How can DPPs support OECD due diligence in global fashion supply chains?

The digital product passport (DPP) serves as a structured digital record under the Ecodesign for Sustainable Products Regulation (ESPR). These passports do not replace due diligence but rather act as "structured containers" for the necessary data to support it. This is what Catherine Lomonaco, founder of GoTrace, highlighted at a webinar on 10th February.

The side session of the OECD Forum on Due Diligence in the Garment and Footwear Sector highlighted a pivotal shift in the textile and garment industry from self-declared claims to verifiable data. Lomonaco emphasised the necessity of moving beyond surface-level assertions, stating, "Due diligence is not about claims, but about evidence, traceable information and continuous risk management."

The necessity of open facility data

For that information to be meaningful and accessible, it needs to be open. Nathalie Grillon, CEO of Open Supply Hub, addressed the systemic fragmentation currently hindering supply chain transparency. She identified that siloed, closed data creates a reporting burden for suppliers and leads to inconsistent records for brands. Grillon proposed a movement towards open data, where production sites are assigned a unique, neutral identifier (OSID) to ensure interoperability across different systems. She noted that "facility identification can and should be open and free and accessible to everyone," highlighting that treating this data as public infrastructure is the only way to scale the DPP ecosystem effectively.

By adopting an open data model, the industry can reduce costs for Small and Medium Enterprises (SMEs) and foster a meritocratic system where performance, rather than connections, dictates market access. Grillon illustrated this through a collaboration with the World Wildlife Fund, where layering facility data over water risk maps enabled brands to co-invest in conservation efforts. She concluded that "due diligence and digital product passports... will only work if we treat facility data as public infrastructure, not private assets," urging the industry to move away from viewing supplier locations as private competitive advantages.

Shifting the traceability paradigm

Another issue is tracing back from product after it is made rather than starting right from the fibre before the finished garment. Rhys Davis, COO of Aware, challenged this traditional "backward-looking" approach to traceability, where brands attempt to reconstruct a product's history from the finished garment. He argued that this method is inherently unreliable and often leads to unintentional greenwashing because brands lose visibility after the first two tiers. Instead, Davis advocated for "tracing forward" from the source — starting at the cotton farm or the plastic recycling facility. He asserted that "if the producer information is wrong or missing, the DPP is no longer credible and frankly does not matter."

Aware’s solution involves a digital “ledger” where data is added in real-time as the fibre moves through the supply chain. This physical-to-digital link ensures that the impact measurements, such as carbon emissions or water usage, are captured at the point of production rather than estimated later. Davis highlighted that this approach empowers producers by giving them "verifiable proof of what they are claiming," shifting the burden of readiness from the brands to the suppliers. He maintained that for a DPP to be truly reliable, the data must be primary and originate from the actors physically handling the material.

Implementing product-level verification

Maciej Bulkowski, CEO of Caruma, focused on the practical implementation of DPPs at the collection level, specifically regarding upcycling and vegan alternatives. He introduced a framework of "Claim, Evidence, Link and Action," arguing that a DPP without a link to evidence is merely a marketing tool. Bulkowski demonstrated that by using blockchain for immutable event records while keeping sensitive commercial data off-chain, brands can build genuine trust with consumers. He warned that "traceability without verification is only storytelling, it is not due diligence," emphasizing the need for audit-ready documentation.

A standout case study presented by Buklowski was the "Material First" approach used with vegan leather. In this model, a DPP is assigned to the material source before the product is even created, allowing the final garment to "inherit" the material's verified history automatically. This ensures the evidence chain remains unbroken from the factory floor to the retail shelf. This method simplifies compliance for designers and ensures that circular economy initiatives are backed by high-quality data rather than vague promises, providing a clear roadmap for brands navigating new EU regulations.

Preparing for future regulatory standards

The concluding Q&A session addressed the practical anxieties of garment manufacturers and brands regarding the pending EU textile delegated acts. The panel advised that while exact data standards are still being finalised, organisations should begin by centralising "must-have" data such as product identifiers, material composition and facility locations. The speakers noted that wait-and-see tactics are no longer viable, and aligning with existing frameworks like the UN Transparency Protocol is a prudent interim step. Bulkowski noted that the industry is in a learning phase, stating, "We are learning how to use this information, how to build information in DPP."

Ultimately, the transition to DPPs represents a fundamental change in how the textile industry manages risk and communicates value. Whether through open facility mapping, fibre-level ledger systems or blockchain-backed product passports, the goal remains a "single source of truth" that survives the entire lifecycle of a garment. As the industry awaits the finalisation of the EU registry, the consensus among these experts is clear: the infrastructure for transparency must be collaborative, science-based, and, above all, rooted in verifiable evidence at every stage of production.