Digital Product Passports for Small Fashion Brands

In November, I attended a working breakfast in the MEP Salon of the European Parliament, hosted by Maria Grapini MEP and organised by SME Connect: Making Digital Product Passports Work for Small Businesses. Alongside DG GROW, Oxera, Amazon and designer Valérie Berckmans, I spoke on behalf of roughly 1,000 micro SMEs on the COSH! platform in Belgium, the Netherlands and Germany. Here is what I said, and why it matters if you invest in or partner with fashion tech.

Transparency is not new to me. Around 2010 – 2012, I was a business developer for Honest By, Bruno Pieters’ brand and the first luxury fashion house to disclose its suppliers, the prices it paid and the hours each step of the textile and garment production took. The goal was simple: help people revalue the hands behind their clothes and prove the sustainability claims we were making. Digital Product Passports (DPPs), a digital ID card for each product under the EU’s Ecodesign for Sustainable Products Regulation (ESPR), could scale that idea. Whether they will depends on design choices being made right now.

A saturated DPP market built on the wrong maths

I see the DPP market from two sides: as a technology provider and as a platform for small brands. Somewhere between 500 and 1,000 DPP providers are chasing this market, each promising their potential investors they’ll be the number one. Millions in grants and venture funding have already gone into pilots, and many of those projects will not survive the ongoing delays to the delegated acts.

Most providers calculated themselves rich. They assumed a huge fashion market and a big slice of it. Then pilots revealed a minimum setup cost of around €7,000 per brand, and several providers now serve only companies above €2 million in turnover. Large brands have already secured their passports. Medium-sized and small companies are stalling on cost and regulatory uncertainty, hoping the investment and the burden of the work will go away.

Why €600 a month doesn’t fit a craftsman

Outsiders assume €600 per month is a normal software price. Now look at who actually makes clothes in Europe’s small-business segment. A craftsman produces 5 to 20 items a month. A one- or two-person label runs 100 to 3,000 pieces. Spread €6,000 – 7,000 of software over that volume, and you add around €10 per passport, more than a complete garment costs on Shein. For everyday apparel, that is simply uncompetitive. And that’s just for its digital layer. One still has to pre-invest in physical QR-code labels and workload, because buying the software isn’t the only bottleneck. Many small brands have no ERP or stock system; some don’t even work in spreadsheets. They don’t need an IT expert explaining a dashboard. They need someone who knows the supply chain and tells them what to change and where.

55633715478 ffaffdde77 h — Niki de Schryver discussing DPPs for SMEs at the working breakfast in the MEP Salon of the European Parliament

Where DPPs already work

This is where COSH! comes in. We built a fashion and textiles DPP system for small makers, with preset sections so textile, fashion and accessory brands can ease in step by step. Through a group purchase, we now offer passports from € 29 to € 129 per month, depending on your production volume. Twenty early adopters have started, and they are eager to show how they work differently.

The pattern is clear: makers of limited editions and handmade pieces, often selling at €500 or more, see full transparency as a competitive advantage.

Three warnings to legislators, though.

First, our team of four trained industry professionals does the hand-holding, and that workload is not yet covered by what small brands can pay. If EU deadlines keep slipping or adoption is postponed, DPP providers currently need alternative revenue streams so multifunctional teams can stay aboard; otherwise, small brands will be left with only the big providers, often without industry knowledge.

Secondly, if DPPs drop traceability requirements, the main advantage for micro SMEs disappears.

Thirdly, the EmpCo Regulation is closely connected to DPPs. Micro SMEs that invest in premium organic fabrics are no longer allowed to state that they use organic material. So why invest in premium materials if they can’t claim this?

Three proposals I put on the table

Let small producers show fabric certificates in their DPPs. Brands making fewer than 10,000 garments pay premium prices for GOTS-certified fabric, yet under the EU’s Empowering Consumers Directive (EmpCo), they can’t communicate it on the final product. They are also too small to get chemical data from fabric suppliers. Let them list traceable fabric certificates on the DPP at the fabric level.
Exempt post-consumer upcycling from full composition data requirements. Small-scale upcycling designers making one-offs often cannot know the exact blend or chemicals in the textiles they rescue. For pre-consumer deadstock, responsibility should sit with textile manufacturers, for example through a DPP on the fabric roll itself.
Rethink durability in the PEFCR. The Product Environmental Footprint Category Rules rely on fabric durability tests that don’t translate to finished-garment resilience. How a brand communicates (and how marketing pushes for sales one doesn’t need) also shapes how often people actually wear their clothes. Make durability factors and statements come from real-life garment use, not forecasted estimates. Considering forecasted sustainability estimations are also not allowed by EmpCo. COSH! holds real-life wear data across 7,500 brands that could inform a better framework.