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The Digital Product Passport - Where to get started?

The fashion industry faces a regulatory challenge similar to a "Game of chicken" – who waits for specific requirements in the delegated acts? How long until action is crucial, and what are the consequences of waiting? Previously, simply noting "supplied by supplier" was enough, making traceability and transparency impossible. Brands must adapt to new standards for sourcing fabrics and trimmings to meet evolving expectations and regulations.

We had a conversation with Alexandra Morge Rochette, the Chief Sustainability Officer from Birger Christensen, to talk about this topic, and how she is preparing the company and her team.



ESPR Explained:

The European Parliament recently approved the Eco-design for Sustainable Products Regulation (ESPR), replacing the existing Eco-design Directive. This regulation aims to enhance product circularity, energy performance, and overall environmental sustainability. It introduces Digital Product Passports (DPPs) to improve supply chain information flow and expands the scope to include non-energy-related products. The ESPR will enter into force after 20 days of final adoption and publication in the Official Journal of the EU. Delegated acts will be developed to specify requirements for various products, with textiles being a potential priority. The Sustainable Textiles & Apparel Retailers and Wholesalers Interest Group is actively engaged in contributing to the Textile Delegated Act by the European Commission.

Data mapping as the starting point

Alexandra from Birger Christensen explains their first focus was prioritizing manageable tasks and data information management over documenting durability and longevity, which EU regulations haven't yet addressed. Building information starts with securing a base and gradually becoming more granular, involving internal training and supplier engagement. 

“The DPP is the last bit of the full new regulations plan. It’s the one that goes deeper at the product level. You cannot talk about the DPP without discussing the ESRS and the Due Diligence requirements as well. We are really in the midst of a whole new regulation system.”

Alexandra Morge Rochette

Alexandra highlights Birger Christensen's efforts to anticipate upcoming regulations, particularly the CSRD, driven by their partnerships with major retailers. They focus on gathering data and documentation. Transparency is key as they address inquiries about materials, country of origin, and extensive component details.

When Alexandra started at Birger Christensen, they had just onboarded Delogue, which meant that they were already working on creating new processes. A process to ensure that the correct data was stored and that it could be distributed to other platforms with an easy integration. Alexandra and her team rely on Delogue as the central source of truth for product information, maintaining up-to-date data through established tasks and processes. This ensures accurate historical records and enables effective tracing and storage of agreements made with suppliers. Once product data is validated in Delogue, they integrate it with their ERP solution and subsequently distribute it to their sales platforms.

Keeping the focus on the materials, the related data points, and risk assessment

Alexandra and her team decided on their focus with the materials they use, because in terms of carbon emissions that is where you also start to calculate your impact. Creating guidelines and training the team and the suppliers. 

“We based it on Textile Exchange’s preferred materials”, because we wanted it to be based on an external point of view”

Alexandra Morge Rochette

Birger Christensen started with fabrics because it was where they could find immediate data. They were thereby able to collect transparent information, certifications, and standards to support their choice of material in their collection. They also performed an extensive chemical testing program, as a part of their risk assessment and process descriptions to streamline their way of working:

“It was by mapping all of these risks and processing, that helped shape the ways We work internally. The big topic is processes, we cannot live without processes, when we are so reliant on the collection of data to be compliant and deliver to our customers.”

Alexandra Morge Rochette

Component data is the key to transparency - Suppliers are the key to component data

At Birger Christensen, there's a focus on comprehensive data, not just on fabrics but also on all other components that significantly impact a garment’s chemical performance. They've built a trim library to ensure suppliers can deliver without hazardous chemicals. This emphasis on safety led to consolidating suppliers to those capable of meeting standards and evolving with the company.

Their proactive approach to supplier assessment has reshaped their supply chain. Suppliers, historically focused on fabric composition, are adapting to new priorities. This shift underlines the importance of asking the right questions and, if necessary, transitioning to more aligned partners.

“All the regulations are forcing us to move to sourced fibers. “Local sourcing” is no longer an option when traceability is the key.”

Alexandra Morge Rochette

Retailer demands are pushing the agenda - revenue becomes dependent on data points

Having customers that have vast demands for documentation, data needs, and extensive information requirements is pushing the industry to be prepared. It is suddenly not just the CSR person wanting it. The requirements from retailers mean a risk of minimizing revenue. Alexandra underlines the fact that this is pushing the agenda. She states that the work is worthwhile because it becomes the entry point to some of the customers - if you want to sell to us, you need to be able to deliver the documentation. 

“I don’t think any retailers will accept newcomers, without them being data-ready. You need to be able to react fast and provide proof of the claims”

Alexandra Morge Rochette

Furthermore, she underlines that large retailers in the EU are currently obligated to report data, with the ESRS making it compulsory to publish data on a database, even though the database doesn't exist yet. This underscores the importance of not waiting for the system to be in place, but rather starting to collect data now. Building an internal system to gather and manage data is crucial to prepare for upcoming data system requirements.

The job isn’t CSR manager - it is Risk managers 

A big part of Alexandra’s job is to prove to her board of directors that she is a risk manager. She believes that the role of CSR needs to be efficient, to remove any value-driven or ethical language. “People seem to think that sustainability people are not realists - that we are dreamers.” she says, “And that we are necessary, but sometimes also a necessary pain. So I’ve always made sure that I remove any ethical elements from my language. And make it be that we are the risk assessors of the company. Because we are the only ones that are broad enough to assess what’s coming to us.” 

It is about providing the necessary overview of the coming legislation to ensure that the brand you are working for is aware of what is coming. Regulations are definitely a good motivator. It has an effect on business. If you can actually use what your core buyers are saying and have future requirements, it puts the importance of that at the top of the list. Alexandra explains that it is a bit like a marketing director. She elaborates that the job requires her to see what’s coming, what is out there and how they need to prepare for demands and potential PR risks. 

“I could probably get cheaper products if I didn’t have to have animal welfare in check. Do you want the PR risk?”

Alexandra Morge Rochette

The role of a PLM platform is crucial for preparing


Birger Christensen has always tried to limit the platforms that can do as much as possible. Alexandra elaborates that it is about finding the one source of truth, and supplementing that with others who can provide supplementary data points to ensure regulatory compliance and being able to deliver it to their customers. They are not yet focusing on the display of the Digital Product Passport, but rather to ensure the data behind it firstly, collecting all necessities and waiting on the specific legislation descriptions. 

“We want the other platforms to be supplementary to our existing so that they “only” ensure data on top of data, and not a parallel version, where data source of truth potentially exists in multiple places.”

Alexandra Morge Rochette

Alexandra points out that they need to be data-strong, collect all the information, and know where their products originate. It’s about treating the Bill of Material as the starting point for supply chain mapping and helping the workload with platforms able both for brands and suppliers.