New metrics: durability, repairability, recycled content.
Microplastic release module
Stricter data requirements (primary BOM data, supplier details)
What does this mean for fashion brands? Brands are now expected to measure the environmental impact of each product across its entire life cycle: from raw material extraction and production to transport, use phase, and end-of-life.
According to PEFCR v3.1, brands must calculate impact based on factors such as:
Climate impact (CO₂ equivalents)
Water use, land use, and fossil resource depletion
Toxicity, acidification, and particulate matter
Microplastic release
Intrinsic durability, repairability, and lifespan
All materials—like cotton, polyester, and viscose—are treated equally. There’s no room for unsubstantiated sustainability claims.
How does this link to the Digital Product Passport (DPP) The Digital Product Passport will not just be a compliance tool but also a transparency and brand differentiation tool, linking impact data to consumer trust, repair services, and resale.
The outcomes of your PEF study will feed directly into the mandatory Digital Product Passport, part of the upcoming Eco design for Sustainable Products Regulation (ESPR).
What must the DPP include?
A unique QR code or digital ID per product
Data on material composition, origin, and impact figures (e.g. CO₂, water use)
Usage tips, repair instructions, and end-of-life options
Information on chemical substances (if applicable)
Any sustainability claims or certifications, supported by verified data
The DPP must be accessible to consumers, authorities, and supply chain actors.
What can your brand do now? 1. Start mapping your data: Across materials, processes, suppliers, and product lifespans. 2. Explore multiple DPP providers: Compare offerings, prices, integration, and usability 3. Align impact data with your CSRD strategy and upcoming Green Claims Directive. 4. Prepare for eco-modulated EPR fees: products designed for durability and recyclability will pay less once EU-wide textile EPR is fully in place (France has this in place).
Need help? At RethinkRebels and The Circle Club, we've already guided brands in implementing these frameworks, from circularly designed jackets and bags to upcycling collaborations within The Circle Club. Furthermore, we support brands with:
Building PEF-compliant impact data
Collaborating with DPP providers and making informed choices
Integrating everything into your CSRD strategy, Green Claims-proof storytelling, and due diligence systems
We don’t build DPP tools, but we help you ask the right questions, navigate tools, and choose a solution that fits your brand’s goals and resources.
Curious to learn more or ready to get started? Email rachel@rethinkrebels.com for a free intake.