For years, sustainability in fashion has largely been communicated as a branding and reporting exercise. Claims around recycled materials, responsible sourcing and reduced impact have become central to marketing and ESG strategies.
But as regulation tightens and expectations around transparency increase, a more uncomfortable reality is becoming clear: sustainability claims are only as strong as the data behind them.
Recent analysis highlights how widespread weak or unverified environmental claims have become across industries, with studies suggesting that only around half of brands fully deliver on their stated green commitments. Research cited by FACTA indicates that companies meet roughly 50% of their environmental pledges, underlining a significant gap between sustainability claims and actual delivery. Across the sector, multiple reviews also point to systemic transparency issues, where claims are often difficult to verify due to inconsistent or incomplete data, reinforcing growing scrutiny from regulators and the UN around greenwashing and the need for clearer, evidence-based reporting.
Greenwashing is therefore no longer just a communications risk. It is increasingly a structural issue rooted in how product information is captured, shared and verified across the supply chain.
Labelling is moving from storytelling to verification
Sustainability labelling is evolving from voluntary communication into regulated disclosure, but its credibility will increasingly depend on traceability.
The Digital Product Passport (DPP), being developed under the EU’s Ecodesign for Sustainable Products Regulation (ESPR), sits at the centre of this shift. While its exact scope is still evolving, it is widely seen as a step towards greater product-level transparency in fashion. Early indications suggest it could require extensive data capture across the value chain, with estimates pointing to 100+ data entry points.
This reflects a broader move towards more structured product information, where sustainability and compliance claims are expected to be supported by data that can be accessed and validated.
However, the effectiveness of this system depends on the quality of underlying supply chain data — and this remains a persistent challenge.
Most fashion supply chains still rely on fragmented systems, with product and supplier data spread across multiple tools, teams and formats. Visibility beyond Tier 1 remains limited for many brands, particularly upstream in processing and raw material stages. This makes it difficult to build a complete, auditable view of a product’s impact.
This is further complicated by the reliability of certifications and self-reported data, where paper-based documentation and declared volumes do not always match production realities. As a result, brands are increasingly turning to digital traceability and fibre-level tracking approaches to improve visibility and strengthen supply chain assurance.
Greenwashing is increasingly a systems issue
In this context, greenwashing is less about intent and more about infrastructure.
When data is incomplete or inconsistent, even legitimate sustainability efforts become difficult to evidence consistently across products and markets.
Sustainability, sourcing and product teams often operate in separate systems, using different metrics and processes, meaning information is frequently transferred manually rather than shared through a unified data environment. This fragmentation creates gaps between sustainability ambition and operational reality – gaps that become harder to manage as regulation increases.
The question is no longer only how sustainability is communicated, but whether it can be reliably proven at product level.
From claims to capability
The shift underway is from sustainability as narrative to sustainability as infrastructure.
The DPP is intended to link physical products to digital information at key stages of the value chain, particularly during product development and at point of sale, with additional data potentially accessible across the product lifecycle. While the framework is still evolving, it signals a move towards more consistent access to product-level information across creation, commercialization and post-purchase stages.
This changes what readiness looks like for brands. It is no longer defined by reporting outputs alone, but by the systems behind them.
Brands that begin building connected product data, improving traceability and aligning internal systems are not only preparing for regulation — they are reducing operational risk and improving decision-making across the value chain. In practice, this requires two complementary layers: a unified product development environment, typically anchored in PLM, and a connected traceability capability that links sourcing and material data back into product decisions. When integrated, these form a continuous digital thread from design through to finished product — increasingly central to how advanced fashion operations are structured.
As noted in Vogue Business, sustainability teams are already under significant data pressure, with AI increasingly being explored to consolidate fragmented information, improve data quality and support traceability across complex supply chains. This highlights that the challenge is not only about tools, but about underlying data architecture.
Conclusion: traceability is becoming the baseline
Fashion is moving into a phase where transparency is no longer optional — particularly for large brands, where regulatory pressure, investor scrutiny and consumer expectations are converging.
The Digital Product Passport is part of a wider shift towards verifiable product-level information, where sustainability claims will increasingly need to be supported by data that can be accessed, traced and validated.
In this environment, greenwashing becomes harder to sustain not because of messaging scrutiny alone, but because the underlying infrastructure is changing. As data requirements extend across the value chain, from materials to finished product, the ability to evidence claims in real time is becoming both a financial and reputational risk factor.
Put simply: if it cannot be traced, it cannot be claimed.
