What Fashion Brands Can Collect for DPP Now — Before the Textile Delegated Act

Waiting for the delegated act is not the same as collecting nothing

Many fashion compliance teams are adopting a "wait and see" approach, assuming that no action is required until the textile-specific ESPR delegated act is finalized. This assumption is risky. While the exact data fields for the textile sector are expected to be set in late 2027, the general framework for Digital Product Passports (DPP) is already established. The mandatory DPP compliance for textiles and footwear is expected to land in the 2027-2028 window once the delegated act is finalized. Waiting until the final text is published means starting from zero with data collection, supplier onboarding, and system integration. By starting now, you build the data infrastructure that will be required, ensuring you are not scrambling to retrofit legacy systems in the final months before the deadline.

Fields Art. 9-11 already names

Regulation 2024/1781, specifically Articles 9-11, already defines the general structure of the DPP. This is not a placeholder; it is a binding legal framework that outlines what must be included. The current structure covers:

• Unique product identifier (QR / RFID / data matrix)
• Material composition (fiber types, origin)
• Technical and safety information
• Environmental performance data (durability, repairability, recyclability, carbon footprint)
• Manufacturer/importer details
• Instructions for use and care
• End-of-life instructions (disassembly, recycling pathway)

These fields are not speculative. They are the baseline. Your data teams should be mapping these categories immediately. If you cannot currently provide a carbon footprint figure or a repairability score for a specific SKU, that is a gap you need to identify now, not in 2027.

Material composition and origin you can start mapping

Material composition is one of the most critical and complex areas for fashion brands. The regulation explicitly requires fiber types and origin. This goes beyond simple labeling. It requires a granular understanding of your supply chain. For example, if a jacket contains 80% recycled polyester and 20% organic cotton, you must be able to verify the origin of both fibers. This often requires deeper supplier engagement than standard compliance audits. Start by auditing your Bill of Materials (BOM) for every SKU. Identify where you have gaps in origin data. This is a data hygiene exercise that will save significant time when the delegated act specifies exactly how this data must be formatted.

What is still unspecified for textile supply-chain fields

It is important to be precise about what is not yet defined. Supply chain information is not yet fully specified for textiles in the general framework. The delegated act expected in late 2027 will set the exact DPP data fields for the sector, including specific supply chain transparency requirements. This means you should not over-engineer your data collection for supply chain details that may change. However, you should ensure your data architecture is flexible enough to accommodate new fields. Do not hard-code assumptions about supply chain data structures. Build for modularity.

Identifiers and access tiers to design once, not twice

Two technical aspects of the DPP are already clear and should be designed now. First, data carriers must be ISO/IEC 15459 compliant unique identifiers. This standard ensures that your QR codes, RFID tags, or data matrices are interoperable and scannable across the EU. Second, the DPP will have access tiers. Some data will be public, while other data will be restricted to regulators and recyclers. Designing your access control and data segregation now prevents the need to rebuild your entire DPP infrastructure later. If you wait, you may find that your current system cannot support the required access tiers, forcing a costly migration.

How KadmilOS fits in

KadmilOS is designed to help fashion brands manage this transition. Our API allows you to start collecting and structuring your product data now. The POST /api/v1/dpp endpoint accepts structured product data and returns a DPP record along with a compliant data carrier URL. This means you can begin generating DPPs for your products today, using the current Art. 9-11 framework. As the delegated act is finalized, we will update our system to include the new textile-specific fields. Your data will already be in place, ready for the final compliance check. You do not need to wait for the law to be perfect to start building your data foundation. You need to start building it now.

Ready to start collecting your DPP data? See KadmilOS pricing or Check ESPR scope.