Will DPPs create a new way of greenwashing?
Risks, challenges and potentials of the Digital Product Passports and a deep dive with retraced
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A range of new regulations for the textile sector passed by governmental institutions keeps brands on their toes. The EU Ecodesign for Sustainable Products Regulation (ESPR) is one of them and became law this summer. With it comes Digital Product Passports (DPPs) that provide digital identities and records for physical products. They have to be provided on all goods sold in the EU by 2030.
The ESPR's role is to ensure that products are sustainably designed, produced, and managed throughout their lifecycle. It’s not merely a compliance measure but a pathway toward integrating sustainable practices within the core of fashion brands. DPPs are the “communication tools” and an important part of reaching the EU’s goal of creating a circular economy, where resources are reused, recycled, and kept in circulation for as long as possible.1
Though, as good as DPPs sound in theory, many practical questions remain open. Are customers going to use them? Which information will DPPs provide? How can the information be structured best to be useful across industries? In this issue, we will cover as many questions as possible and tackle another important aspect barely discussed in detail: Will DPPs bring new forms of greenwashing?
What to expect in today’s pro section:
We spoke to Thakane Bazill from retraced:
How we can ensure that DPPs aren't just amplifying selective disclosure or greenwashing
How retraced prevents brands from using traceability platforms for greenwashing
Whether DPPs are shifting responsibility to the consumers
All the best,
Tanita & Lavinia
Digital Product Passports (DPPs) are a comprehensive digital record accompanying products, detailing every aspect of their lifecycle from raw material sourcing to end-of-life disposal. In practical terms, DPPs provide a digital identity for products. They can be easily accessed via a QR code or similar technology.
The aim is to offer full transparency, making it possible for consumers, regulators, and stakeholders to trace the origins, production processes, and sustainability credentials of products.
While the exact data points required for the DPP have not been finalized yet, the idea is to provide information such as:
Material origin and quality: Information on the sourcing and sustainability of raw materials.
Manufacturing processes: Details on production facilities, including labor conditions and environmental impact.
Product lifecycle data: Insights into the durability, repairability, and recyclability of the item.
Environmental footprint: Metrics on emissions, water usage, and waste management throughout the product’s lifecycle.
Recycling and end-of-life options: Guidelines on how the product can be recycled or responsibly disposed of.
What’s important: The DPP is designed and marketed not just as a compliance tool, but as a reputation safeguard for brands that want to prove their sustainability claims are real. Because it is supposed to provide verifiable data.2
The Potential and Challenges of DPPs
By providing comprehensive product data across the supply chain, DPPs can (hopefully):
🔸 Enhance supply chain traceability: Consumers and stakeholders gain insight into the origin, production methods, and impact of the materials used. It forces brands to get to know their supply chains and improve visibility at each production phase. DPPs also bear the potential to ensure sustainable sourcing and human rights compliance.
🔸 Promote circularity: Information on the recyclability and reusability of materials helps consumers, businesses, and recyclers extend the lifespan of garments and will assist with sorting and optimization at the end of a product’s life, contributing to more efficient recycling processes.
🔸 Foster “sustainability”: The DPP encourages more sustainable practices by holding brands accountable for their ecological footprints–from production to the end-of-life phase of a product.
🔸 Improve robust “sustainability” claims: DPPs require brands to disclose key sustainability metrics (e.g., carbon footprint, water usage, lifecycle data) and offer means to provide verifiable data to back them up.
🔸 Bring back consumer trust: As greenwashing accusations continue to erode consumer trust, particularly with brands that make false or exaggerated claims about their environmental and social impact, the DPP offers a data-backed way to demonstrate transparency. So for brands, the DPP is not just a regulatory measure; it can be a strategic opportunity to differentiate themselves in a crowded and sustainability-conscious market and build trust (again) with consumers (let’s give us some hope here!).
🔸 Establish new communication “channel”: Some brands already test out DPPs on their clothes such as QR codes sewn into the products. This builds a new touch point and new channel through which brands can contact customers and possible customers who might have bought the product second-hand. But this is only possible if the tag has not been cut out before (which many people do!) and the tag is scanned and actually used.
Challenges of implementing DPPs remain:
🔹 Data integration: Implementing DPPs across a global and fragmented supply chain is complex. Fashion brands often rely on a vast network of suppliers, each using different data formats and technologies. This fragmentation makes it difficult to compile, validate, and integrate information in a cohesive and universally accessible way. To implement DPPs effectively, the industry’s processes must be fully digitized, along with a deep understanding of the diverse sourcing models and global production networks.
🔹 Missing universal standards: The lack of universal standards for measuring specific environmental impacts, like a product’s carbon footprint in circular terms, complicates the implementation of DPPs. While the European Commission’s Product Environmental Footprint (PEF) and Organisation Environmental Footprint (OEF) provide frameworks for assessing lifecycle impacts, they still face challenges. The PEF, in particular, attempts to offer a comprehensive evaluation by including stages such as consumer use and the end-of-life phase, aiming to capture a product's full environmental impact. However, it is also criticized for oversimplifying complex environmental data. And it’s not yet clear how DPPs will handle this.
🔹 Penalties & enforcement: It’s still unclear which exact penalties companies risk if they don’t comply and how authorities will manage enforcement consistently across different industries and countries within the EU.
Now that we’ve covered the basics let’s look at some risks of DPPs. While the Digital Product Passport (DPP) is designed to enhance transparency and sustainability in consumer goods industries, its existence may open the door to new forms of greenwashing.3 Here’s how alignment with the DPP could create a misleading image of sustainability:
1. Selective storytelling
Brands could selectively highlight certain aspects of their DPP data to appear more sustainable than they truly are. For example, a brand may tout improvements in material sourcing (e.g., organic cotton or reduced carbon footprint) while ignoring their excessive use of water or energy in production processes. By selectively highlighting favorable metrics, brands could divert attention from critical but negative aspects and create a superficial sense of environmental responsibility while the full scope of the company's impact remains hidden.
2. Complexity overload
Dense and technical data presented in sustainability reports can be overwhelming to consumers. Companies might use this complexity, highly technical language and metrics to create an illusion of transparency and sustainability. If information is inaccessible or impenetrable, it can undermine genuine transparency efforts.
3. Minimalistic reporting
Brands might focus on meeting the DPP’s basic requirements without committing to deeper environmental or social improvements. For example, a fashion brand could report on its carbon footprint or material composition while avoiding more complex issues like labor rights violations or overproduction.
4. Failure to address overproduction
The fashion industry’s massive overproduction problem remains largely unchallenged by the DPP. A brand could produce enormous volumes of clothing, much of it destined for landfills, while still showcasing its compliance with the DPP as proof of its environmental responsibility. The focus on individual product sustainability doesn’t address the broader issue of how much is being produced.
5. Labor exploitation behind the data
While the DPP focuses on product metrics, it could fail to sufficiently address labor conditions within supply chains. Brands might publicize their DPP data to promote sustainability, but behind the scenes, workers in low-wage countries could still be enduring poor working conditions, low wages, or unsafe environments. The DPP’s emphasis on product data risks that human costs are overlooked.
6. No real change
The DPP requires data on aspects such as product lifecycle and composition, but merely checking off regulatory requirements doesn’t mean a brand is addressing core sustainability challenges. A brand can comply with the DPP, yet continue using exploitative labor or unsustainable manufacturing practices.
7. Marketing tool, not transformation
As the DPP becomes a legal requirement, brands might use it as a marketing tool to bolster their green credentials without fundamentally changing their practices. They can point to their compliance with the DPP as proof of “sustainability,” diverting attention away from unsustainable business models focused on high-volume production and short product lifecycles.
The DPP has the potential to bring positive change, but without careful oversight and a focus on holistic sustainability, it risks becoming a greenwashing tool. For real change to happen, brands need to go beyond the data points and commit to addressing the root causes of the fashion industry’s impact on people and the planet.
Brainstorming on these risks of greenwashing, we were inspired by the thought-provoking conversation between Rachel Donald and Veronica Bates Kassatly. Big recommendation to watch and listen here:
Donald, Rachel. "The Green-Washing Machine: Veronica Bates Kassatly." Planet: Critical.
Bates Kassatly, Veronica. "The True Cost of Fashion." YouTube video. Directed by Planet: Critical.
Welcome to our pro section!
In this issue’s pro section, we talk to Thakane Bazill, Account Executive at retraced. She’s worked in sustainable supply chain strategy, business development, and consulting for more than eight years with a special focus on fostering sustainability in the global south. In our interview we talk about:
How we can ensure that DPPs aren't just amplifying selective disclosure or greenwashing
How retraced prevent brands from using traceability platforms for greenwashing
Whether DPPs are shifting responsibility to the consumers
Thakane, when did you start looking into e-tech and blockchain and what does it have to do with fashion supply chains?
My deep dive into this space started when I saw brands beginning to claim sustainability without providing concrete proof, which truthfully has not been an easy challenge! The potential of blockchain to decentralize data control and enhance accountability expands across industries; notably democratising ownership and intellectual property in the arts and music. This lead me to a deeper examination of how this tech could genuinely impact transparency in supply chains in fashion as well as protect design IP. From my perspective, the journey of interrogating e-tech and blockchain in fashion really began when the industry's complexity—its sprawling and complex supply chains, the obscurity around labor practices, and environmental impacts—became undeniable.
The integration of e-tech in supply chain management has evolved from basic electronic communication to sophisticated, data-driven, and decentralized systems. Historically e-tech has been used for stock & retail management in the form of centralised ERP systems back in the 90’s, with companies such as SAP. The centralised nature of ERP systems, whilst great for internal and cross-departmental data consistency, poses serious constrictions to supply chain management, which in its nature is decentralised and requires varying data from many parts of the world in different formats and from ever interchangeable stakeholders. As new legislations push for worldwide supply chain transparency, only decentralized blockchain applications have the ability for scalable transparency and accountability between various stakeholders.
How do we ensure that DPPs aren't just amplifying selective disclosure or greenwashing?
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