Time to submit your thoughts on 𝗗𝗶𝗴𝗶𝘁𝗮𝗹 𝗣𝗿𝗼𝗱𝘂𝗰𝘁 𝗣𝗮𝘀𝘀𝗽𝗼𝗿𝘁𝘀 𝗳𝗼𝗿 𝘁𝗵𝗲 𝘁𝗲𝘅𝘁𝗶𝗹𝗲 𝗮𝗻𝗱 𝗳𝗮𝘀𝗵𝗶𝗼𝗻 𝗶𝗻𝗱𝘂𝘀𝘁𝗿𝘆! 𝘛𝘢𝘬𝘦 𝘵𝘩𝘦 𝘴𝘶𝘳𝘷𝘦𝘺 (𝘦𝘹𝘵𝘦𝘯𝘥𝘦𝘥 𝘵𝘰 𝘑𝘶𝘭𝘺 10) 🔗 https://lnkd.in/dNQbihMN

CARE ID has submitted our response to the European Commission's public consultation on Ecodesign Textile DPP Requirements, validating 𝑡ℎ𝑒 𝐽𝑅𝐶 𝑆𝑐𝑖𝑒𝑛𝑐𝑒 𝑓𝑜𝑟 𝑃𝑜𝑙𝑖𝑐𝑦 𝑅𝑒𝑝𝑜𝑟𝑡, 𝑆𝑡𝑢𝑑𝑦 𝑜𝑛 𝐷𝑃𝑃 𝑐𝑜𝑛𝑡𝑒𝑛𝑡 𝑓𝑜𝑟 𝑡𝑒𝑥𝑡𝑖𝑙𝑒 𝑎𝑝𝑝𝑎𝑟𝑒𝑙 𝑝𝑟𝑜𝑑𝑢𝑐𝑡𝑠 𝑢𝑛𝑑𝑒𝑟 𝐸𝑆𝑃𝑅.

We went through the full report and responded as a non-EU DPPSP building Digital Product Passport infrastructure for the textile and fashion industry, with a particular focus on Korea and the wider Asian supply chain.

𝗔 𝗳𝗲𝘄 𝘁𝗵𝗶𝗻𝗴𝘀 𝘄𝗲 𝗖𝗔𝗥𝗘 𝗮𝗯𝗼𝘂𝘁 𝗺𝗼𝘀𝘁:

→ 𝗧𝗵𝗲 𝘁𝗲𝘅𝘁𝗶𝗹𝗲 𝘃𝗮𝗹𝘂𝗲 𝗰𝗵𝗮𝗶𝗻 𝗶𝘀 𝘀𝘁𝗿𝘂𝗰𝘁𝘂𝗿𝗮𝗹𝗹𝘆 𝗱𝗶𝗳𝗳𝗲𝗿𝗲𝗻𝘁. As the report itself notes, 80% of garments circulating in the EU are imported, made across thousands of SMEs and micro-factories outside the EU. The brand that places a product on the market and the factory that physically makes it are usually separate entities, often in different countries. The framework needs to reflect this in its terminology, its data requirements, and above all in accessibility for the non-EU supply chains that actually make the clothes.

→ 𝗜𝗱𝗲𝗻𝘁𝗶𝗳𝗶𝗲𝗿 𝗰𝗵𝗼𝗶𝗰𝗲 𝘀𝗵𝗼𝘂𝗹𝗱 𝘀𝘁𝗮𝘆 𝗴𝗲𝗻𝘂𝗶𝗻𝗲𝗹𝘆 𝗼𝗽𝗲𝗻. The framework allows GS1 "or equivalent," and that flexibility needs to be real in practice, not just on paper. We operate prEN18219-aligned identifier infrastructure, the standard the Commission tasked CEN/CENELEC JTC 24 with developing, which lets us issue compliant product, batch, and model identifiers directly to brands, so that identifier costs don't become a barrier for the SMEs that make up 99% of the textile economy.

→ 𝗚𝗿𝗮𝗻𝘂𝗹𝗮𝗿𝗶𝘁𝘆 𝘀𝗵𝗼𝘂𝗹𝗱 𝗯𝗲 𝗯𝘂𝗶𝗹𝘁 𝗳𝗼𝗿 𝗮𝗰𝗰𝘂𝗿𝗮𝗰𝘆. To a recycler, "100% cotton" isn't one thing: dye chemistry, finishing, and contamination all shape whether it can actually be recycled, and a model-level average smooths that variation away. We argued for batch-level as the structural baseline for environmental data, which also avoids costly re-work if the Delegated Act later calls for that accuracy.

This consultation directly shapes the upcoming Delegated Act. If you're a brand, manufacturer, recycler, or anyone touched by textile DPP, your input genuinely matters — and the people writing these rules want to hear from the industry.