The EU’s Digital Product Passport (DPP) regime is focused on sustainability and supply chain transparency, but could also give fashion and luxury brands a powerful new source of product traceability data for authentication, enforcement and supply chain monitoring.
The DPP is relevant not only to EU-based businesses, but also to companies outside the EU that manufacture products for, or otherwise sell products into, the EU market. The UK government issued a consultation on digital product records policy in July 2026. Although textiles don’t appear in the government’s initial priority list, the UK is clearly keeping a close eye on developing EU policy.
What is the Digital Product Passport?
The DPP forms part of the EU's Ecodesign for Sustainable Products Regulation. Textiles and apparel have been identified as a priority product category and are expected to be among the first sectors subject to product-specific DPP requirements. While the detailed rules are still being developed, fashion businesses selling products into the EU should assume that products placed on the EU market will ultimately need to be accompanied by a DPP containing prescribed product information. Current indications are that legislation implementing the DPP requirements for textiles will be adopted in Q4 2027, with additional guidance, technical specifications and implementation measures to follow.
In simple terms, the DPP is intended to provide access to information about a product through a digital identifier, such as a QR code. Depending on the final requirements, this may include information relating to a product's composition, manufacture, durability, repairability and end-of-life treatment. The detailed framework governing how this information will be stored and accessed is still under development.
What could this mean for brand protection?
Luxury, fashion and consumer goods businesses have long explored digital authentication and traceability solutions. For example, LVMH, OTB, Prada Group and Cartier helped launch the AURA Blockchain Consortium, which uses blockchain technology to create secure digital records of a product's authenticity and provenance. The DPP therefore builds on a trend towards greater product traceability that is already familiar to many brands.
Although the DPP is not intended as an anti-counterfeiting measure, the requirement for a unique digital identifier linked to product-specific information could create additional opportunities for product authentication, supply chain oversight and brand protection. Consumers, retailers, customs authorities and enforcement teams may, depending on how the regime develops, be able to access information that assists in verifying a product's authenticity and tracing its journey through the supply chain.
Beyond counterfeit detection, fashion and luxury brands continue to face challenges relating to grey market activity, unauthorised diversion of stock and supply chain leakage, with products often ending up in markets or channels that were never intended by the brand owner. Greater product-level traceability could help brands understand where products originated, which entities handled them and how they reached the market, providing valuable information when investigating or enforcing contractual restrictions within distribution networks.
For brands that already operate authentication or traceability systems, the DPP may provide an opportunity to leverage and enhance existing infrastructure rather than develop entirely separate solutions. In turn, this could strengthen product authentication processes, improve oversight of distribution channels and support wider compliance, risk management and brand protection objectives.
Transparency vs confidentiality
However, the DPP regime's focus on transparency may create tensions for some brands. Information about suppliers, manufacturers and distribution channels is often closely guarded, particularly in the fashion and luxury sectors. Many businesses have invested significant time and resources in developing those networks and may be reluctant to increase visibility into how products are sourced and brought to market.
Many businesses will also be asking what DPP compliance might look like in practice, particularly in relation to the information that will need to be disclosed and who will be able to access it. As the regime develops, those questions are likely to be as important as the compliance requirements themselves.
The compliance burden should also not be underestimated. Many brands will need to implement new processes for gathering, validating and managing product data across extensive supplier and manufacturing networks.
Brands will therefore need to think carefully about how DPP requirements are implemented, balancing the benefits of greater transparency and traceability against the practical realities of compliance and the need to protect commercially sensitive information.
What should brands be doing now?
As mentioned above, the DPP regime remains under development and many of the detailed requirements have yet to be finalised. However, fashion and luxury businesses do not need to wait for the final rules before considering the potential implications.
Brands should take this opportunity to assess the traceability and product authentication measures they already have in place and consider whether those systems could support both future DPP compliance and wider brand protection objectives. This may involve reviewing how product information is collected and retained, whether products can be linked to unique identifiers and how information is shared across suppliers, distributors and retail partners.
Conclusion
The DPP is not intended to be an anti-counterfeiting tool, but the increased traceability it is designed to create could have significant brand protection benefits. While many aspects of the regime remain to be finalised, brands should be considering not only how they will comply with the new requirements, but also how DPP-related data and infrastructure could support wider authentication, enforcement and supply chain oversight objectives.
