Digital Product Passports: the golden threadthrough textile recycling?
13 January 2026 ● 15:00-17:00 CET ● Centre for European Policy Studies, Place du Congrès 1, 1000 Brussels
Data, interoperability, and supply chain challenges for textile DPPs: Key points from the panel discussion
DPPs as a foundation for textile recycling and circularity
Digital Product Passports (DPPs) are widely viewed as a cornerstone for enabling textile-to-textile recycling and scaling the circular economy. They can be important drivers for recycling by making downstream-relevant information - such as fibre composition, blends, dyes, and contaminants - consistently available to sorters and recyclers. When this information is mandatory, harmonised, and verified, it improves feedstock visibility, sorting efficiency, and planning reliability, reducing market uncertainty and supporting investment in recycling capacity.
DPPs should complement existing chain-of-custody and traceability systems rather than duplicate them, and ideally serve multiple policy and market needs, including Extended Producer Responsibility (EPR), eco-modulation, certification, and compliance.
Persistent data gaps at macro and micro levels
Significant data gaps undermine circularity across the post-consumer textile value chain. At the macro level, there is still no reliable, EU-wide picture of post-consumer textile volumes, locations, holders, and destinations. National statistics are fragmented, trade data lacks fibre-level granularity, and no shared mechanism exists to aggregate quantities, composition, and geography into a single dataset that maps resources and flows.
At the micro level, operational data within collection, sorting, preprocessing, and recycling facilities is captured inconsistently and in non-comparable formats. There is no uniform requirement to record auditable, batch-level information or to make it available downstream. These micro-level weaknesses directly prevent the creation of reliable macro-level datasets and hamper the evidential implementation of the EU-DPP.
Interoperability and standardisation as a prerequisite
Interoperability is essential but insufficient on its own. Today’s landscape is characterised by fragmented, proprietary traceability systems that are incompatible and require companies to report data repeatedly and in different formats. While regulation can define what information must appear in a DPP, it does not automatically define how data should be collected, structured, exchanged, and verified across heterogeneous systems.
Open, protocol-based interoperability approaches (like the United Nations Transparency Protocol, UNTP) are seen as critical to enable end-to-end data flows from production through collection, sorting, and recycling, while allowing data to remain decentralised and under the control of its owner. Interoperable traceability turns DPP fields into scalable, auditable evidence for circularity and EPR, and reduces administrative burdens, particularly for smaller actors.
Standards are required on two complementary fronts. First, data system standards must define identifiers, data carriers, data models, exchange protocols, and shared vocabularies to ensure information can move seamlessly and be understood across systems. Second, content standards must define what sustainability claims mean and how they are measured, including durability, repairability, and recyclability. Claims such as “recyclable” should only be used where realistic processing routes and capacity exist, supported by harmonised criteria and test methods.
Verifiability, greenwashing risks, and limits of current standards
Preventing greenwashing requires that DPP information be verifiable and linked to defined standards and indicators. In practice, verification is challenging. Existing schemes differ in methodologies, indicators, and assurance levels, ranging from self-declarations to third-party audits. This makes claims difficult to compare and assess across schemes. While technical interoperability can enable data exchange, semantic alignment - harmonised definitions, metrics, and indicators—is also crucial. Mutual recognition between standards schemes could reduce duplication and cost, but such mechanisms are not yet established.
Incentives and capacity-building are key for operational data reporting
High-quality DPP data ultimately depends on consistent, facility-specific, batch-level operational data generated at every step of the post-consumer value chain. Each actor must record what arrives, how it is processed, and what moves on in a way that is auditable and understandable downstream.
However, many facilities lack both the incentives and the capacity to professionalise data capture. Without clear incentives, data collection remains inconsistent and cannot credibly support recycled-content claims, certification, or regulatory reporting. Incentivising operators to perform proper data collection and reporting - e.g. by linking due diligence, auditability, and accurate reporting to compliance checks and financial levers - can unlock multiple benefits: the same data that improves business operations can also serve compliance, audits, and market transparency.
Unequal distribution of costs and risks across the value chain
The actors facing the greatest challenges in implementing DPP requirements are those with the lowest margins and highest operational and capital costs, particularly in the post-consumer segment (waste handlers, collectors, sorters, pre-processors, recyclers). These actors often lack mature digital systems and must commit working capital to acquire waste before knowing whether it will meet recycler specifications or future eco-design requirements.
If DPP-related costs and risks are pushed disproportionately onto these actors, the DPP risks becoming a formal data-declaration exercise rather than an instrument that enables textile-to-textile recycling at scale. Mandatory, harmonised requirements, interoperable “collect once, use many times” data exchange, and financial or regulatory support are seen as necessary to rebalance risk.
Data carriers and fit-for-purpose implementation
The choice of data carrier directly affects accessibility, speed, and depth of DPP data. QR codes are well suited to consumer-facing use cases, enabling access to care, repair, reuse, and disposal information via smartphones, but are inefficient in high-volume sorting environments. RFID enables rapid, bulk scanning and supports large-scale reuse and recycling operations, but requires dedicated infrastructure and is currently not consumer accessible.
A hybrid approach is broadly supported, combining multiple data carriers for different use cases. Policy should remain technology-neutral while defining minimum interoperability and data-structure requirements, allowing companies to choose solutions aligned with their processes and investment capacity.
Panellists’ policy recommendations
Make DPPs evidence-based and interoperable: Ensure that DPPs are supported by a verifiable, secure digital ecosystem that links reliable evidence to ecodesign/ESPR claims. Prioritise interoperability so data can flow across systems and be reused.
Harmonise data requirements and methodologies: Define EU-level minimum data quality rules, mandatory data fields, calculation methods, and verification requirements. Ensure consistent application across ESPR, DPPs, and EPR schemes to avoid fragmentation and comparability issues between Member States.
Adopt a “collect once, use many times” approach: Design DPP data models so the same datasets can serve multiple policy needs (EPR, eco-modulation, public procurement, compliance, and audits), reducing duplication and administrative burden.
Support weakest actors and ensure fair competition: Balance regulatory ambition with competitiveness by avoiding disproportionate cost and risk for post-consumer actors. Strengthen enforcement and customs controls so non-EU products comply with the same rules.
Embed verification and anti-greenwashing safeguards: Require verification of recycled content and recyclability claims against defined standards and indicators, with clear assurance levels. Avoid reliance on self-declarations.
Ensure predictable timelines and regulatory coherence: Keep regulatory timelines clear and stable to enable investment and business model transitions. Align and harmonise overlapping regulations to prevent contradictory or duplicative reporting obligations.
Use demand-side levers to improve data quality: Create demand for high-quality data by embedding requirements in public procurement, compliance checks, eco-modulation, and financial incentives.
Align EU frameworks with global standards: Ensure that EU data models, vocabularies, and protocols are interoperable with international standards to support global supply chains and avoid duplicative systems.
