By Megan Brewster
A new era in sustainability compliance is officially upon us. Since coming into force in July 2024, the European Commission’s Ecodesign for Sustainable Products Regulations (ESPR) has set out a legal framework for establishing ecodesign requirements to reduce the environmental, energy, and climate impacts of manufacturing and consumption.
Implemented as a crucial measure under the ESPR, the Digital Product Passport (DPP) is a digital record or virtual label that will be required to be attached to products providing information pertaining to their composition, origin, recyclability, and lifecycle. Rollout is already underway for certain product categories, with more categories planned into 2030, and eventually expanding to all products sold in the EU (including imports) as clarified in the recently published Single Market Strategy. Under DPP measures, any company that sells products in the EU — including U.S. companies — will be required to comply.
So, why should this matter to companies now? In April 2025, the European Commission released the ESPR Working Plan, laying out the official implementation timeline for DPP product categories over the next five years. Among the first product categories outlined in the plan that will require DPPs are textiles and apparel. With a 2027 timeline for adoption, brands manufacturing and selling textile items in the European market must ready themselves for the upcoming deadline. So, how should companies respond to ensure they meet DPP compliance requirements under the ESPR in time?
Pathways To DPP Compliance
According to a recent survey by Impinj of supply chain professionals, nearly half (49%) of respondents cited concerns about their organization’s ability to meet requirements under DPP, and more than one-third (37 percent) anticipate not being able to meet the DPP compliance deadline. However, the pressure is on to act quickly to pave a smooth pathway to regulatory compliance, particularly for companies within the textiles and apparel space who will be among the first industries required to be DPP compliant.
As such, there are key steps textile and apparel companies can take to ensure their organizations can meet critical requirements under the mandate:
- Identify an internal expert or trusted consultant to act as a DPP champion: Critical to ensuring companies can keep up with the requirements of the new EU legislation, identify a subject matter expert on all things DPP. This will enable your organization to stay ahead of any updates and that the latest thinking is reflected in their DPP planning and strategies.
- Collaborate with suppliers to outline your DPP strategy: Collaborating with suppliers and partners to outline your DPP strategy will enable accurate evaluation of DPP data collection requirements and the technologies that must be adopted to comply with regulatory requirements.
- Evaluate the systems and technologies required: To provide detailed information on products’ composition, origin, and lifecycle, a digital record or “digital twin” will be required.
This information must be consumer-accessible through at least one identifier – including a
QR code, barcode, NFC tag, or a battery-free wireless RAIN radio frequency identification
(RFID) tag. Each of these technologies takes a different approach and offers different
benefits. Organizations must ensure that they adopt the solution that best ensures
compliance while also improving their day-to-day operations.
How RAIN RFIDs Can Enable DPPs
RAIN RFID is a battery-free wireless technology that enables the seamless identification and authentication of products. RAIN RFID will enable manufacturers and retailers to provide the critical product information required under DPP. At the same time, RAIN RFID provides additional insights into overall inventory management, ensuring companies can both comply with DPP regulations and reap benefits beyond the mandate. RAIN RFID provides real-time visibility into inventory levels, enabling retailers and manufacturers to quickly and accurately locate, identify, and engage with their products.
Beyond DPP compliance, RAIN RFID offers a variety of other extended benefits, such as revolutionizing loss prevention efforts, ensuring authenticity, and bolstering sustainability efforts.
The establishment of both the broader ESPR and the Digital Product Passport initiative by the EU sets out to create much-needed product transparency and traceability in a larger push towards a global circular economy. With the next critical milestone in DPP legislation set to take effect in 2027 — when DPPs for textile and apparel products will enter force —retailers and manufacturers now have a critical opportunity to evaluate and take action to ensure they are staying ahead of these global regulatory changes.
Editor’s Note: Megan Brewster is the vice president of advanced technology at Seattle-based Impinj, a provider of RAIN radio frequency identification technologies. Prior to joining Impinj, Brewster served as fellow and senior policy advisor for advanced manufacturing for the White House Office of Science and Technology Policy, where she supported the stand-up of the administration’s signature advanced manufacturing initiative.
June 24, 2025
