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There is a conversation repeating itself in CIRPASS-2 working groups, at DPP conferences, and now on LinkedIn: "The Digital Product Passport helps consumers make conscious, sustainable choices."

This is only partially true—and that part is the least relevant for those working in the textile supply chain.

The Digital Product Passport (DPP) is a tool for legal liability between economic operators and market surveillance authorities. The consumer scanning the QR code is the endpoint, not the primary recipient.

Understanding this distinction radically changes what non-EU suppliers must do, what brands must purchase, and why most DPP platforms currently on the market are selling the wrong solution to the wrong people.

Who Holds the Legal Obligation for the DPP?

ESPR (EU 2024/1781) Article 21 is clear: the manufacturer—or, if based outside the EU, the importer—is responsible for generating the DPP and ensuring its compliance. Not the Bangladeshi manufacturer, not the Chinese weaver, not the Indian spinner.

The European brand that places its label on a garment and introduces it to the EU market is the "manufacturer" under ESPR. They sign the DPP. They are the ones answering to customs authorities when the QR code is scanned at the border. They are the ones risking sanctions—up to 4% of global turnover—if the DPP is missing or non-compliant.

The non-EU supply chain has no direct legal obligation to issue a DPP. However, they have an indirect obligation that is just as binding: providing the verifiable data that the brand will input into the DPP. If they don’t provide it, the brand cannot buy from them. End of contract.

The Customs CoA Test: Data That Already Exists

Thirty years in the textile supply chain have taught me one thing that many DPP startups seem to ignore: every textile bulk export already has a composition test.

It is the Certificate of Analysis (CoA) that accompanies every shipment for customs purposes. It is the document upon which HS duties are based; it is legally binding and issued by accredited laboratories. It is not a self-declaration—it is a document carrying signature and legal weight.

When a factory in Vietnam exports 10,000 meters of fabric labeled "55% linen, 45% polyester" to an Italian brand, that CoA test already exists in the customs documentation. It contains exactly the information the "compositional" DPP requires.

This is the point the DPP market has yet to grasp: For simple composition declarations—without certified claims like GRS, GOTS, or OCS—the CoA test is sufficient. You don’t need a new verification system. You don’t need mass balance. You need a system that takes that existing document, structures it into the standard DPP format (UNTP DPP 0.6.1), and publishes it with a verifiable QR code.

In this scenario, a DPP platform is simply an intelligent data repository with ESPR-compliant output. Nothing more.

When Mass Balance Becomes Mandatory

The situation changes radically when a brand makes a certified claim on the finished product. "This garment contains 45% GRS certified recycled polyester."

This sentence is a commercial claim toward the consumer, backed by a Transaction Certificate (TC) that authorizes a specific volume of certified material—expressed in kilograms, over a 90-day period.

The structural problem—which I formally documented in the CIRPASS-2 survey (Contribution ID: bb6997ac, January 2026)—is that no current system verifies whether that volume in kg actually covers the garments produced.

A TC for 500 kg of GRS recycled polyester can cover 2,700 shirts weighing 185g—or 2,700,000 shirts, if no one does the math. The difference is the gap between real compliance and documented greenwashing.

Gram-per-garment mass balance is the bridge between these two worlds: it converts the TC volume (kg) into consumption per garment (g) and blocks the issuance of the DPP if the balance does not close. This is the mechanism that ESPR and the Green Claims Directive require for certified claims—and it is a mechanism that no system currently offers except Reeco.

Two Modes, One Massive Market

The practical consequence of this reasoning is that two distinct DPP markets exist, driven by completely different logics:

Market 1: Compositional DPP (No Certified Claims)

  • Scale: The vast majority of global textiles. Virgin polyester, conventional cotton, uncertified blends.

  • Requirement: Structure the existing customs CoA test into DPP format.

  • Technical Complexity: Low.

  • Competition: High.

  • Unit Value: Low.

  • This market is huge in volume but hard to differentiate. Anyone can build a DPP "wrapper" around a PDF. Platforms selling this service to Asian manufacturers are essentially replacing Excel with a more structured format.

Market 2: DPP with Certified Claims (GRS, GOTS, OCS, RCS)

  • Scale: Currently a minority, but growing rapidly under ESPR pressure.

  • Requirement: Verified mass balance at the garment level; hard block on issuance if the TC does not cover production.

  • Technical Complexity: High.

  • Competition: Almost zero.

  • Unit Value: High.

  • Sanction Risk for the Brand: Maximum.

The turning point occurs when the Textile Delegated Acts become operational. These are expected in 2027, with an 18-month transition period. From that moment, any brand selling garments with certified claims in the EU market without a mass balance verification system will be in direct violation. Market 2 shifts from optional to mandatory.

What Non-EU Suppliers Must Do Now

The answer depends on what you sell and to whom.

  • If you sell fabric without certified claims to European brands: Ensure you have your CoA tests in a structured, digitally transferable format. You don’t need a complex DPP platform—you need your ERP (or the brand’s system) to be able to ingest the document. The cost of adaptation is marginal because the document already exists.

  • If you sell certified fabrics (GRS, GOTS, OCS) or if your buyer makes certified claims: The CoA test is not enough. Your buyer needs a system that verifies the mass balance between your TC and the garments they produce. If you don’t provide this—or allow them to verify it—you are a non-compliance risk for them. In the post-Delegated Act market, this means losing the order.

  • If you are the brand: The legal responsibility is yours. The supplier gives you the data, you issue the DPP, you answer to the authorities. Choose a platform that distinguishes between simple composition and certified claims—treating them as the same thing means either overspending on what you don’t need or lacking verification where it matters most.

The Multi-Billion Dollar Question

The DPP platform market is crowding quickly. Every week brings new entrants, new pitches, and new announcements.

The question no one is asking openly is: Which of these systems actually blocks the issuance of a DPP when the math doesn't add up?

The consumer scanning the QR code won’t know. The market surveillance authorities, when inspections begin, certainly will.

A brand that chooses a data repository over a verification system today hasn't solved the problem—they've just hit "snooze" on the alarm.

Stefano Cipriani is the founder of Reeco and Stefano Cipriani Studio, with 30 years of experience in the international textile supply chain. Reeco is registered in the UNTP Software Implementation Register (UN/CEFACT) as the first active textile implementation with DCC export. Expert Member CIRPASS-2 EWG1, EWG3.