4.2 Where Your Business Stands Today

Before a fashion brand can create its first DPP, it needs to understand the following:

What product information already exists, where is it stored, who owns it, and what information are we still missing?

For many fashion brands, the challenge is not that product information does not exist. The challenge is that it is spread across the business.

Fibre composition might sit with the product developer, a fabric certificate with sourcing, a factory address in the ERP system, chemical data in a supplier declaration, photographs with marketing, and repair information with customer service.

DPP readiness starts with understanding the information a business already has — where it lives, who holds it, and how complete it is. That groundwork makes every later step, including choosing a system to manage the data, far more straightforward.

4.2.1. The starting point: Mapping the information you already have

A useful starting point is to map the information associated with one product from design through to sale. For example, imagine a fashion brand launching a cotton T-shirt. The company may already have the below listed information.

While the information may exist, it might not necessarily be in a form that can easily be connected to a DPP. It also isn't all equally easy to compile: industry pilot projects have found that data splits broadly into two kinds — straightforward facts such as country of manufacture or material composition, and data that depends on a calculation method not yet agreed industry-wide, such as a product's carbon footprint. The second kind will typically take longer to become "ready," regardless of how well-organised a company's records are.

4.2.2 A practical DPP data inventory and readiness check

The table below combines an inventory of where product information tends to live with a quick readiness status: READY (exists, owned, evidenced), NEEDS WORK (exists but incomplete or hard to find), or MISSING.

Important: This table is an example of a business-readiness tool, not a definitive list of future textile DPP fields. The final mandatory data requirements depend on the applicable EU product rules and delegated acts.

This exercise usually reveals that the biggest problem is not data collection, but data organisation and ownership: the information already exists somewhere in the business, but no one has connected it, verified it or taken responsibility for it.

A fictional case study: Fragmented information

Situation: A fictional 25-person fashion brand believes it already has most of the information it needs for its first DPP.

· fibre composition is in an Excel file;

· supplier addresses are in an ERP system;

· factory information is in a sourcing manager's spreadsheet;

· certifications are stored in individual supplier folders;

· chemical test reports are in the compliance team's email;

· sustainability claims were developed by marketing; and

· care instructions are stored in product-development files.

No single person has a complete view.

The real problem is not a data shortage; it is fragmentation.

4.2.3 From 'Where is the data?' to 'Who owns the data?'

One of the most useful decisions a brand can make is to assign clear data ownership — not necessarily a new role. In a smaller company, one person may hold several responsibilities; in a larger one, they tend to sit with dedicated teams.

The key is that someone should be responsible for knowing: 'Is this information correct, and where is the evidence?'

Ownership is not only about who is responsible internally — it is also worth considering who eventually needs to see each piece of information. Some data stays internal to the brand, some needs to be shared with or verified by suppliers, and some will ultimately need to reach downstream actors such as repairers, resellers or recyclers. Mapping ownership alongside this kind of access need makes it easier to decide what to priorities first.

A parallel worth watching: Battery manufacturers are already going through this exact exercise. Under the Battery Regulation (EU 2023/1542), a mandatory digital battery passport applies from 18 February 2027 — and the European Commission's own guidance for it lists 71 separate data points across categories like carbon footprint, recycled content, performance and safety. Getting ready has meant the same things this chapter recommends: assigning named ownership for each data category, coordinating with suppliers who hold information the manufacturer doesn't, and building the data-collection habit well before the deadline rather than after it. Textile brands are roughly two to three years behind this timeline, which gives a real preview of what's coming.

European Commission (n.d.) Batteries. Available at: https://single-market-economy.ec.europa.eu/batteries_en (Accessed: 23 July 2026).

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