Supply Chain Transparency in Fashion: What the EU Parliament DPP Study Says

Supply chain transparency moved from marketing to product-level information systems in EU policy discourse. This post summarises what the official European Parliament study Digital product passport for the textile sector (PE 757.808, June 2024) says — and what it does not claim.

The gap the study documents

Analysis of 54 Fashion Pact brands (cited in the study):

83% publish CSR / extra-financial reports
30% publish a first-tier supplier list — usually not linked to products
93% show country of manufacture in-store for most products; 17% online

Conclusion in the study: move from brand transparency to product transparency (specific product + manufacturing process).

Why traceability is hard

The garment chain is buyer-driven with Level 0 (brand/retail) through Level 4 (raw materials):

Level	Tier	Typical activity
0	Brand	Order, market, sell
1	CMT	Cut, sew, assemble
2	Fabric	Weave, knit
3	Yarn	Spin, prepare fibre
4	Raw material	Farm, polymer, recycled feedstock

A barcode alone cannot distinguish similar products with different processing (study Figure 3 example).

What Phase 1 transparency requires (study)

Mandatory in the minimal DPP (2027 horizon):

Locations of confection, weaving/knitting, dyeing/printing, significant wet processes
Composition themes: recycled material, dangerous substances, plastic microfibers
Recyclability, packaging data, environmental innocuousness

Not Phase 1 mandatory:

Full public tier 4 traceability to every trim supplier (survey: very difficult)
Public supplier name lists where confidential (study + survey: access control required)
Manufacturing costs

Confidentiality is part of the design

Survey comments in the study (81 stakeholders):

Supplier names can be confidential — use authorisation and need-based transparency
Different user views for consumer vs business vs authority
Each actor should be responsible for local data with quality standards

Transparency ≠ publishing everything on a public website.

Business benefits (aligned with study aims)

The study lists aims relevant to brands:

Informing companies — centralised supply-chain data for quality, sourcing, compliance
Managing resource flows — sourcing shifts (e.g. organic vs conventional cotton)
Market surveillance and regulatory compliance
Commercial differentiation for brands that prove claims
Circularity — repair, resale, recycling need product data

Specific ROI percentages (conversion uplift, wholesale revenue) are not in the study — treat those as your own business cases if you measure them.

Other EU instruments the study mentions

ESPR and delegated acts (product requirements, DPP rules)
Textile labelling revision (physical + digital labelling with ESPR)
CIRPASS (standards-based DPP data model)
Corporate Sustainability Due Diligence proposal / CSRD (social reporting may feed DPP)
AGEC (France) — since January 2023 for product environmental information

Minimum viable transparency for Phase 1

Recycled content, dangerous substances, microfibers (as applicable)
Recyclability
Process locations (confection, fabric formation, dyeing/printing)
Packaging circularity fields
Innocuousness / environmental product information

Add tier names, certificates, and transport in Phase 2 or as voluntary data when buyers ask — consistent with the study’s phased model.

How to start

One product line, Phase 1 fields only
Restricted supplier identity where needed
Supplier portal instead of email PDFs (study: manual collection is costly and error-prone)
Link public pages from e-commerce