Do Digital Product Passport Requirements Apply to Small Fashion Brands?

Smaller fashion brands often assume that new European sustainability and product regulations apply only to large companies. That is true for some corporate reporting and due-diligence requirements, but it is not a general rule.

Product legislation usually applies according to the product being placed on the EU market and the role of the economic operator, rather than company revenue or employee count.

This distinction is particularly important for the Digital Product Passport. Once DPP requirements apply to a textile product category, smaller brands placing covered products on the EU market may also need to comply unless the relevant legislation provides a specific exemption.

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Company-level and product-level rules are different

EU legislation can affect small fashion companies in different ways.

Company-level requirements may depend on criteria such as revenue, number of employees, listing status or corporate structure. Sustainability reporting and corporate due-diligence legislation may therefore exclude many smaller companies from their direct scope.

Product-level requirements regulate products placed on the EU market. These rules may apply regardless of whether the company is a multinational group or an independent brand.

Smaller businesses can also be affected indirectly when larger customers, retailers, marketplaces or financial institutions request information from their value chain.

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Will small fashion brands need Digital Product Passports?

Digital Product Passport obligations are introduced progressively by product category. Company size is not, by itself, the criterion that determines whether a product requires a DPP.

For textiles and apparel, the relevant delegated act is still under development. It will establish:

• which products are covered;
• which information must be included;
• the applicable level of granularity;
• which economic operator is responsible;
• whether any exemptions apply;
• the implementation date and transition provisions.

Until that act is adopted, it is not accurate to state that every apparel brand must implement DPPs from 2027. The current expectation is that the textile delegated act will be adopted in 2027, with application following according to the final measure.

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What can remain proportionate for a smaller brand

Preparing for DPP requirements does not require a smaller company to recreate the infrastructure of a global fashion group.

The implementation can be proportionate to:

• the number of products and variants placed on the market;
• the number and complexity of suppliers;
• the systems already used to manage product information;
• the granularity required for the relevant products;
• the amount of information that changes between collections.

A smaller catalogue and a more direct supplier network can make responsibilities and data flows easier to define. The essential requirement is that the process remains reliable and scalable as collections evolve.

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Where small brands should start

A practical starting point is to:

1. identify the products sold in the EU and the company responsible for placing them on the market;
2. map product information already available in spreadsheets, e-commerce systems, ERP, PLM or supplier documents;
3. identify the suppliers responsible for materials and production data;
4. determine which information is supported by documents or other appropriate evidence;
5. assign internal responsibility for collecting, reviewing and updating the data;
6. test the process on a limited product range or collection;
7. select technology that can expand without requiring the process to be rebuilt.

The objective is to create a manageable product-data process, rather than collecting every possible sustainability metric before the applicable requirements are known.

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What small brands should avoid

Smaller fashion companies should avoid:

• assuming that SME status creates an automatic DPP exemption;
• treating 2027 as a confirmed compliance deadline for textiles;
• collecting extensive environmental data without understanding how it will be used;
• presenting voluntary information as legally required;
• making environmental claims without adequate supporting evidence;
• adopting a closed system from which product data cannot be exported;
• managing every collection through isolated spreadsheets and manual requests without defined responsibilities.

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Starting before the final requirements

The final textile dataset is still being developed, but smaller brands can already prepare the foundations that are unlikely to become obsolete: product identifiers, data ownership, supplier involvement, supporting evidence and connections with existing systems.

Starting with a limited scope can help establish a repeatable process before expanding the DPP across additional collections or product categories.

Small fashion brands may have fewer resources, but they often have shorter decision-making chains and closer relationships with suppliers. A proportionate implementation can turn these characteristics into an operational advantage.

Renoon supports fashion companies in assessing applicable requirements, structuring product and supplier data and implementing Digital Product Passports according to their catalogue, systems and internal resources.

Talk to our team about preparing a proportionate DPP implementation.