METHODOLOGY

How we measure DPP readiness

by Lior Gabriel Graetz · LG Fashion Labs

The Digital Product Passport becomes mandatory for textile products sold in the European Union between mid-2028 and early 2029, depending on the product category’s final Delegated Act adoption timeline. Before that deadline, most mid-market EU fashion brands need to answer one operational question: how much of the required data do they already have, structured correctly in their production systems, and how much is missing, inconsistent, or held only in unstructured formats like PDFs and email threads?

The LGFL DPP Readiness Audit, built on a production orchestration fashion approach, answers that question. It applies the most rigorous published DPP data protocol — the Trace4Value DPP Data Protocol v2 — to assess brand-level readiness across 125 structured data points in 9 domains, producing a granular readiness score and a remediation roadmap.

This page documents what we assess, how we assess it, and what remains uncertain as EU regulation finalizes.

Why Trace4Value

Multiple DPP frameworks have been proposed since the EU’s Ecodesign for Sustainable Products Regulation (ESPR) was adopted on 13 June 2024 [Regulation (EU) 2024/1781]. LGFL benchmarks brand readiness against Trace4Value, the framework developed under a Vinnova-funded research pilot coordinated by RISE Research Institute between 2022 and 2024.

We selected Trace4Value for four reasons:

It is the most operationally tested. The Trace4Value working group piloted the protocol on over 3,000 live garments from Kappahl (Swedish high-street retailer) and Marimekko (Finnish design brand) with QR-coded data carriers attached at the supplier production stage. This is the only published DPP protocol with documented end-to-end field deployment at scale.

It is built from industry consensus, not a single company’s roadmap. The working group included TrusTrace (the traceability platform that led the technical implementation), GS1 Sweden (global supply chain identification standards), the Swedish Institute of Standards (SIS, CEN/ISO national mirror body), Kappahl, Marimekko, GANNI, and Textile Exchange. Consensus across retailers, standards bodies, and platform vendors matters because it reduces the risk of methodology bias toward any single technology stack.

It aligns with the ESPR data architecture. The protocol was designed in anticipation of the Delegated Acts for textiles under ESPR. Its 9 domains map directly to the information categories that ESPR Article 7 requires DPPs to cover, including product identification, material composition, substance compliance, supply chain operators, and circularity performance.

It is free and open-source. The Trace4Value DPP Data Protocol is published openly, updated in April 2024 to reflect two years of pilot learnings. Auditing against a proprietary methodology would create vendor lock-in for the brands we assess. Auditing against an open protocol does not.

Every Trace4Value DPP audit follows this open protocol. The primary source document — Trace4Value Digital Product Passport in Textile — Data Protocol — is available at trace4value.se. The v2 update is documented in the TrusTrace DPP knowledge base.

The 9 data domains

The Trace4Value protocol groups 125 data fields into 9 thematic domains, each assigned a numerical Info Group code. The audit evaluates every domain. Below is what each covers, the typical gap pattern we expect to observe in mid-market EU fashion brands, and why each matters for final DPP compliance.

How we score

Each of the 125 data fields is assessed against three states:

Ready. The field is populated, structured in a machine-readable format (typically in a PLM, ERP, or traceability platform), and verifiable against a source of truth. For material composition, this means component-level percentages with documentary evidence. For supply chain, this means per-stage country of origin with supplier records.

Partial. The field is populated but either held in unstructured formats (PDF, email, image), populated inconsistently across product lines, or structured but lacking verification evidence. Example: a brand that records material composition in structured form but does not maintain documentation of the recycled percentage claim.

Gap. The field is absent entirely, or exists only as marketing claim without underlying data. Example: “95% sustainable materials” on a website with no per-product documentation.

The readiness score is computed as the percentage of the 125 fields scored Ready, weighted equally across domains. We publish the score as an overall readiness percentage and as a per-domain breakdown, because aggregate scores mask the fact that a brand may be 90% ready on product information and 10% ready on circularity — a distribution that will shape remediation priorities.

We do not weight domains differentially at this stage, for one reason: the Delegated Acts have not yet specified which data points are mandatory versus optional. Equal weighting assumes the worst case — that all 125 fields become mandatory — and produces a conservative readiness benchmark. When the Delegated Acts for textiles are published (expected early 2027, per the ESPR 2025–2030 Work Plan), we will update the weighting model to match the mandatory-field list.

How this maps to ESPR

The ESPR (Regulation (EU) 2024/1781) establishes the framework for DPPs. The specific data requirements for textiles will be defined in a Delegated Act adopted by the European Commission, expected in early 2027, followed by a minimum 18-month transition period. Compliance is therefore expected between mid-2028 and early 2029 for textile products sold in the EU market.

In parallel, the CEN CENELEC DPP standards textiles initiative is developing eight harmonized standards for DPPs under European Commission Mandate M/604, due 31 March 2026. These standards will define technical requirements for data carriers (prEN 18220), identifiers (prEN 18219), data access governance, data authentication, and interoperability between systems. Once published in the Official Journal of the EU, they will carry legal weight as harmonized standards, offering a presumption of conformity under ESPR.

The Trace4Value protocol was designed to align with ESPR Article 7 information requirements and with emerging CEN/CENELEC technical standards. When the Delegated Acts and harmonized standards are finalized, the protocol will be updated — and so will the LGFL audit methodology.

What remains uncertain

Three things are not yet knowable:

The exact list of mandatory fields. The Delegated Acts for textiles will determine which of the 125 Trace4Value data points are mandatory, which are conditional, and which are optional. Our assumption — validated by the TrusTrace working group’s published position — is that the Trace4Value protocol represents a close approximation of the final mandatory set, with likely adjustments in the sustainability and circularity domains where methodology standards are still being defined.

The granularity requirement. ESPR defines three granularity levels for DPPs: model, batch, and item. The Delegated Acts will specify which granularity is required for textile products. Item-level granularity would require per-garment unique identifiers; model-level would require only per-SKU identifiers. The implementation cost difference is significant.

The role of CEN/CENELEC standards vs. industry protocols. Once the harmonized standards are published (late 2026 expected), the Trace4Value protocol may need updates to maintain full ESPR conformity. We monitor both streams and will issue audit updates when either materially changes.

Where the audit result depends on a regulatory assumption that is not yet settled, we flag it explicitly in the report rather than treating it as certain.

The 5-day audit process

The audit runs over five working days from the point of engagement:

Day 1 — Scope and access. We confirm the collection to be audited (one sample collection, typically 10–20 styles), establish access to the brand’s PLM/ERP system or equivalent, and collect supplier contact information for the top three to five suppliers by volume.

Day 2–3 — Field assessment. We evaluate each of the 125 fields against the Ready / Partial / Gap scoring logic, pulling evidence from the brand’s systems, supplier documentation, and where needed, direct supplier communication.

Day 4 — Analysis and remediation mapping. We compile the per-domain readiness breakdown, identify the highest-impact remediation paths, and estimate effort per remediation by domain (internal data structuring vs. supplier-side capability building vs. third-party verification).

Day 5 — Deliverable and walkthrough. We deliver the audit report and walk the brand team through findings in a 60-minute review call.

The audit is performed against a single sample collection. Extrapolating readiness to a full seasonal catalog requires additional engagement.

What the deliverable looks like

Every audit produces four deliverables:

A readiness score — one aggregate percentage and 9 per-domain percentages.

A detailed field-level report — all 125 fields with Ready / Partial / Gap classification and supporting evidence.

A remediation roadmap — prioritized gap list with estimated effort and recommended sequence, distinguishing internal work from supplier-side coordination.

A regulatory assumptions log — which audit findings depend on Delegated Act assumptions that are not yet final, so the brand can reassess when the regulation publishes.

Reports are delivered in PDF and structured data (JSON) formats. Brands retain ownership of their audit data.

Next steps

The methodology is public. The audit is free during Phase 0. For brands evaluating top DPP providers fashion 2026, transparency of scoring methodology is a key differentiator.