Preparing for the Digital Product Passport: CISUTAC’s Open Data Guide
Europe, with its ambitious sustainability agenda, faces both an urgent challenge and a unique opportunity: transforming post-consumer textile waste into valuable secondary raw materials. Achieving this, however, is not simply about scaling up recycling infrastructure, it requires a fundamental shift in how data is shared, accessed, and managed across the textile value chain. Transparent, harmonised, and accessible product data will determine whether circularity in the sector remains an aspiration or becomes a reality.
In summer 2025, CISUTAC released a comprehensive report, developed by partners RISE and GTS, titled “Open Data Guide” (Deliverable 2.2) that addresses precisely this challenge. The guide explores how the textile industry can overcome the critical bottleneck of insufficient data accessibility, laying out practical steps for brands, recyclers, and other stakeholders in the value chain to prepare for the forthcoming Digital Product Passport (DPP) under the Ecodesign for Sustainable Products Regulation (ESPR). By defining minimum data requirements, highlighting harmonisation needs, and providing actionable advice, the Open Data Guide serves as both a roadmap for compliance and a catalyst for unlocking new circular business opportunities.
Data Requirements for Circularity
Data mangement challeges faced by companies
Many companies still handle much of their data manually in spreadsheets, with low IT integration slowing digitalisation and circularity efforts.
Only a few have mature systems tracking product data across their full supply chain.
Most rely on statistical averages and focus mainly on the primary fabric, not full product content.
Terminology and categorisation remain inconsistent across companies.
Few can extract detailed material data, which is essential for fibre-to-fibre recycling.
The Digital Product Passport is a central element of the Ecodesign for Sustainable Products Regulation. Its purpose is to increase transparency across product value chains by providing comprehensive, standardised data on each product. This includes information about origin, material composition, environmental footprint, and recommendations for end-of-life management. All data must be accessible via a physical carrier linked to a unique product identifier, must be structured and machine-readable, and must be interoperable across systems. Unlike the ESPR, which sets performance requirements, the DPP defines what must be known and shared.
In this context, data becomes the critical enabler for turning waste into a resource. If accessible across the value chain, data can support the development of circular design, enable second-hand markets, repair services, and scalable recycling, and guide producers to anticipate the fate of their products through Extended Producer Responsibility schemes. Beyond regulatory compliance, improved access to relevant product data unlocks broader opportunities for innovation and new business models.
CISUTAC’s Decision Support Tool
A crucial part of CISUTAC’s work has been to identify exactly which data points are needed to enable circular practices. The project’s Decision Support Tool highlights 17 specific data points that could significantly accelerate the transformation of post-consumer textile waste into reuse, repair, and recycling markets. Among these, condition level stands out as the most decisive parameter.
One key piece of data needed to establish a circular business model is a product’s condition (whether it can be reused, needs repair, or should be recycled). However, this will not be part of future legal requirements, since such information only becomes available once a product has been placed on the market. Yet, there is no unified international grading system for second-hand clothing today. To advance the discussion on a standardised definition, CISUTAC has proposed five condition levels that follow the waste hierarchy:
Premium items are essentially like new and can be reused directly,
High-condition garments show only light wear such as minor pilling.
Medium-level products require small repairs,
Low-condition textiles are better suited for recycling,
and Very low-condition items, heavily contaminated or damaged, may only be destined for incineration, though thermomechanical or chemical recycling should be preferred in the future.
These definitions are a first step toward more transparent and standardised condition reporting, which could make sorting and export processes more accountable and efficient.
Testing in practice
Visualisation of the Interface developed by CISUTAC partner STAM in the CISUTAC sorting pilot
The importance of condition becomes particularly clear in practice. Texaid is leading CISUTAC’s semi-automated sorting pilot combined AI, near-infrared scanning, and RFID tagging to test how data can support sorting operations. By feeding key data points into a decision support interface, the pilot guided operators with real-time visual prompts, helping them direct textiles more accurately to reuse, repair, or recycling pathways. This experiment demonstrated how condition data, when captured and made accessible, can directly improve efficiency and recovery rates.
A central insight from the pilot is that the most crucial data points for improved sorting, especially from the sorter’s perspective, are the material composition of each layer and trim. Without detailed and accurate material data, it becomes difficult to effectively separate textiles for recycling. A future challenge and opportunity lie in also including chemical content data, which could further enhance the precision and sustainability of sorting.
Overall, the clearest lesson from the pilot is that establishing a functional and scalable data flow in such a complex and diverse industry requires extensive standardisation between suppliers and technology providers. When captured and made accessible, condition and material data can directly improve efficiency and recovery rates, driving progress toward true textile circularity.
Organising Data for Reuse, Repair, and Recycling
CISUTAC’s Open Data Guide also provides practical advice on how companies can start organising their data. The first step is to build a shared vocabulary of textile terms. Standardised formats and semantically clear vocabularies reduce manual processes, improve accuracy, and ensure that data is meaningful for multiple stakeholders. The CISUTAC Decision Support Tool follows ISO 5157 vocabulary for environmental aspects of textiles. This structured approach ensures compatibility while leaving room to capture details that matter for reuse, repair, and recycling.
Apolda Texaid’s sorting facility, showing the emptying of a container and the random storage of feedstock waiting for further processing.
Equally important is establishing a clear structure for data collection and use. Companies need to decide early what information to save, who will use it, and which roles will be responsible. Prioritisation is key: some data points (such as fibre composition, chemical content, colour, and brand) are particularly relevant for circularity. Once priorities are clear, data collection can be scaled systematically, supported by IT systems that are able to handle higher volumes and ensure traceability.
Another consideration is the choice of data carriers. Different technologies can be used to link physical products to their digital records. RFID offers scalability and speed, particularly for industrial sorting, while QR codes provide consumer-friendly access to product information. However, Digital Product Passport (DPP) implementation must remain flexible to meet evolving industry needs and adapt to new technologies.
CISUTAC’s work shows that QR codes are currently unsuitable for high-speed sorting due to technical limitations, whereas RFID tags (especially UHF Gen 2) show strong potential as adoption in apparel increases. Still, achieving this will require greater standardisation and industry alignment. A hybrid model, using QR codes for consumer engagement and RFID for automated sorting, could offer the most effective solution if integrated from the design stage. This approach still needs testing, and further development of RFID and other data carriers is expected. One initiative that will explore this further is Trace4Value/SwePass.
CISUTAC’s practical checklist
By 2027 , the European Commission will finalise the delegated acts that define the performance and information requirements for both ESPR and the Digital Product Passport. Companies cannot afford to wait until then. CISUTAC’s Open Data Guide includes a practical checklist that helps organisations take their first steps.
The checklist encourages companies to begin by assessing their starting point: mapping what product and material data they already hold, often in simple formats like Excel. From there, businesses can set priorities, for example by focusing on their top ten materials by volume. Building knowledge of circularity data is the next step. CISUTAC has identified 17 key data points (ranging from condition, repairability, and recycled content to fibre composition, durability, and chemical content) that can accelerate reuse, repair, and fibre-to-fibre recycling. Companies are encouraged to test their existing data against these requirements to identify gaps.
Organising and structuring data is equally important. Aligning terminology with ISO standards, grouping data by circular relevance, and defining access and roles across the value chain all help ensure consistency and interoperability. At the same time, design and material choices should be revisited. Limiting fibre blends, reducing elastane, and documenting chemical finishes are concrete steps that make recycling more viable.
Finally, companies must prepare their digital capacity and supply chain collaboration. This means ensuring IT systems can handle new data demands, engaging suppliers in data management, and testing technologies such as RFID or QR codes. Internal training and cross-functional teams can accelerate progress. Crucially, action should begin now. Pilot projects, even on a small scale, build knowledge and reveal challenges before regulation makes compliance mandatory.
The transition to a circular textile economy cannot be achieved without a strong data foundation. The Open Data Guide provides the industry with a critical first step, helping stakeholders identify relevant data, build the capabilities to collect and share it, and establish robust systems for data verification and exchange.
In essence, the report serves as a practical tool to help the industry prepare for upcoming legislation. It is based on and summarises key learnings from previous work conducted within CISUTAC. It draws on insights from the Decision Support Tool, the CISUTAC pioneering semi-automatic sorting pilot (WP4), and the development of the Global Textile Scheme (GTS) in Task 2.
