DPP readiness: The designer's pivotal role

Much has been written about the digital product passport (DPP), the digital twin which needs to be linked to the physical product from mid 2029 onward. At least for anyone wanting to place textile products on the European market. However, information about the DPP usually focuses on data compliance and technical preparations. But the fact is that the majority of what is measured is determined at the design stage.

FashionUnited spoke with Narendra Makwana, co-founder & CEO at SaaS (Software as a Service) platform GreenStitch, and Emma Grace Bailey, director of sustainability at global trend forecaster Future Snoops (formerly Fashion Snoops) about the role of the designer and the design team when it comes to DPP readiness and foresightful design. 

According to the European Commission, up to 80 percent of a product’s environmental impact is decided at the design stage. This makes sense, after all, the material selection alone can have a great impact, as does the manufacturing and, depending on the previous two, the garment’s or textile’s longevity.  

“No compliance team, technology platform or data management system can compensate for design decisions that do not live up to DPP standards,” emphasises Makwana.

Let’s take a closer look at each of these three important areas to find out how decisions taken at the design stage influence the environmental impact of a garment or textile. 

How design decisions determine environmental impact

Material

Many considerations have to be taken into account when selecting a garment, for instance are microplastics released when washing it? How much water was used to grow or make the raw material? How many pesticides? Which dyes and chemical treatments were necessary? How easy is it to recycle the garment or textile once it has reached the end of its life? 

Synthetic fibres like polyester release microplastics, while conventional cotton cultivation may use harmful pesticides and consume much water. Dyes and chemical treatments can pollute local water sources if not managed properly. Though textile-to-textile recycling is becoming more refined, mixed-fibre fabrics like polyester-cotton blends for example still pose a challenge.

At this point, a word about elastane. It is widely used in the industry, especially when stretchiness is desired, for example in activewear, swimwear, shapewear and stretch denim. However, it is hard to recycle with the existing technology and even if a majority of the material used is not elastane, even a fairly small percentage makes the entire product much harder to recycle or repurpose.

Though not yet confirmed and still subject to the Delegated Act, it is likely that the threshold for garments and textiles even considered for recyclability will need to have less than 15 percent elastane. “High elastane content creates significant recyclability risk and is expected to attract higher EPR fees under the DPP system,” warns Makwana (see Recyclability below for design alternatives).

Production process

Even if an environmentally favourable material has been chosen, much depends on its processing - how dense is the weave, for example, and how strong are the seams? How durable is the thread that was used to stitch the different parts together? Are there reinforced parts and seams for high-impact clothing like outdoor and athletic wear? All these considerations can prevent early wear and tear, thus extending the life of a garment.  

If a garment should need repair, for example due to a split seam or a missing button, how visible are the seams? Are spare buttons included for easy repair? 

Even the style plays a major role in extending a garment’s life span: Is it designed following quickly changing trends or is it a timeless design that will last many seasons? The same is true for colour choices - are they trendy and seasonal or classic and lasting?  

End-of-life and circularity

Two factors stand out when it comes to what happens to a garment at the end of its life: mono-materials and disassembly. Using a single fibre type makes it easier to break down and recycle a fabric; avoiding permanent glues or mixed trims helps workers separate parts easily. 

“This is why designers must be brought into DPP compliance at the beginning of a brand’s transition, not at the end,” urges Bailey. “[They] are not peripheral to DPP compliance - they are its primary determinant.”

Key performance indicators for designers

While the details for DPP data fields are currently still being worked out, four core performance indicators or so-called design options (DOs) are currently suggested to be required for DPP compliance: The robustness score (DO1), the recyclability score (DO2), recycled content (DO3) and carbon footprint (DO4). 

Robustness

What does this mean? DO1 assesses the physical performance of a garment after five wash cycles, tested via standardised ISO methods. This includes colour stability, pilling, seam integrity, fastener function, spirality, dimensional change and shrinkage.

For each new product, designers should consider different parameters like fabric construction and weight, fibre quality, seam construction and stitch density, fastener and trim quality and care label accuracy. The latter will be scrutinised and tested, so giving accurate information is imperative.

Recyclability

DO2 measures end-of-life material recoverability. This includes blend composition and construction, both on a scale of 1 to 10. Mono-material products, those with a simple construction and garments made with fibres compatible with existing recycling technology score highest; products containing more than 15 percent elastane (see above) will likely score lowest if not zero. 

“Recyclability is almost entirely determined by material specification decisions. Designing out elastane is key. Designers must explore alternatives, such as mechanical stretch via fabric construction, natural stretch fibres like wool, and bio-based elastane alternatives,” advises Bailey.

Recycled fibres

The third design option looks at the percentage of recycled fibres used in a product. Brands must distinguish between open-loop recycled content and closed-loop textile-to-textile recycled fibre. The former is a system where discarded fabrics are repurposed into new products different from their original form and for different industries (down-cycling). 

Closed-loop recycling means recycling textiles and clothing into new products of the same type and quality as the original. “It is likely that future requirements will limit recycled content to closed-loop only,” notes Makwana.

This means that designers can no longer avoid recycled content targets and should build them into material briefs by default, working closely with procurement to identify certified suppliers.

Carbon footprint

DO4 measures the manufacturing-phase (Tier 1– 3) impact including either the greenhouse gas (GHG)/carbon emissions or the environmental footprint (GHGs, energy, water use and water pollution). While Tier 4 will likely be excluded from Phase 1, it will likely be required from Phase 2 onward. Though average secondary data is permitted initially, primary data will be expected eventually. 

“Material choice is key. Designers must consider the impact of conventional cotton vs organic cotton, virgin polyester vs recycled polyester and so on,” emphasises Makwana. Designers should keep in mind that Tier 2 dyeing and finishing accounts for 36 percent of greenhouse gas emissions at the manufacturing level. Hence, low-impact processes and dyeing techniques perform better. 

How to embed DPP compliance at the design stage 

When ensuring DPP compliance right from the design stage, brands need to bring in new standards and processes that have circularity at their center: A regenerative approach that creates products, services and systems that eliminate waste and pollution by making them (re)usable, again and again. 

The report highlights seven areas that designers should start from: designing mono-material garments or low-blend compositions keeping disassembly, mono-components and recycling pathways already in mind, minimising or eliminating chemical-intensive finishes such as PFAs waterproofing, not compromising durability for aesthetics, integrating verified recycled content from the brief stage and documenting everything as design decisions create DPP data.

“The DPP is only as accurate as the data behind it. Designers who make decisions verbally, informally or in non-standard formats create data gaps that compliance teams cannot close,” warn both Makwana and Bailey. 

Brands must embed circular design principles from the very beginning of the creative process to eliminate waste and keep materials in use. Designers need to prioritise mono-material garments or keep secondary fibre blends below 15 percent, while embedding verified recycled content into the initial brief rather than leaving it as a procurement preference. 

Additionally, chemical-intensive treatments like PFAS should be minimised to prevent compliance penalties and recycling hurdles, favouring functional fabric choices or bio-based solutions instead. “Design functional performance into construction and fibre choice rather than chemical finishes, or invest in emerging bio-based solutions,” advises Bailey. 

Products must also be conceived with realistic end-of-life recycling pathways and built for easy disassembly through zippers in separable tracks rather than being sewn-in, matching fibres for shell and linings and removable trims and embellishments. 

“Designers should ask at the concept stage, what recycling pathway is this product designed for? Which technology can recover this material, and is that technology accessible enough to ensure it will be recycled?,” urges Bailey. “‘Designed for recycling’ isn’t the same as ‘it will actually be recycled’,” she adds.

Beyond initial material choices, long-term durability and meticulous data tracking are essential for full compliance. Garments must be engineered to endure wear and repeated washing without pilling, fading or seam failure, as poor performance can trigger higher Extended Producer Responsibility (EPR) penalties. Achieving this requires careful selection of fabric weights, stitch densities and seam allowances from the first sketch. 

Finally, because a DPP is only as accurate as its underlying data, all design decisions, material specs, chemical treatments, and supplier choices must be formally documented in standardised digital formats rather than agreed upon informally. “Every material specification, construction choice, chemical treatment, care instruction and supplier decision needs to be formally documented in a way that flows into the DPP data system,” recommends Makwana.  

How long will design DPP readiness take? 

For many brands, this may sound rather complicated and time-consuming but the two industry stakeholders have put together a timeline specifically for designers that makes the switch easy. The main impetus is to act now and not wait. 

“Collecting verified fibre composition, chemical treatment and environmental data from Tier 2 fabric mills takes a minimum of 12-18 months and every design decision that creates a new Tier 2 supplier relationship creates a new data gap that takes over a year to close. Brands need to act now, and design briefs should be updated with DPP criteria before the Delegated Act is determined in 2028,” advises Markwana. “If you wait for the Act to be finalised before taking action, you will face a structural crisis - fewer than 18 months to build systems and data pipelines that take a minimum 12-18 months to establish.”

They have identified six action items that designer and design teams can start with immediately. First, present practices should be scrutinised, especially in regards to the usage of elastane (see above), and current design briefs should be updated so that DPP criteria becomes a standard.

Next, they should use DPP scoring systems to evaluate and approve materials and products. Also they should be equipped from day one with DPP standards and the seven circular design principles, namely sourcing better materials, material optimisation, carbon-conscious design, design for longevity, adaptability and disassembly and refining circular loops.

Establishing cross-functional DPP design working groups is also an important step, as well as developing a material library with only DPP-compliant materials. Finally, DPP data collection should commence on three to five stock keeping units at first before expanding.

Challenges

As seen, designers play a pivotal, upstream role in DPP readiness because approximately 80 percent of a product's overall environmental impact is determined during the design phase. Rather than treating the DPP as a physical label or regulatory requirement tacked on at the end of manufacturing, designers must therefore adopt a proactive mindset—embedding compliance, circularity and commercial value directly into early product development. 

This requires design teams to make deliberate, data-driven decisions regarding raw material selection (such as preferring closed-loop recycled fibre over virgin inputs), durability and repairability standards (ensuring stability against wear, fading and shrinking) and disassembly for end-of-life recycling. 

Ultimately, designers act as the primary architects of a product’s digital twin, locking in the data parameters—such as carbon footprint, recycled content percentage and robustness scores—that determine a brand's long-term regulatory compliance and circular economy potential.

However, operational, technical and market realities exist that designers have little influence over. While they can select sustainable materials on paper, they depend entirely on primary data from upstream suppliers like dye houses, yarn spinners and chemical treatment facilities. Many lower-tier suppliers—particularly small and medium-sized enterprises (SMEs) in developing regions—lack the digital infrastructure or standardised tracking systems (yet) required to feed granular LCA (Life Cycle Assessment) data into a DPP. Hence, a designer’s specification is only as valid as the weakest link in the supply chain data flow.

In addition, positioning designers as the primary ‘architects’ of a product’s digital twin places an overwhelming technical and administrative burden on creative teams. Designers are rarely trained in regulatory compliance, data schemas or detailed lifecycle software. Without automated integration between Product Lifecycle Management (PLM) systems, Enterprise Resource Planning (ERP), and DPP platform APIs, forcing designers to manually track compliance data risks could bottleneck the creative and development workflow.

Another challenge is cost: Prioritising closed-loop recyclability or mono-material design can conflict with financial constraints. High-grade recycled fibres, specialised detachable hardware, or certified eco-friendly dyes often increase unit manufacturing costs or require higher minimum order quantities. Design reports often underemphasise the friction between design ideals and commercial margin targets enforced by merchandising and finance teams.

Last but not least, there is the disconnect between consumer and recycling infrastructure to consider, meaning that a product designed for circularity does not necessarily guarantee circular outcomes. The reality is that a product meticulously designed for repair or disassembly will still end up in a landfill if local sorting, repair networks and high-value recycling facilities do not exist at scale in the consumer's region. Furthermore, without intuitive user experience design that prompts consumers to actually scan the DPP and participate in take-back programs, the digital passport may remain unused.

While certainly important to consider, none of the challenges are insurmountable. But they make another compelling point for designers and design teams to get started on the road to DPP readiness sooner rather than later. 

More about the role of the designer and DPPs can be found in Future Snoops and Greenstitch’s  joint report “Digital Product Passports: Designing for Future Regulation, Now”. 

The full report can be downloaded on the Future Snoops website.