The brands getting ahead of the EU Digital Product Passport mandate share three things in common: they started early, they treated it as a supply chain project rather than a compliance project, and they didn't wait for perfect data.
Starting earlier than required
Arket began collecting structured material data years before the mandate's first textile deadline — not because they had perfect systems, but because they recognised that data collection at scale takes time.
The lesson: every quarter you delay is another quarter of products shipped without the underlying data captured. Retroactive data collection is expensive. Prospective collection is cheap.
The supply chain project framing
Brands that frame DPP as a "compliance project" end up building a PDF export. Brands that frame it as a supply chain project end up with a structured data infrastructure they can actually use.
Patagonia's materials traceability work predates DPP requirements entirely. Their traceable down standard and textile certifications give them a data foundation that maps directly to DPP fields. The compliance cost, for them, is low — because the underlying data already exists.
The common gaps
In practice, the three most common gaps we see are:
Tier 2 supplier data. Brands know their cut-and-sew facilities. They often don't know which fabric mills supplied those facilities, or can't get structured data out of them quickly.
End-of-life guidance. The regulation requires specific, actionable disassembly and recyclability information. "Recycle where facilities exist" doesn't qualify.
Real-time accuracy. DPP data must stay current. A product published in January 2026 that still reflects 2025 material sources in 2027 creates compliance exposure.
What the leaders did differently
They started with a data audit, not a technology decision. Before selecting any platform, they mapped exactly what data they had, where it lived, and what was missing.
They then prioritised Tier 2 supplier engagement — the hardest part — before any other work. Everything downstream (QR codes, public pages, compliance scoring) is straightforward once the data exists.
The technology choice came last.
Where to start
If you're a fashion brand with 50+ SKUs preparing for the 2026 mandate:
- 1.Run the supply chain data checklist against your current product catalogue
- 2.Identify which data fields are missing or unstructured
- 3.Begin Tier 2 supplier outreach now — this takes longer than you expect
- 4.Choose a DPP platform once you know the shape of your data
Don't let perfect be the enemy of published. A 70% complete DPP in January 2026 is better than a perfect one in April.