Environmental footprint and material composition get most of the attention in DPP discussions. But there is another category of disclosure that the EU's newly published DPP data specification methodology treats as equally significant: substances of concern.
For fashion brands, this means that dyes, finishes, flame retardants and chemical treatments used in textile production may need to be disclosed at the product level through the Digital Product Passport. The methodology sets out exactly what kind of chemical information the DPP framework is designed to capture.
What "Substances of Concern" Means Under the ESPR
The ESPR defines "substance of concern" broadly. It includes substances identified as Substances of Very High Concern (SVHC) under REACH, those in certain hazardous classifications (carcinogenic, mutagenic, reproductive toxins and similar categories), persistent organic pollutants (POPs) and any substance that hinders reuse, refurbishment or high-quality recycling.
That last criterion is particularly relevant for textiles. A chemical finish that makes a garment difficult to recycle effectively could qualify as a substance of concern under the ESPR definition, even if it is not currently restricted under REACH.
What the DPP Will Need to Include
Article 7(5) of the ESPR empowers the Commission to require disclosure of substances of concern through delegated acts. The methodology maps out what this disclosure could look like:
Identification. The name or numerical code of the substance using IUPAC or equivalent international nomenclature. Trade names, abbreviations, EC/EINECS numbers and CAS numbers may also be required.
Location. Where in the product the substance is found. For textiles, this could mean specifying whether a flame retardant is applied to the outer fabric, the lining or the interlining.
Concentration. The concentration, maximum concentration or concentration range at the level of the product, its components or spare parts.
Safe use instructions. Relevant guidance for consumers on how to use the product safely in light of the substances it contains.
End-of-life information. Instructions for disassembly, preparation for reuse, recycling and environmentally sound disposal, specifically relating to the presence of substances of concern.
Why This Matters for Fashion Brands
Most fashion brands do not currently track chemical substances at this level of granularity across their product range. Certification schemes like OEKO-TEX Standard 100 test finished products for harmful substances, but they do not produce the structured, product-level chemical data that the DPP framework describes.
The methodology makes this distinction explicitly. It notes that certifications "provide third-party verification against defined criteria" but "do not, in most cases, provide product-level environmental performance data." A certification confirms that a standard was met. It does not produce the specific chemical identity, location and concentration data that the DPP may require.
For brands with complex supply chains spanning multiple tiers, gathering substance-of-concern data at the level of detail the ESPR describes will require supply chain engagement beyond what most currently have in place. The data sits with chemical suppliers, dye houses and finishing facilities, and collecting it in a structured format is a non-trivial operational challenge.
The Access Model for Chemical Data
The methodology's tiered access framework applies to substances of concern as well. Consumer-facing information (Tier 1) would include clear, understandable warnings about the presence of relevant substances and safe-use guidance. Recyclers (Tier 3) would receive precise chemical names, CAS numbers and location data to enable safe sorting and prevent contamination of recycling streams. Regulatory authorities (Tier 5) would have access to the full technical file including concentration levels and compliance documentation.
This tiered approach means brands do not need to publish detailed chemical formulations to consumers. But they do need to have the data available for restricted-access tiers, which means collecting it from their supply chains.
How ENVRT Approaches DPP Data
ENVRT LAB™ generates climate impact (CO₂e) and water scarcity impact at the product level, on a cradle-to-gate basis and aligned with ISO 14040 and PEFCR methodology. While substance-of-concern disclosure sits alongside environmental footprint data in the DPP framework, the structured data approach ENVRT uses for environmental assessment provides the product-level data architecture that chemical transparency will also need to sit within.
If you want to understand how your products map against emerging DPP requirements, get in touch with the ENVRT team.
