Regulation Didn't Create Your Data Problem. It Just Made It Visible
There is a particular kind of organisational conversation happening right now in boardrooms and leadership teams across the fashion and textiles industry. It tends to go something like this: we need to get ready for the DPP. What do we need to do, and by when?
It is a reasonable question. It is also, in a subtle but important way, the wrong one.
The Digital Product Passport does not create a new requirement for product data. It reveals whether an existing requirement — to know what your products are made of, where they came from, and what happened to them — has ever been taken seriously. The organisations discovering that they are unprepared for the DPP are not discovering a new problem. They are discovering, often for the first time at leadership level, a structural weakness that has been present and accumulating for years.
That distinction matters. Because the organisations that respond to the DPP as a compliance project — building what is needed to satisfy the regulation and stopping there — will find themselves in the same conversation again when the next requirement arrives. And it will arrive.
The regulatory timeline for fashion and textiles is not a single deadline. It is a sequence. The Delegated Act setting the specific data requirements for textiles is expected by the end of 2026 or early 2027, with an enforcement window of approximately 18 months following. But that is the beginning of a trajectory that runs through 2030 and toward a fuller circular economy framework by 2033. Each phase deepens the requirements — more data, more verification, more supply chain depth, more lifecycle coverage.
Alongside it, the Corporate Sustainability Reporting Directive is already in effect for large companies, demanding evidence-based disclosure across value chains. Extended Producer Responsibility is placing end-of-life accountability on producers that most have never had to operationalise. The Green Claims Directive is targeting the gap between what brands say about their products' sustainability and what they can demonstrate. These are not independent regulatory events. They are different expressions of the same underlying demand: show your workings.
An organisation that treats each of these as a separate compliance project will spend the next decade assembling and reassembling the same underlying data, at significant cost, with diminishing tolerance from the regulators and investors watching the process.
What makes the DPP particularly clarifying — and this is where the mirror metaphor is useful — is that it does not allow ambiguity about what is required. A product either has a verifiable, accessible digital record or it does not. The data is either there or it is not. The supply chain is either mapped to the depth needed or it is not.
That clarity is uncomfortable for organisations accustomed to sustainability reporting that allowed a degree of estimation, aggregation, and narrative alongside the numbers. The DPP does not accommodate narrative. It requires data — structured, linked to a specific product, retrievable on demand. And the data it requires does not spring into existence at the point of compliance. It has to be built, over time, through decisions made earlier in the product lifecycle: in design, in sourcing, in supplier engagement, in operations.
This is why the organisations furthest ahead are not the ones that started earliest on DPP implementation. They are the ones that started earliest on data capability — building the foundations that make DPP implementation a matter of configuration rather than construction.
There is a version of the compliance response that is worth examining, because it is the one most organisations will be tempted by. It involves identifying the minimum data set required for the 2027 requirement, finding a way to assemble it, and declaring readiness. It is efficient. It is focused. And it is likely to produce an organisation that is compliant on paper but has not actually closed the gap the regulation was designed to address.
The regulation exists because the fashion and textiles industry has an environmental and social transparency problem that voluntary action has not resolved. The DPP is a mechanism for making that transparency non-negotiable. An organisation that responds to that mechanism by doing the minimum necessary to satisfy it has understood the letter but not the substance.
More practically, the minimum viable approach tends to be the most expensive over time. Data assembled specifically to meet a requirement, in a format designed for that requirement, connected to systems built for that purpose, will need to be rebuilt — partially or wholly — when the requirement changes. The investment does not compound. It depreciates.
The more durable response begins with a different question. Not: what do we need to comply with the DPP? But: what would it mean to actually know our products — their composition, their provenance, their environmental footprint, their end-of-life potential — well enough that answering a regulatory question is the easy part?
That question reframes the DPP from a deadline to a diagnostic. It asks the organisation to look at its data capability not through the lens of what the regulator requires, but through the lens of what genuine knowledge of its own products would enable.
The regulation didn't create this challenge. It made it impossible to defer.
Michael Shea is a digital excellence advisor, non-executive director, and leadership coach working with organisations navigating the human and technical dimensions of digital transformation. He hosts The Aeolian Discourse and writes at The Aeolian.
Photo by Hans Eiskonen on Unsplash