Why Middle Eastern Fashion Brands Can’t Afford to Ignore the EU’s Digital Product Passport (DPP) PART 1
Disclaimer: This article is intended for informational and educational purposes only and does not constitute legal advice. While efforts have been made to ensure the accuracy of the information presented, FashionTech Middle East makes no guarantees regarding its completeness or applicability. Readers are encouraged to consult legal or regulatory professionals for advice specific to their business circumstances and jurisdiction.
Welcome to Part 1 of our series of posts about Digital Product Passport (DPP) regulation, where we will unpack what they mean and how fashion businesses can prepare to ensure compliance.
Europe’s push for sustainability means businesses exporting into the EU will be required to comply with the Digital Product Passport (DPP) requirements. The fashion industry will be one of the first to be impacted, and businesses should start putting wheels in motion to prepare for this major upcoming compliance change. DPP is the sweeping new regulation that is set to reshape the way garments are designed, documented, and distributed. While it may seem like a change that will affect mostly European businesses, the reality is that any brand exporting into the EU will need to comply. That includes fashion businesses across the Middle East whose products land on European shelves, marketplaces, or runways.
DPP isn’t just another label or marketing certification. It’s a data-rich, technology-enabled passport for every product, revealing its origins, composition, sustainability footprint, and lifecycle. And it will soon be a legal requirement for accessing the EU market. But lots is still unknown.
The question isn’t if your brand needs to prepare, but how soon.
What Is the Digital Product Passport (DPP)?
The Digital Product Passport is part of the EU’s broader sustainability push under the Ecodesign for Sustainable Products Regulation (ESPR), a legislative framework introduced as part of the European Green Deal. The goal is to make products more durable, recyclable, and transparent. For fashion and textiles, that means embedding information into every garment that allows regulators, retailers, and consumers to trace its environmental and social impact.
Each DPP will be digitally accessible, often through a QR code, NFC tag, or other scannable method, and contain structured, standardised information about the item. This includes details about its material content, manufacturing process, carbon footprint, origin, and recyclability.
The passport will travel with the product, from production to point of sale, and even into resale or recycling, ensuring a consistent, traceable story of its life cycle. Our general understanding is that at this point, DPP is aimed at tracking the finished product (when it hits the market), and hence, data around production traceability is not fully mandatory for inclusion in the DPP.
Importantly, while detailed production traceability may not be fully mandatory in the initial phase, some aspects of production (e.g., key manufacturing processes) are required from the start, with comprehensive traceability expected in later phases (2030 and 2033).
It is also worth noting that, though not always "mandatory", traceability (materials, processes, and origin) is strongly encouraged and likely to become a key expectation, also in textiles.
Why It Matters for Middle Eastern Fashion Brands
Middle Eastern fashion brands often operate as exporters, with strong demand from European consumers for everything from modest luxury to contemporary streetwear. But without alignment to European regulation, these cross-border transactions may soon face serious friction.
Even if you’re not headquartered in the EU, your European buyers will be subject to these rules, and they’ll expect their suppliers to keep up. Non-compliance could result in hefty fines up to €20 million or 4% of global annual turnover, whichever is greater. It can also trigger temporary or permanent bans on sales or imports, and hence lead to brand damage and loss of consumer trust.
Beyond market access, DPP is also about staying relevant. Sustainability is no longer a trend, it’s fast becoming a baseline expectation. European consumers want to know what’s in their clothes, who made them, and how. Brands that can’t answer those questions, or worse, won’t, risk becoming obsolete in an increasingly values-driven market.
This is especially urgent for Middle Eastern labels that rely on white-label manufacturing or fragmented supply chains. Now is the time to get visibility, before it’s legally mandated.
What Will DPP Require From You?
To comply with the Digital Product Passport, brands will need to capture and disclose structured information about each product. This isn’t just marketing fluff, it’s traceable, verifiable data that may need to be updated over time. Here’s a non-exhaustive list of technical requirements:
Gathering and verifying this information will require collaboration across your supply chain, from raw materials to final assembly, and the adoption of digital tools to manage and share it.
When Is This Happening?
While the ESPR was adopted in June 2024, specific requirements for textiles are expected to be detailed in delegated acts by 2026, with full implementation targeted for 2030. However, some requirements, such as initial reporting obligations, may start as early as 2027 for textiles. But don’t let that timeline lull you into complacency. European brands are already piloting DPP systems, and importers are beginning to ask questions.
Implementing the right systems, training your team, and aligning your suppliers won’t happen overnight. A two-year runway is tight, especially for smaller brands with complex manufacturing setups.
Expected phased implementation:
Phase 1 (2027): Minimal and simplified DPP, focusing on mandatory information such as recycled material, dangerous substances, supply chain processes (e.g., confection, weaving, knitting, dyeing, printing), and packaging recyclability, plus additional lifecycle analysis data like weight, quantity, and transport means/distance.
Phase 2 (2030): Advanced DPP, extending to more stakeholders, with detailed supply chain evaluations, finished product assessments, and aftersales/second-hand tracking.
Phase 3 (2033): Full circular DPP, fully integrated supply chain, automated impact calculation, tracked distribution/usage/aftersales, enhanced sorting/recycling, and higher closed-loop recycling.
What Middle Eastern Brands Should Do Now
Start by mapping your supply chain. Know who makes what, where, and with which materials. Conduct an internal audit of data availability: do you know the carbon footprint of your garments? Can you verify where your zippers or dyes come from?
Next, explore partnerships with traceability tech providers or fashion sustainability platforms that can help structure this information in line with EU requirements. If you’re working with European distributors, start conversations about their expectations and timelines (we will explore some tech providers in Part 3 of this series).
Internally, DPP isn’t just the sustainability team’s responsibility. Design, product development, logistics, and marketing will all play a role in shaping the data narrative. Equip your team with the tools and training they need to meet the challenge.
Finally, track regulatory updates and industry best practices. This space is evolving quickly, and those who stay informed will be better positioned to adapt.
Action Points for Fashion Businesses
Start Data Collection Now: Begin mapping your supply chain to gather data on materials, production, and logistics. Focus on traceability, recycled content, and environmental metrics like carbon footprint to prepare for DPP requirements. Partner with suppliers to ensure data accuracy.
Choose the right path for your brand: If you're an emerging or mid-sized label, integrate with a trusted third-party provider. If you're digitally advanced with strong in-house tech capabilities, consider building your own DPP platform for full control.
Monitor Regulatory Updates: Regularly check EU Commission updates and delegated acts expected in 2026 for textile-specific DPP requirements.
Educate Your Team and Suppliers: Train internal teams and Middle East-based suppliers on DPP requirements and the importance of transparency. Build relationships across the supply chain to streamline data sharing and compliance efforts.
The Future of Fashion Is Transparent
The Digital Product Passport isn’t a compliance burden, it’s a window into the future of global fashion trade. Brands that embrace it early will build deeper trust with customers, improve operational resilience, and gain a competitive edge in one of the world’s most demanding markets.
Middle Eastern fashion has the creativity, craftsmanship, and cultural relevance to thrive on the international stage. But in the age of digital traceability, style alone is not enough. Transparency is the new luxury, and DPP is your ticket in.
If you would like to learn more about DPP and its implications, please feel free to reach out to us.
In Part 2, we will explore the current uncertainties relating to DPP rules and how brands can future-proof to adapt to evolving requirements.
