Digital Product Passports Expand Transparency Requirements for the Textile Industry

The textile industry is entering a phase in which product data may be no less important than manufacturing capability, delivery times, or cost. In Europe, new regulations on ecodesign and sustainable products are laying the groundwork for a mechanism known as the Digital Product Passport. This mechanism aims to link a set of digital data to a product, thereby providing information about its materials, origin, durability, repairability, recyclability, and end-of-life treatment.

For Vietnamese textile companies, this is not merely a technical requirement imposed by an import market. It could affect how companies purchase yarn, manage fabrics, record dyeing processes, coordinate with accessories suppliers, and substantiate environmental claims. As European customers increasingly demand more specific information, product records will have to be prepared from the beginning of the supply chain rather than added at the time of export.

From Sustainable Product Regulations to Data Across the Entire Lifecycle

The European Union adopted the Ecodesign for Sustainable Products Regulation, commonly known as the ESPR, in 2024. This regulation establishes a broader legal framework for sustainability requirements across various product groups and provides the legal basis for implementing Digital Product Passports by product category.

Unlike an approach focused solely on the energy performance of certain devices, the ESPR expands its scope to cover a range of environmental and resource-related characteristics. Depending on the product group, requirements may concern durability, repairability, the use of recycled materials, resource efficiency, recyclability, or information needed to process products after they are discarded.

The Digital Product Passport is an important component of this structure. In essence, it is a collection of electronic information linked to a product through an identifier or an appropriate means of accessing data. Consumers, regulators, importers, retailers, repair providers, and recycling facilities may be granted access to different parts of the information.

Importantly, the regulation does not mean that every textile product will immediately have to carry the same type of record or the same level of data. The specific content depends on the implementing regulations for each product group. Companies therefore need to distinguish between the general legal framework that has been established and the detailed requirements that will apply to each product, market, or sales channel.

Textiles Are a Sector Clearly Affected

Clothing and textile products have multilayered supply chains. A shirt may involve fiber production, spinning, weaving or knitting, dyeing, finishing, cutting and sewing, printing, embroidery, packaging, and transportation. These stages are often carried out by multiple companies in multiple countries. If data is recorded only at the final sewing stage, companies will find it difficult to fully substantiate the characteristics of the product.

In this context, a product record means more than simply the fabric type or composition percentage printed on a label. The data may need to cover the type of fiber, the proportion of recycled fibers, the source of materials, information about chemicals or treatment processes, care instructions, repairability, and post-use treatment options. The actual level of detail will depend on the applicable legal requirements and standards, but the general trend is toward information that can be verified.

This represents an important change for companies that have traditionally managed data by order or in separate internal records. Fabric composition information may be held by the purchasing department, test documents by the quality department, supplier information by the import-export department, and production data in the factory’s system. When customers request a unified record, these pieces of data must be linked and cross-checked.

Traceability Goes Beyond the Factory Level

For many years, traceability in the textile industry has generally been understood as identifying the manufacturing facility or the place where an order was completed. Sustainable product requirements may expand this concept to cover the raw-material level and processing stages.

For recycled yarn, for example, companies may need to substantiate the source of the input materials and the proportion used in the product. For cotton, information about the source, certification standards, or control systems could become part of the commercial record, depending on customer requirements. For dyed fabric, information related to chemicals, water, and treatment processes may be considered under different sets of criteria.

This does not mean that companies must disclose all production data to every party. Digital Product Passports are designed to allow access rights to be assigned. Consumers may need simple information about composition, care, and disposal; regulators may need more detailed data; and recycling partners may be interested in material structure and fiber separation capabilities.

The Biggest Challenge Lies in Data Quality

Technology costs are often the first concern when companies discuss digitizing product records. However, the more difficult issue may lie in data consistency and reliability. The percentage of fiber composition stated in purchasing documents must match test results and published information. Shipment lot codes must be linkable to materials, production processes, and finished products. If data changes between departments without a control process, digitization will only transmit discrepancies more quickly.

Data from suppliers presents another challenge. Garment factories may not directly control the sources of yarn, chemicals, or accessories. Meeting the new requirements will therefore require coordination throughout the supply chain. Purchase contracts may need to include requirements concerning data formats, deadlines for supplying records, inspection rights, and responsibility when information is inaccurate.

For small and medium-sized enterprises, the challenge also lies in resources. They may not have enough budget to immediately implement a complex management platform, nor necessarily have a dedicated product-data team. A more appropriate approach is to start with key export product lines, establish a minimum data inventory, standardize coding methods, and test the process with several important suppliers.

A Digital Passport Should Not Be Equated with a QR Code

In commercial discussions, the Digital Product Passport is sometimes described simply as a QR code on a product. This understanding is incomplete. A QR code or another identification tool is merely a means of accessing information. The value of the system lies in the data behind it, how that data is authenticated, its ability to be updated, access rights, and the degree of interoperability among stakeholders.

A code that leads to a company’s general information page cannot replace a record containing specific product data. Similarly, placing a large amount of information on a platform without a verification process does not ensure that customer or regulatory requirements can be met. Companies need to view this as an information-management challenge, not merely a matter of printing an additional code on a label.

Impact on How Companies Organize Production

When environmental and material data become part of a product record, production decisions may be subject to an additional layer of evaluation. Changing the type of yarn, dye supplier, blending ratio, or finishing process affects not only quality and cost. It may also change the content of the record, the comparability of different batches, and compliance with customer requirements.

This creates an incentive for companies to introduce data management earlier in the product-development process. As soon as a collection is designed or an order is quoted, the company may need to determine what information must be collected, which standards will be used, and what evidence must be retained. This approach helps reduce the situation in which documents or supplier confirmations are only sought at the end of an order.

Digital Passports may also change the relationship between garment companies and international customers. Buyers with strong data-management systems may require suppliers to transmit information in a particular format rather than simply sending composition tables or certificates as separate files. Companies capable of providing data quickly, consistently, and in a verifiable form will have an advantage during supplier evaluations.

However, the Digital Product Passport should not be regarded as an automatic guarantee of orders or higher prices. Competitiveness still depends on quality, productivity, delivery times, costs, design, and the ability to meet many other requirements. Good data helps companies reduce transparency-related risks and better demonstrate their capabilities, but it does not replace the core elements of production.

Where Should Companies Start to Avoid Scattered Investment?

Preparation can begin with a data review rather than the immediate purchase of new software. Companies need to map the supply chain for each product group, identify the data they have, the data they lack, where it is stored, and who is responsible for it. Duplicate information or information recorded in multiple formats should be standardized before being entered into a system.

The next step is to classify data by importance. Product identification information, material composition, lot codes, suppliers, and test documents are generally foundational data groups. Other information can be added according to customer requirements, product regulations, or the company’s own management objectives. A layered approach helps companies control costs and avoid creating an excessively large database that is difficult to operate.

At the same time, companies should clearly identify which environmental claims they can substantiate. Terms such as “recycled,” “sustainable,” “environmentally friendly,” or “green production” have commercial value only when accompanied by appropriate criteria, scope, and evidence. Claims that go beyond the ability to verify them may increase legal and reputational risks.

Employee training is an inseparable part of the process. Purchasing staff need to know how to request data from suppliers; technical teams must understand the relationship between material changes and product records; quality teams need to control the evidence; and information technology teams must ensure access rights and data security. If the task is assigned only to a small group, the system will struggle to accurately reflect the factory’s actual operations.

Outlook: Data Will Become Part of Product Value

Europe’s legal framework indicates a shift from requiring companies to disclose general information toward organizing more specific data at the product level. In textiles, this process may progress unevenly across product groups and may not apply in the same way to every company. Even so, exporters are unlikely to be able to wait until a mandatory requirement appears before beginning preparations.

For Vietnam’s textile industry, the opportunity lies in turning transparency into a supply capability rather than viewing it solely as a compliance cost. Companies with reliable data will be better positioned when working with international brands, evaluating suppliers, controlling changes in materials, and responding to customer requests. In the long term, the same data platform could support multiple objectives, from quality management to measuring resource efficiency.

This is an analysis of potential impacts, not a claim that every textile company or every product is already subject to the same Digital Product Passport obligation. Companies need to monitor the European Union’s specific implementing regulations, individual customer requirements, and relevant standards before making investment decisions.

The immediate preparation required is a management mindset: every exported product should have a consistent, traceable data record that is updated whenever materials or processes change. As sustainability requirements become increasingly tied to the ability to substantiate claims, data is no longer merely a back-office part of production. It is becoming part of the product itself as it is sold on the market.