Digital Product Passport Guide: Turn Compliance Into an Edge
A practical guide for fashion brands navigating sustainability claims in the EU
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Estimated reading time: 10 minut
The fine that changed everything
Armani was fined €3.5 million. Shein, €1 million. H&M and Decathlon had to drop their “eco-friendly” labels entirely.
These are some of the biggest names in fashion. What sank them wasn’t bad products. It was a claim they couldn’t prove.
“Sustainable.” “Responsible.” “Eco-conscious.” These words are used to build brand equity. Now they build legal risk. Regulators don’t read labels anymore — they ask for the data behind them. Most brands don’t have it.
DPP exists because of ESPR, the EU law behind it. But brands that treat it as just a checkbox are missing the more useful part — and that part has nothing to do with regulators.
Why did “eco” stop being enough?
In 2024, the EU’s Green Claims Directive changed the rules. An environmental claim without proof now counts as misleading. “Made sustainably” isn’t a tagline anymore. It’s a liability.
Regulators want specifics: what it’s made of, where it came from, how it was made, and what happens to it after. Not a brand story. Data tied to a single product that is ready on demand.
The brands that got fined weren’t lying. They talked the way fashion always has — broad claims, good intentions. That doesn’t work in the EU anymore, and it’s getting harder everywhere else, too.
The question used to be: how do we talk about sustainability? Now it’s: can we prove it, for this product, right now? That’s a much higher bar. Here’s exactly what it takes to clear it.
What a DPP actually contains
A Digital Product Passport isn’t a certificate or a score. It’s a data record associated with a single product. Anyone can scan it — a customer, a retailer, a regulator.
A DPP holds:
- Material composition — down to the fiber
- Origin — where the materials came from, where it was made
- Production process — how, and by whom
- Care and repair information
- End-of-life guidance — how to recycle or return it
Your marketing team already talks about all of this. DPP just makes it provable.
A retailer wants proof during a tender. A journalist asks what “recycled” means for one jacket. A regulator investigates your “eco” label. Same answer every time: the data record.
The story you’d normally tell becomes evidence instead. That’s the theory. Here’s what it looks like when two brands actually try it.
Three brands using DPP as a marketing tool, not just a legal requirement
INTU Circularity x Answear — upcycling that can prove itself
INTU builds collections from defective garments, pieces that would otherwise become waste. Every item in their Renewed collection is one of a kind — different scrap, different origin, different story.
That’s exactly what makes upcycled products hard to verify. A generic sustainability label means nothing when no two pieces share a history.
With Caruma and GS1 Polska, INTU added a GTIN code to a digital product card for every piece. Now, a customer in any of Answear’s twelve markets can scan a QR code and see where the denim came from, what it used to be, and how it changed.
Upcycling stopped being a story. It became something you can check.
Kopyto — DPP as a live conversation
Kopyto, a Polish fashion brand, rolled out a digital product card before any deadline forced them to. At Responsible Fashion Business in Gdańsk, June 2026, they showed it live on stage: a real scan, what customers see, what it signals to a retail partner.
The room’s questions changed fast — from the regulation to how to get the same thing themselves.
That’s the difference between a checkbox and a brand asset.
Two different brands, two different reasons for starting — and the same result. Proof beat promise both times. Here’s what that means for your next campaign.
What marketing actually gains from DPP
Right now, most sustainability claims sound the same across the industry. Every brand says “responsible.” Every brand says “conscious.” None of it stands out, because none of it can be checked.
A DPP breaks that pattern. It gives marketing something almost no competitor has yet: a data-backed claim anyone can verify on the spot. Not a slogan — a scan.
That changes what a campaign can say. Instead of “made responsibly,” a brand can say “scan this and see exactly where it came from.” Instead of a general promise, a retailer gets proof for a specific product during a tender. Instead of “trust us,” marketing gets to say “here’s the data.”
Brands with this in place get picked first — by retailers running tenders, by customers comparing two similar products, by journalists looking for a brand that can actually answer a question rather than dodge it.
That’s the advantage: not avoiding a problem, but having something to say that competitors still can’t. Somewhere, a brand in your category is already selling on proof while the rest of the market is still selling on promises. Here’s how to make sure it’s you.
Where to start
- Audit what you already have. Material composition, supplier origin, certifications — most brands have more than they think, buried in spreadsheets and old emails.
- Pick one product or collection. You don’t need a full catalog on day one. Five products will teach you more than a year of planning.
- Talk to a partner who’s actually done this — not a consultancy with a framework, but a team that’s shipped DPP for a real brand.
Brands that start now won’t be scrambling in 2027. They’ll be the ones retailers call first.
Frequently Asked Questions
What is a Digital Product Passport (DPP)? A Digital Product Passport is a data record attached to one specific product, covering material composition, origin, production process, care instructions, and end-of-life guidance. Customers, retailers, and regulators can all scan it and verify the claims directly.
Why did environmental claims become risky for fashion brands? The EU’s Empowering Consumers for the Green Transition Directive (2024/825) treats unproven sustainability claims as misleading commercial practice. Armani, Shein, H&M, and Decathlon were fined or forced to remove eco-labelling after regulators found claims they couldn’t back up at the product level.
How does a DPP help marketing, not just compliance? A DPP lets marketing replace vague claims like “made responsibly” with proof a customer can scan on the spot. That gives a brand an edge with retailers during tenders, with journalists asking specific questions, and with shoppers comparing similar products.
Is a DPP the same as a sustainability certificate? No. A DPP isn’t a rating or certification — it’s a structured, product-specific data record, verifiable independently of any brand’s own marketing claims.
When do EU Digital Product Passport rules for textiles take effect? Under the European Commission’s ESPR Working Plan 2025–2030, the textile-specific delegated act is expected around 2027, with mandatory compliance realistically arriving from 2028 onward.
Key Takeaways
- Fashion brands like Armani and H&M have been fined for failing to substantiate their environmental claims.
- The 2024 EU Green Claims Directive mandated proof for sustainability declarations, completely changing the game for the fashion industry.
- The Digital Product Passport (DPP) is a data record assigned to a specific product, enabling the verification of its components, origin, and manufacturing process.
- Brands leveraging the DPP can stand out in the market by offering real-time data instead of generic marketing claims.
- To implement a DPP, you need to audit existing data, select a single pilot product, and collaborate with an experienced partner in this field.
Sources
- Directive (EU) 2024/825 of the European Parliament and of the Council — EUR-Lex: https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng
- European Commission — Green Claims policy overview: https://environment.ec.europa.eu/topics/circular-economy-topics/green-claims_en
- European Commission — Implementing the Ecodesign for Sustainable Products Regulation (ESPR/DPP timeline): https://green-forum.ec.europa.eu/implementing-ecodesign-sustainable-products-regulation_en
- The Fashion Law — Italy fines Armani and Shein in fashion industry ESG crackdown: https://www.thefashionlaw.com/tl-dr-italy-fines-armani-shein-in-fashion-industry-esg-crackdown/
- ESG Today — H&M and Decathlon to remove sustainability labels following ACM investigation: https://www.esgtoday.com/hm-to-remove-sustainability-labels-from-products-following-investigation-by-regulator/
Caruma implements Digital Product Passports for fashion, furniture, and electronics brands across the EU. If you want to see what a live implementation looks like for your product category, reach out:
📩 office@caruma.io
This article was created in collaboration with the marketing agency BoostNow.pl — SEO, GEO, and content for brands operating in the EU market.