Fashion Is Lurching Toward a Compliance Reckoning
Two years out from implementation, digital product passports and extended producer responsibility have arrived as operational realities. The systems required to meet them — from supplier data to sorting infrastructure — are not.
Reported by Vogue.
The fashion industry is about to hit a wall it didn't see coming. By late 2027, the EU will require digital product passports (DPPs)—essentially a digital resume for every garment sold in Europe, documenting materials, supply chain, and environmental impact. By April 2028, extended producer responsibility (EPR) rules kick in, forcing brands to finance end-of-life waste management. The catch? The infrastructure to actually deliver on either mandate barely exists.
These aren't optional upgrades for European brands. Any company—regardless of headquarters—selling into the EU must comply. That means tracking granular product-level data from raw material to recycling bin, a feat that currently lives scattered across incompatible systems: spreadsheets, PLM software, ERP platforms, lab reports. Much of the information brands need simply hasn't been collected yet. Basic data points like product weight often aren't systematically available, according to Philipp Mayer, co-founder of supply chain transparency platform Retraced. The closer you look at the supply chain beyond direct factory partners, the worse it gets. Textile mills, dyeing facilities, and material suppliers—especially smaller operations in developing countries—still rely on PDFs and email.
The Real Problem Isn't Regulation. It's Organizational Dysfunction.
Strip away the compliance language and the actual crisis emerges: fashion brands are siloed internally and disconnected from their suppliers in ways that have never mattered operationally until now. Merchandising doesn't talk to sourcing. Sourcing is isolated from suppliers three tiers upstream. Nobody owns the data. "DPP and EPR are exposing two things that were already broken," says Liza Amlani, principal at Retail Strategy Group. "Functional silos inside most brands, and supplier relationships too shallow to carry real information flow." The regulation is just making visible what's been dysfunctional for decades.
Then there's the infrastructure gap. DPPs assume sophisticated sorting and recycling systems will actually use that data. They largely won't—at least not yet. EPR creates incentives for brands to design recyclable products, but the domestic sorting and processing capacity to handle those volumes doesn't exist. Existing systems rely on exporting waste or funneling goods to resale channels; neither scales to EPR volumes. And the workforce capable of collecting and verifying data under new requirements? Underdeveloped, especially in regions operating on razor-thin margins.
The most immediate fix is structural: build a centralized product data layer that serves both DPP and EPR requirements simultaneously, rather than creating parallel compliance infrastructures. Most brands are treating them as separate problems, which guarantees duplicated investment and inconsistent data. Without a single source of truth, tracking inventory from concept to end-of-life becomes impossible—and accurate compliance reporting becomes fiction.
Compliance frameworks are only as functional as the actual systems behind them, and fashion's are nowhere near ready.
Read the original at Vogue.
