable products entered into force. This regulation provides a basis for the European Union to issue more specific requirements for individual product groups, potentially including requirements related to durability, repairability, recyclability, the use of raw materials, and the provision of environmental information.

What is notable is that this approach does not stop at the import or sales stage. Manufacturers, importers, and relevant actors in the supply chain may have to provide information that enables regulators, businesses, and consumers to assess a product throughout its life cycle. The digital product passport is designed in this way: as an electronic data record linked to a product, batch, or product model, depending on the specific requirements.

For textiles and apparel, the data may relate to fiber composition, raw material sources, durability, repairability, care instructions, end-of-life treatment methods, and supply-chain information. Not every data field has yet been established for each type of clothing or textile product. Therefore, enterprises should not view the digital product passport as a fixed form that can be implemented once and for all, but rather as a data-management system that needs to be developed step by step.

Why Is the Textile and Apparel Industry Particularly Affected?

Textiles and apparel have a multilayered supply chain. A garment may use fibers supplied by one enterprise, yarn from another, and fabric woven and dyed at a different facility before being transferred to a factory for cutting, sewing, finishing, and packaging. Each stage generates its own set of data.

Under the traditional ordering model, apparel enterprises generally focus on technical specifications, delivery schedules, and quality control of the final product. As traceability requirements expand, data on materials and processes at earlier stages also becomes important. An apparel factory may not directly produce yarn or dye fabric, but it still needs to collect and verify information from suppliers if it wants to demonstrate the product’s compliance.

This is a major difference between batch traceability and life-cycle data management. Batch traceability is usually intended to identify when and where a product was made and which materials were used. Depending on how it is implemented, a digital product passport may require broader information about product characteristics, long-term usability, and options for handling the product after it is discarded.

What Changes Are Vietnamese Enterprises Facing?

First is the requirement to standardize data. Many enterprises already have information on materials, chemicals, or factory standards, but the data may be scattered across spreadsheets, emails, order-management software, and audit records. Units within the same supply chain may also use different names for the same type of material or record data using different units of measurement.

When customers need to enter data into a shared system, these differences will increase the time required for reconciliation. The risk is not limited to delayed order responses. If data is inconsistent, enterprises may face difficulties proving fiber composition, the origin of raw materials, or environmental claims.

Next is the need to clearly define responsibilities among supply-chain members. Yarn suppliers need to be responsible for yarn data; weaving and dyeing facilities need to provide information about their processes; and apparel enterprises must control the consolidation of data for the final product. Without rules governing access rights, update deadlines, and verification mechanisms, a digital record may become a difficult-to-control collection of documents rather than a tool for improving transparency.

Another change concerns investment capacity. Digital transformation in textiles and apparel is often viewed from the perspective of production automation, order management, or sewing-line optimization. The digital product passport adds another layer of requirements: data must be structured, traceable, protected, and capable of connecting with customer systems or platforms within the supply chain.

Do Not Wait Until Requirements Become Mandatory

The specific implementation timeline for each product group depends on the European Union’s implementing legal documents. However, exporting enterprises do not necessarily need to wait for a final template before beginning preparations. Building a basic data platform can help enterprises reduce future transition costs while also improving their current management capabilities.

First, enterprises need to map the supply chains for their key product groups. This map should identify suppliers of yarn, fabric, accessories, chemicals, and finishing services, along with the types of information each entity can provide. Stages that cannot yet be traced to the required level should also be recorded as data gaps rather than ignored.

The next step is to build a minimum data set for each product. This data set may include the product code, material composition, blend ratios, supplier, batch code, care-instruction information, and relevant certification records. This is not a legal checklist applicable to every situation, but a management foundation that enables enterprises to assess their ability to respond when customers or regulators request information.

Finally, enterprises need to designate those responsible for data. In many factories, environmental data belongs to the sustainability department, material data belongs to the procurement department, and product data is held by the technical or order-management department. Without a coordinating point of contact, the consolidation of information will depend on individual employees and be difficult to maintain consistently.

Digital Product Passports Do Not Replace Quality Control

One risk during the preparation process is that enterprises may equate data digitization with meeting sustainability requirements. The two issues are related but not identical. A digital product passport helps provide information, while product quality still depends on design, materials, production processes, and inspection methods.

If a product has a complete data record but is not durable, is difficult to repair, or cannot be appropriately handled after use, digitization does not change the nature of the product. Conversely, a well-designed product may still encounter obstacles when entering a supply chain that requires transparency if its data is incomplete.

Therefore, an appropriate strategy needs to combine three layers. The first is product improvement, such as selecting appropriate materials, increasing durability, and limiting designs that make recycling difficult. The second is process control, including chemicals, energy, water, waste, and production conditions. The third is data management, which records and demonstrates what the enterprise has done.

Risk of a Growing Gap Between Enterprises

Large enterprises with integrated management systems and long-term relationships with suppliers are generally better positioned to standardize data. Meanwhile, small and medium-sized enterprises may face difficulties related to software costs, specialized personnel, and their ability to require suppliers to share information.

This could create a new gap within the industry. Previously, competitiveness was primarily reflected in price, quality, capacity, and delivery time. In supply chains that increasingly value transparency, the ability to provide reliable data may become a criterion for selecting suppliers. Enterprises lacking data will not necessarily be excluded immediately, but they may need more time, incur higher inspection costs, or be limited to orders with lower requirements.

To avoid a situation in which each enterprise builds an incompatible system, coordination among industry associations, technology solution providers, and international brands will be very important. Common data templates, terminology guidance, and cost-sharing mechanisms could help small enterprises reduce the initial burden. This is an issue that needs to be discussed at the supply-chain level, not only at individual factories.

Preparing in a Practical and Verifiable Way

A very large technology project is not a mandatory starting point. A practical approach is to select a group of products currently exported to markets with high requirements, then test the process of collecting and verifying data. The results of the pilot will show which data is already available, which data needs to be added, and which stages may create inaccuracies.

At the initial stage, enterprises should prioritize data that directly affects traceability and product quality. The information should be linked to product codes or batch codes so that it can be checked retrospectively. Supplier records also need to be updated periodically, because a certificate or technical specification reflects only a particular point in time.

At the same time, enterprises need to exercise caution with environmental claims. Terms such as “green,” “sustainable,” or “environmentally friendly” only have value when accompanied by an appropriate scope, assessment method, and supporting evidence. A general claim that cannot be verified may create reputational and compliance risks, especially as buyers increasingly demand a clear distinction between measured data and marketing messages.

For regulators and industry-support organizations, the immediate priority is to improve enterprises’ access to information. European regulations are highly technical, while enterprises need more specific guidance on terminology, input data, and the allocation of responsibilities. Training in supply-chain data management may have an impact just as practical as support for investment in machinery.

A Challenge but Also an Opportunity to Upgrade the Supply Chain

The digital product passport is not the only factor determining the competitiveness of Vietnam’s textile and apparel industry. However, it reflects a broader trend in international trade: goods increasingly need to be accompanied by data about how they are created, used, and handled after their life cycle.

For enterprises involved only in the sewing stage, the new requirements may increase the pressure to coordinate with suppliers and customers. For enterprises investing in design, recycled materials, resource-efficient production, and supply-chain management, this is instead an opportunity to turn those results into evidence that can be used in commercial activities.

What needs to be monitored in the coming period is how the European Union specifies requirements for each product group, as well as the degree of consistency among brands and data platforms. While awaiting detailed requirements, the most valuable preparation for Vietnamese enterprises is to review their supply chains, standardize core data, and ensure that all product claims can be verified. When data becomes part of a product, information-management capacity will become part of production capacity.