Amid the EU’s push for a circular economy and heightened supply chain transparency requirements, the Digital Product Passport (DPP) is emerging as a critical tool in product lifecycle management. With the EU currently accounting for over 10% of Vietnam’s total textile and garment exports, these new DPP requirements will directly impact businesses within the export supply chain to this market. On March 19, 2026, the European Commission’s Joint Research Centre (JRC) released its methodology for defining data requirements for the DPP under the Ecodesign for Sustainable Products Regulation (ESPR) framework. This article analyzes the key changes in the DPP data methodology while clarifying three practical issues for textile enterprises: what data needs to be prepared, who is responsible for providing the data, and how compliance costs can be allocated.
Shifting from Information Disclosure to Data Governance
The DPP is a key tool for achieving the goals of the Ecodesign for Sustainable Products Regulation (ESPR), aiming to enhance transparency, traceability, and promote a circular economy for products circulating within the EU market. However, the ESPR merely establishes a general legal framework, while specific data requirements for each product category will be defined through Delegated Acts.
According to the latest JRC report published in March 2026, establishing standardized data requirements for the DPP requires a common methodology to determine which data is necessary, its level of detail, and who has access rights. This methodology will serve as the foundation for the European Commission to draft data requirements for individual product groups in the coming period.
For the textile and garment industry, this signals a shift in the DPP’s focus from mere information disclosure to data governance. Rather than simply adding extra data fields, enterprises need to build a solid foundation for data governance, traceability, and data sharing across the entire supply chain.
Fundamental Changes in Data Methodology
The new Digital Product Passport (DPP) methodology published by the JRC in March 2026 shifts the focus from mandating what information companies must disclose to determining which data is truly necessary to serve policy objectives, stakeholder needs, and practical implementation. Consequently, the DPP does not require businesses to generate additional data, but rather demands more effective data governance.
Instead of storing records in paper formats or isolated files, enterprises must standardize their data into structured, updatable, and interoperable digital systems. At the same time, traceability requirements are shifting from document-based proof to actual data across the entire product lifecycle—from raw materials and production to distribution, reuse, and recycling. Pilot programs demonstrate that the primary challenge is not generating QR codes, but rather collecting and verifying data across the supply chain.
Furthermore, the DPP emphasizes the crucial role of data standardization and product identification. QR codes, RFID, or NFC tags are merely access tools; the core value lies in the underlying data system. Therefore, enterprises must prioritize standardizing product codes, raw materials, supplier information, and data structures to meet traceability requirements and implement the DPP effectively.
What Must Textile Enterprises Prepare Ahead of the DPP Roadmap?
The greatest challenge in implementing the Digital Product Passport (DPP) lies not in generating QR codes or investing in software, but in the capacity to collect, verify, and share data from suppliers across the supply chain. Experience from international pilot programs shows that enterprises should prioritize building data governance mechanisms and assessing existing data gaps, rather than spreading technology investments too thin.
According to the JRC methodology, companies do not need to collect all data points at once. Instead, they should prioritize critical data sets such as product identification, raw material specifications, supply chain mapping, chemical usage, compliance certifications, and circular economy data. At the same time, it is essential to clearly define data provision responsibilities among manufacturers, suppliers, and brands, while proactively negotiating data scopes, cost-sharing mechanisms, and information security protocols.
Because the detailed EU regulations for the textile and garment sector are still being finalized, Vietnamese enterprises should not wait for official policies to be enacted before taking action. Selecting a few product lines exported to the EU to conduct data inventories and test information-sharing mechanisms during 2026–2027 will help mitigate risks, progressively meet DPP requirements, and ensure readiness for the implementation roadmap in the coming years.
Key Implications for Textile Enterprises
From the JRC’s new methodology and the ESPR framework, it is clear that the DPP is primarily a requirement for product data governance, not merely a QR code or a software tool. Since specific requirements for textiles remain dependent on upcoming EU Delegated Acts, enterprises do not yet need to roll out implementation across their entire product portfolio. However, they should leverage the 2026–2027 period to evaluate data gaps and standardize codes for products, raw materials, and suppliers, as well as data regarding chemicals, certifications, and traceability.
In addition to internal data standardization, companies must proactively engage with clients and suppliers regarding data scope, access rights, information security, and compliance costs. Over the long term, the DPP may serve as a litmus test for the supply chain governance capacity of textile enterprises, while simultaneously presenting an opportunity to enhance traceability, supplier oversight, chemical control, and compliance with the increasingly stringent sustainability standards of export markets.
