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In February 2027, every electric vehicle battery, every industrial battery above 2 kWh, and every LMT battery placed on the EU market must carry a Digital Product Passport. Article 77 of Regulation (EU) 2023/1542 is operational. Annex XIII specifies the data fields. The harmonised standards — DIN DKE SPEC 99100, JTC24 — are converging. The major battery manufacturers are implementing.
In February 2027, the fashion industry will not have anything comparable.
This is not because ESPR is delayed. It is not because textiles are less regulated than batteries. It is because the architecture that worked for one industry cannot be copy-pasted onto the other — and most of the DPP providers selling to fashion brands are doing exactly that. The battery passport is shipping because batteries are the easy case. Fashion is not the easy case. Anyone selling a fashion brand a passport modelled on the battery template is selling them an artefact that will pass formal compliance and fail substantive verification.
Why batteries were the easier case
A battery has a native serial number from the moment the Battery Management System is initialised. A garment does not. A battery has a finite, chemically documented bill of materials — cathode chemistry, anode composition, electrolyte, cell count — declarable per Annex XIII with CAS numbers and percentages. A garment’s claim is about a fibre that, once converted, is chemically indistinguishable from its non-certified equivalent. Recycled polyester is the same molecule as virgin polyester. Organic cotton is the same molecule as conventional cotton. The claim does not live in the material — it lives in the chain of custody.
A battery is produced by an industry of perhaps a few hundred globally relevant manufacturers, vertically integrated or close to it. A garment is the output of a fragmented network of tens of thousands of converters, dyers, finishers, and cut-and-sew operations across Tier 2, Tier 3, Tier 4. The brand owns very little of this chain.
Volumes are not comparable. A few million EV batteries per year is a manageable identification problem. 29 billion garments per year is not — and the industry has spent fifty years optimising for SKU efficiency, not unit-level identity.
And the certification landscape is plural where the battery world is converging. A battery passport reconciles against one regulatory annex. A textile passport must reconcile against GRS, GOTS, RCS, OCS, European Flax, BCI, Supima, US Cotton Trust Protocol, Lenzing certifications, RWS, RDS — each with its own scope, its own claim wording, its own transaction-or-scope-certificate model, and partially non-comparable assumptions about how mass balance is constructed.
This is the structural starting point. From here, the IT consultant and the textile expert each see only half of the picture.
Two stacks that do not meet
Talk to a senior digital identity consultant who can implement OID4VCI properly — Ed25519 plus ES256 dual signing, JWKS aligned with the issuer DID, three coherent verificationMethod entries, a Sphereon Wallet returning ✅ Verified — and ask them what a Transaction Certificate is in the GRS Standard. Ask them how a Scope Certificate differs from a Transaction Certificate. Ask them why European Flax has no transaction-level certificate at all, and what that absence means for a per-garment claim. Ask them why Supima and BCI work on entirely different verification models — direct grower verification versus chain-of-custody mass balance — and what that implies for the structure of the DPP claim itself.
They will not know. They were not trained to know. They are not paid to know.
Now talk to a senior textile sustainability manager — twenty years of certifications, audits in Vietnam, Bangladesh, Turkey — and ask them what an eIDAS-2 qSeal is, why a DPP issuer must be registered under Article 5 of the EU DPP Registry Common Implementing Regulation (Ares(2026)4424976), what Ed25519 is for, what happens when the JWKS endpoint does not match the verification methods declared in the DID document. They will not know either. They were not trained to know. They are not paid to know.
Both populations are excellent. Both are necessary. Neither, in isolation, can build a DPP that survives a customs inspection in Rotterdam.
What the IT consultant does not see
Take a brand declaring 10,000 garments at “100% recycled polyester.” Take a competent, well-paid IT consultant building the DPP infrastructure. They will collect the GRS Transaction Certificate from the supplier. They will hash it, attach it to the credential, sign it with a qSeal. The DPP will pass formal compliance. The wallet will say ✅ Verified.
Now ask the question the IT consultant has never been trained to ask: does the certificate cover the garments?
A GRS Transaction Certificate certifies, say, 10,000 kg of recycled polyester delivered to a specific buyer for a specific period. It does not certify garments. The bridge from kilograms to garments is mass balance — a calculation that requires inputs which do not exist in the certificate, do not exist in the brand’s ERP, and are distributed across multiple Tier 2–4 operations the brand does not directly control. Knowing the calculation exists is the first competence gap. Knowing how to close it is the second.
The IT consultant does not know to ask. The textile manager who could close the gap is in another department, possibly in another company, often in another country. So the brand declares 10,000 units recycled, the certificate in real terms covers fewer, and the gap is silently absorbed into the DPP. Eighteen months later, customs inspection in Rotterdam finds the discrepancy. The DPP is technically signed. The claim is technically false. The brand — under ESPR Article 9 — carries the legal liability.
This is not a hypothetical. I have reviewed the technical output of seven providers operating in this market. Not one performs mass balance reconciliation at the unit level. None.
What the textile expert does not see
Reverse the situation. A textile expert understands GRS perfectly. Chain of custody, certification bodies, audit cycles, claim wording — all flawless. They are asked to design the DPP layer. They produce a PDF. They produce a URL. They produce a QR code linking to a brand-controlled landing page with a nicely formatted ingredient list.
The credential fails wallet verification. There is no DID. There is no qSeal. There is no OID4VCI-compliant issuance flow. The brand is not registered as a service provider under Article 5. When market surveillance authorities issue their first targeted query in 2027 — under the standardised access architecture the regulation requires — there is no public endpoint to call. The textile expert was right about everything textile, and wrong about everything that makes a passport a passport in legal terms.
ESPR is not a labelling regulation. ESPR is an enforcement framework. The cryptographic and registry infrastructure underneath it is not decoration. A DPP without it is a website with a green stamp.
Why the big providers are not solving this
The honest answer is uncomfortable for buyers. The large software vendors and consultancies pricing fashion DPP projects at six- and seven-figure budgets are not pricing complexity. They are pricing the absence of the right people— and compensating with team size and timeline. Assemble a team of competent IT consultants and have them build a DPP without textile-supply-chain literacy, and the output is an expensive shell that compiles. Reverse the staffing and the output is a beautifully argued textile claim that no wallet will verify.
The structural failure has four predictable failure points. Tier 4 visibility — where the chain breaks down because no one has integrated dyer and finisher data into the brand’s view. Mass balance methodology — which is not “kg in equals kg out,” and which the typical DPP project scope does not even recognise as a required deliverable. ERP integration — which requires knowing what fields the textile MES actually populates and what they mean. Cryptographic culture — which requires building issuer infrastructure with key management, not buying a SaaS subscription.
A brand cannot self-implement this. A pure software house cannot implement this. A pure textile consultancy cannot implement this. The intersection is what is missing — and the market price reflects the cost of pretending it is present.
What a real fashion DPP looks like
A real fashion DPP is signed by an issuer registered under Article 5 of the EU DPP Registry Common Implementing Regulation, with eIDAS-2 qSeal credentials, dual-signed Ed25519 and ES256, with verificationMethod entries aligned across DID document and JWKS, returning ✅ Verified inside a third-party wallet the brand does not control.
Underneath that signature, a real DPP is the output of a mass balance engine that reconciles certified inputs against declared garments at the unit level. When 10,000 kg of GRS-certified recycled polyester reconciles to coverage for fewer garments than declared, the gap is surfaced before issuance. The brand sees the discrepancy. The brand decides — re-classify, restate, reconcile upstream — and the decision is signed, timestamped, and auditable. What the brand cannot do is pretend the gap was not there.
This is not the LinkedIn version of a DPP. This is the regulatory version.
What happens next
The battery industry will have a working passport in February 2027 because the problem was tractable and the people existed. The fashion industry will not — not because the regulation is softer, but because the problem is harder and the people are missing.
Eighteen months from now, when the first inspections arrive, the difference between the two versions of fashion DPP will be a legal one. Brands will not be sanctioned for what their vendor told them. They will be sanctioned for what they signed.
The math does not close on its own. Someone has to close it.
Stefano Cipriani is founder of Reeco®, Expert Member of CIRPASS-2 (EWG1, EWG3), and a JRC Registered Stakeholder. He brings 30 years of textile supply chain experience and holds patent CN113529235 on sustainable hemp fibre processing.