Guides

The Digital Product Passport

Challenges, Risks, and Opportunities for Businesses: A Translation Perspective

With the entry into force of Regulation (EU) 2024/1781, known as the ESPR (Ecodesign for Sustainable Products Regulation), the European Union has introduced a tool set to fundamentally reshape the fashion and textile industry: the Digital Product Passport (DPP). In practical terms, this is a digital record associated with each product, accessible via QR code, NFC, or RFID, which collects and makes available verified information on material composition, supply chain origin, environmental impact, repair instructions, and end-of-life disposal recommendations. It is a binding regulatory requirement for any business wanting to sell products on the EU market, regardless of where the producing company is based. The objective is to make environmental and social traceability mandatory for every product entering the EU market. For the entire fashion sector, this means rethinking the way products are designed, manufactured, and communicated.

One aspect rarely addressed in discussions around the DPP concerns its linguistic complexity. As a tool designed to be accessible to consumers, authorities, and supply chain operators across all EU member states (and more broadly across the European Economic Area) the digital passport goes well beyond a technical or regulatory matter: it is also a document that must function in multiple languages, with terminological precision and consistency across versions. In the field of specialised translation for the textile sector and Made in Italy, the DPP represents a new and complex territory, with regulated terminology and continuous updates. It is precisely from this perspective that it is worth examining and analysing the translation challenges it presents, the advantages for businesses that invest in professional translation services, and the potential risks for those who underestimate the linguistic quality of their digital passport.

Translation Challenges

Technical and supply chain terminology

The DPP presents data from very different fields: the chemical composition of treatments used in textile production, details regarding fibre composition, environmental certifications, European regulatory requirements, etc. Every term carries a precise meaning, and an approximate translation can turn a technically correct piece of information into a non-compliant declaration. The linguistic challenge lies in building and maintaining consistent terminology across all target languages, ensuring that the same concept is expressed uniformly in every version of the passport.

A data structure, not just linear text

Unlike a manual or a traditional product datasheet, the DPP is a structured data system with values designed to be read by databases and IT systems. The translator does not work on a text with a narrative thread, but on isolated segments of information, often stripped of context. This requires skills that go beyond linguistic proficiency: an understanding of how the data works, where it is entered, and how it is used.

Dynamic data and continuous updates

The DPP is a living document. Unlike a traditional translation intended for print or publication, the digital passport must be updated whenever something changes in the supply chain — whether that is a supplier, a certification, or a material composition. This means moving away from the logic of a one-off project and adopting one of ongoing terminological maintenance.

Linguistic accessibility: a regulatory requirement

Regulation (EU) 2024/1781 explicitly states that the information contained in the DPP must be provided in a language that is easily understandable for consumers, as determined by each member state in whose market the product is sold. For a textile company selling across multiple European countries, this translates into the need to manage multiple language versions that are mutually consistent and compliant with the regulatory terminology of each market.

Advantages for Businesses That Invest in Professional Translation

Legal compliance

Regulation (EU) 2024/1781 requires that DPP information be comprehensible in the target markets. An inaccurate translation, or one produced by automated tools without specialist review, exposes the business to a very real risk of non-compliance. Working with a translator who specialises in the textile sector means having the assurance that every field in the passport meets the regulatory terminology of the relevant country, reducing the risk of challenge by supervisory authorities.

Consumer trust

The DPP was created with a specific purpose: to enable consumers to make informed decisions. A digital passport drafted clearly, accurately, and in the language of the target market is a deliberate act of communication. For Made in Italy companies that build their positioning on quality, craftsmanship, and supply chain transparency, professional translation is exactly how those values reach the French, German, or Dutch consumer who scans the QR code on a garment — intact and as intended.

Competitive advantage for early movers

The specific rules for the textile sector are expected by 2027–2028, but businesses that begin building glossaries, processes, and terminological resources today will find themselves at a considerable advantage over those who wait for the rules to take effect. In a market where transparency is becoming a condition of entry, those who arrive with an already-translated DPP are positioned as reliable partners in the eyes of European buyers, distributors, and consumers.

The Risks of Poor Translation

Unofficial terminology: leather and vegan leather

In Italy, the term pelle (leather) is reserved by law exclusively for materials of animal origin. Legislative Decree No. 68 of 9 June 2020 (Article 3, paragraph 1) explicitly states that products sold using the terms cuoio or pelle, in any language, are prohibited when the materials in question do not meet the corresponding definitions set out in Article 2, paragraph 1. This article defines cuoio and pelle as general terms for the hide or skin of an animal that has retained its original fibrous structure more or less intact and is tanned to avoid putrefaction.
As a result, terms such as pelle sintetica (synthetic leather), ecopelle (vegan leather), or similpelle (faux leather) can no longer legally be used for materials that are not of animal origin. This also includes polyurethane, which does not satisfy any part of this definition. Therefore, describing a synthetic fabric used to make an accessory as ecopelle is a sanctionable breach of the law.

For further information, I recommend consulting the pages of the Italian Ministry of Enterprises and Made in Italy and the full text of the Legislative Decree. [last accessed: 10/04/2026]

In the context of DPP translation, this distinction is fundamental. Anyone who uses or translates the name of a synthetic material using an equivalent containing the word leather risks producing a document that is non-compliant with the regulation, turning what appears to be a minor terminological error into a concrete legal issue.

Classifications that are not valid in the destination country

The risk is increased when the product is made from exotic skins such as crocodile, alligator, or caiman: three species that are often conflated in commercial usage, but differ in value, characteristics, and regulatory status. Every product made from genuine alligator or crocodile skin sold across borders must be accompanied by a Convention on International Trade in Endangered Species (CITES) authorisation of Wild Fauna and Flora, transposed into EU law by Council Regulation (EC) No 338/97. The certificate specifies the scientific name of the species, the country of origin, the quantity, and the licence number.
In the DPP of a product made from exotic leather, the material designation must be consistent with that shown in the accompanying CITES certificate. Generically stating “crocodile leather” when the species is caiman (Caiman crocodilus) or using a common name instead of the scientific designation creates an inconsistency between the digital passport and the customs documentation, with consequences for regulatory non-compliance. For anyone translating a DPP, it is essential to ensure that the terminology corresponds exactly with what appears in the official supply chain documentation.

For further information on Italian legislation, see the page of the Italian Ministry of the Environment. To verify the regulatory status of a species and the correct scientific designation before completing the DPP, the official Species+ database is available at https://www.speciesplus.net, managed by the CITES Secretariat.

Penalties, greenwashing, and reputational damage

The consequences of poor translation also extend to economic and marketing considerations. A DPP containing linguistically or legally imprecise information exposes the business to sanctions.
On the greenwashing front, a vaguely translated environmental term can turn a neutral statement into an unsupported claim with increasingly severe repercussions in the context of the European Green Claims Regulation.
On the reputational front, the DPP is a transparency tool designed to strengthen consumer trust: an inaccurate or misleading digital passport produces precisely the opposite effect, undermining brand credibility at the very moment when transparency has become a market value in its own right.

The Digital Product Passport arrives at a time when the textile sector is being called upon to guarantee transparency. For Made in Italy companies, which have always been valued for their material quality, supply chain control, and artisanal mastery, this regulatory shift represents a tangible opportunity for valorisation. The values that, until now, have simply been entrusted to brand reputation or the label on a tag, are now visible and verifiable. Manufacturing in Italy, the choice of raw materials, the traceability of the production process, and other unique characteristics can finally be communicated in a structured way, in every language, to every European consumer who scans a QR code.

Do you work in textiles or luxury goods and need to prepare for the DPP? Get in touch to translate the materials associated with the Digital Product Passport and ensure that the value of your Made in Italy standard reaches consumers in other languages exactly as intended.