With 80% of environmental impact determined at the design stage, fashion creators must embed circular principles now to meet 2029 European regulations.
The upstream responsibility
The digital product passport (DPP), a digital twin linked to physical textile products, will become mandatory for the European market from mid-2029. While much discussion has centered on data compliance and technical infrastructure, the design stage determines the majority of what gets measured. Narendra Makwana, co-founder and CEO of SaaS platform GreenStitch, and Emma Grace Bailey, director of sustainability at global trend forecaster Future Snoops, spoke with FashionUnited about why designers sit at the heart of DPP readiness.
According to the European Commission, up to 80 percent of a product's environmental impact is decided during design. Material selection shapes this footprint, as do manufacturing choices and the resulting longevity of the finished garment. "No compliance team, technology platform or data management system can compensate for design decisions that do not live up to DPP standards," Makwana emphasises.
Material choices and hidden barriers
Designers must weigh numerous factors when selecting fabrics. Will washing release microplastics? How much water and pesticides were required for cultivation? Which dyes and chemical treatments were applied? How readily can the garment be recycled?
Synthetic fibres like polyester shed microplastics, while conventional cotton farming may employ harmful pesticides and heavy water consumption. Dyes and chemical treatments risk polluting local water sources without proper management. Textile-to-textile recycling is advancing, yet mixed-fibre fabrics—polyester-cotton blends, for instance—remain problematic.
Elastane deserves particular attention. Widely used in activewear, swimwear, shapewear and stretch denim, it resists recycling with current technology. Even small percentages render entire products difficult to repurpose. Though pending confirmation via Delegated Act, garments likely need under 15 percent elastane to qualify for recyclability consideration. "High elastane content creates significant recyclability risk and is expected to attract higher EPR fees under the DPP system," Makwana warns.
Durability through construction
Beyond material selection, processing decisions affect environmental performance. Weave density, seam strength, thread durability and reinforced construction for high-impact garments all prevent premature wear. Visible seams and included spare buttons facilitate repair. Style choices matter too—timeless designs outlast trend-driven pieces, as do classic over seasonal colours.
"This is why designers must be brought into DPP compliance at the beginning of a brand's transition, not at the end," urges Bailey. "[They] are not peripheral to DPP compliance - they are its primary determinant."
Four design options for compliance
While DPP data fields remain under development, four core performance indicators—design options (DOs)—are proposed for compliance. DO1, the robustness score, assesses physical performance after five wash cycles via standardised ISO methods including colour stability, pilling, seam integrity, fastener function, spirality and dimensional change. Designers should consider fabric construction and weight, fibre quality, seam construction and stitch density, fastener and trim quality, and accurate care labels.
DO2 measures end-of-life material recoverability through blend composition and construction scoring. Mono-material products with simple construction and recycling-compatible fibres score highest; those exceeding 15 percent elastane likely score lowest. "Recyclability is almost entirely determined by material specification decisions. Designing out elastane is key," advises Bailey, suggesting mechanical stretch via fabric construction, natural stretch fibres like wool, and bio-based elastane alternatives.
DO3 tracks recycled fibre percentage, distinguishing between open-loop recycling (down-cycling into different products) and closed-loop textile-to-textile recycling into equivalent new products. "It is likely that future requirements will limit recycled content to closed-loop only," notes Makwana, meaning designers should embed these targets into material briefs by default.
DO4 captures manufacturing-phase impact across Tiers 1–3, measuring either greenhouse gas emissions or broader environmental footprint including energy, water use and water pollution. Tier 4 will likely join from Phase 2. Average secondary data is initially permitted, though primary data will eventually be required. Makwana highlights that Tier 2 dyeing and finishing generates 36 percent of manufacturing-level greenhouse gas emissions, making low-impact processes advantageous.
Immediate action required
Brands must embed circular design principles from the creative process outset. Designers should prioritise mono-material garments or keep secondary blends below 15 percent, integrate verified recycled content into initial briefs, minimise chemical-intensive treatments like PFAS, and engineer products for disassembly through separable zippers, matching shell and lining fibres, and removable trims.
"Designers should ask at the concept stage, what recycling pathway is this product designed for? Which technology can recover this material, and is that technology accessible enough to ensure it will be recycled?" urges Bailey. "'Designed for recycling' isn't the same as 'it will actually be recycled'."
Long-term durability and meticulous data tracking prove essential. Poor performance against wear, fading or seam failure triggers higher Extended Producer Responsibility penalties. All decisions—material specifications, construction choices, chemical treatments, care instructions and supplier selections—must be formally documented in standardised digital formats. "Every material specification, construction choice, chemical treatment, care instruction and supplier decision needs to be formally documented in a way that flows into the DPP data system," recommends Makwana.
The urgency of beginning now
Makwana and Bailey have developed a designer-specific timeline to ease the transition. "Collecting verified fibre composition, chemical treatment and environmental data from Tier 2 fabric mills takes a minimum of 12-18 months and every design decision that creates a new Tier 2 supplier relationship creates a new data gap that takes over a year to close," Makwana warns. "If you wait for the Act to be finalised before taking action, you will face a structural crisis."
Six immediate actions can launch designer teams forward: scrutinise current elastane usage, update design briefs with DPP criteria as standard, employ DPP scoring systems for material and product evaluation, equip teams with DPP standards and seven circular design principles, establish cross-functional DPP design working groups, develop a DPP-compliant material library, and begin DPP data collection on three to five stock keeping units before expanding.
More information appears in Future Snoops and GreenStitch's joint report "Digital Product Passports: Designing for Future Regulation, Now," available via the Future Snoops website.