Under the EU’s Ecodesign for Sustainable Products Regulation (ESPR), the forthcoming Digital Product Passport will require garment manufacturers to provide reliable, product-level information on materials, production processes and environmental impacts. This study examines how prepared manufacturers supplying the European market are to meet these requirements. 

The research combines a survey of garment manufacturers in Pakistan, Bangladesh and Turkey with a case study of an upcycled T-shirt produced for the Estonian national team’s Paris 2024 Olympic uniform. Made from cotton fabric leftovers, the T-shirt was compared with an equivalent garment made from virgin cotton. 

The findings show that many manufacturers still face significant gaps in supply-chain data, traceability, digital systems, and life-cycle assessment expertise. Key challenges include incomplete or inconsistent information from suppliers, difficulties verifying product-level data, limited access to suitable assessment tools and insufficient internal capacity to collect, manage and report environmental information across international supply chains.  

At the same time, the case study demonstrates the environmental potential of circular production: the upcycled T-shirt had 91–100% lower impacts than the conventional cotton T-shirt across the assessed categories. 

The study concludes that phased implementation, clearer methodological guidance, harmonised data standards, and stronger technical and financial support will be essential for making Digital Product Passport workable across global textile supply chains. Without this support, there is a risk that the new requirements will place a disproportionate burden on manufacturers, particularly those operating outside the EU, rather than advancing transparency and circularity.