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Add Texture to GoogleAn Excel file, an email exchange, information stored in a document repository that other departments don’t consult: in the fashion industry, transparency begins behind these unspectacular scenes. The digital product passport forces us to examine what truly connects a fashion house to its suppliers. Before delving deeper into the product, we must first know where the data describing it is located, who is responsible for it, and how much trust we can place in it. For the luxury sector, this issue deserves more than a purely technical approach: it requires the ability to align the narrative about the product with a documented understanding of its manufacturing process.
The first challenge lies in the files
The Italian brands surveyed by Osapiens generally haven’t yet reached the stage of ordering their digital passports. They are first seeking to understand what will be required of them, by when, and based on what information. This observation comes from a compliance solutions provider—and thus a commercial player in the field—but it sheds light on the disconnect between the visibility of the issue and its operational progress. According to the company, while experiments are on the rise, they remain few in number.
Nevertheless, a growing number of the companies surveyed are beginning to assess their resources. The most structured groups, particularly in the luxury sector, are mapping their supply chain data and evaluating their level of readiness. This preliminary work has little to do with the final presentation of a passport. It consists of conducting a critical inventory: Does the information already exist? Is it accessible? Is its owner clearly identified? And above all, is it reliable enough to serve as the basis for a regulatory requirement?
Giuseppe Dimaria, Osapiens’ Regional Director for Southern Europe, points to two very concrete challenges: a fragmented supply chain and data scattered across tools that do not communicate with one another. The problem, therefore, is not merely obtaining new information. We must also make the data that’s already in circulation usable. Adding a new tool without addressing this fragmentation would risk shifting the problem rather than solving it.
Who should be in charge?
This question about data management quickly leads to a question of power within the company. Who should be entrusted with the Digital Product Passport, or DPP? Placing it within the scope of sustainability seems logical, but does not guarantee access to procurement data. Entrusting it solely to the supply chain teams overlooks some compliance requirements. As for an IT-only department, it risks prioritizing the technical solution at the expense of the business units’ expected use cases.
The organizational structure recommended by Dimaria relies on support at the highest level and a cross-functional team. Supply chain and sustainability would lead the initiative, with close involvement from product marketing. This division of responsibilities speaks to the nature of the project: the passport must be developed in collaboration with those who collect the information, those who assess its regulatory implications, and those who will use it to communicate about the product.
Data governance here is not merely a trendy consulting buzzword. It refers to an agreement to be established among departments regarding the information selected and how it is managed. An available file does not, on its own, constitute a common foundation. For multiple departments to be able to work from the same data, they must share a common framework, rather than each maintaining its own interpretation of the product.
A Timeline to Be Taken in Stride
However, it is important to distinguish this organizational effort from the obligations that have actually been established. The digital product passport was introduced by the European ESPR regulation, which focuses on the eco-design of sustainable products. For the textile industry, the binding requirements will depend on a specific delegated act from the European Commission. The framework exists; sector-specific requirements have yet to be defined.
According to information available to Osapiens, as reported by Giuseppe Dimaria, this act could be adopted toward the end of 2027, with mandatory implementation beginning in 2028. These dates are subject to change. They should therefore be understood as a preliminary timeline provided by the company, rather than a definitive schedule. This distinction is important for brands seeking to plan their investments.
There is, however, a firm deadline for batteries. Starting February 18, 2027, the passport will be mandatory for batteries in electric vehicles and light-duty vehicles, as well as for industrial batteries exceeding 2 kWh placed on the European Union market. This milestone does not apply to the fashion industry. It does, however, show that, despite sharing the same concept of a “passport,” different sectors are following distinct regulatory paths.
Wait for the final text, or lay the groundwork?
Legal uncertainty does not necessarily justify inaction. Collecting data from suppliers can take several months, sometimes years, Dimaria points out. Added to this timeframe is the time needed to build a shared model across the company’s various departments. An implementation date that is still up in the air does not eliminate this preparation time; it simply makes it more challenging to decide when to begin the work.
A useful distinction lies between anticipating unknown requirements and reviewing what one already has. Osapiens advocates the latter approach: identifying available information, its location, and its reliability, then aligning it with current obligations. The DPP is, in fact, part of a broader regulatory framework. Certain data can be used to meet multiple requirements, which makes it important to avoid a standalone project designed for a single purpose.
This approach aligns with the service provider’s positioning. With its roots in regulatory compliance, Osapiens has gradually expanded its offerings to include the digital passport. The company reports having 100 clients in Italy and more than 2,500 worldwide, across industries ranging from automotive to food, as well as fashion and retail. These figures reflect its commercial footprint, not the number of digital passports already deployed in the textile industry.
Value cannot be dictated by software
For fashion houses, the challenge is also to ensure that the DPP does not remain a burdensome expense, managed in isolation from the company’s overall strategy. Dimaria sees it as a potential economic lever, provided it is integrated into the company’s strategic decisions. This promise should remain conditional: having better-organized data does not automatically yield a competitive advantage. It is still necessary to determine how the data will be utilized and what insights it will provide.
According to him, initial studies have revealed the limitations of an approach based solely on digitization. Marketing and promotion must also be addressed. For the luxury sector, this is a sensitive issue: product documentation and storytelling are not the same thing, but they cannot be considered separately. Involving product marketing from the planning stage onward prevents the marketing team from receiving, at the end of the process, a strategy that is already set in stone.
These trade-offs will be on the agenda of the DPP Revolution webinar, scheduled in Italian for October 21, from 11:30 a.m. to 1:00 p.m. Attorney Olivia Bosaz, of Studio Legale Bosaz, will speak on the legal framework and data governance; Capgemini will address business transformation, while Osapiens will discuss the connection to product compliance. Aimed at the various departments involved, the event promises practical examples and operational guidance. This will bring the discussion down to its most practical level: a supplier to contact, data to verify, or a responsibility to assign.