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Traceability is increasingly critical for fashion and textile brands, driven by evolving EU regulations, growing consumer awareness, and rising demand for sustainable practices. However, for denim manufacturers—especially those working with post-consumer recycled (POCR/PCR) cotton—these pressures can result in operational overload, as they wrestle with inconsistent definitions, standards, and systems across brand partners.

As one Denim Deal member put it during an August 2025 Denim Deal meeting focused on post-consumer cotton production and traceability challenges., “The scalability of PCR is not the main issue — the problem is that every brand has its own certification body and its own portal. This costs us significant money, manpower, and time.”

Industry observers note that supply chain traceability has shifted from being a compliance checkbox to a strategic market differentiator, now seen as essential for brand reputation, consumer trust, and risk management (Inspectorio, 2023).

Regulatory drivers accelerating this shift include:

• The EU Waste Framework Directive will require separate textile waste collection in all member states by January 1, 2025 (European Commission, 2023) (European Environment Agency, 2023).
• Germany’s Supply Chain Due Diligence Act (2023) Requires due-diligence risk management for direct suppliers, and for indirect suppliers when there is substantiated knowledge of potential violations. It currently applies to companies meeting specific employee thresholds. (German Federal Ministry for Economic Affairs and Climate Action, 2023).

At the same time, brands are pushing for tools like digital product passports and fiber-level traceability — some aiming for basic transparency via QR codes, others layering in blockchain-based narratives or resale utility. However, differences in timelines, platforms, and functionality are creating friction and inconsistency for suppliers.

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According to the 10th edition of the Vogue Business Index, 67% of top luxury brands had adopted DPPs by mid‑2025. Under the ESPR, DPPs are moving toward mandatory status, with phase-ins across product categories through the decade. While many frame this as “expected by 2030,” the actual deadlines will be set through delegated acts per product group.

For mills and garment producers in the Denim Deal, the reality is a multi-layered compliance puzzle:

• Different definitions of “traceable” and “recycled” content (e.g., some require ≥20% PCR cotton, others accept blends with pre-consumer waste).
• Multiple chain-of-custody standards (GRS, RCS, and brand-specific audits).
• Platform proliferation: Textile Genesis, FiberTrace, and brand-proprietary systems — each requiring separate registration and fees.
  

Some large brand groups require suppliers to use third‑party traceability platforms (e.g., TextileGenesis); others run proprietary or brand‑specific portals; and still others mandate fiber‑marking technologies (e.g., FibreTrace). For manufacturers, that often means paying multiple platform fees, onboarding teams to different systems, and duplicating data work. “Brands still expect price neutrality for around 20% PCR content, which makes small‑volume orders unviable,” said a Denim Deal member.

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The bottleneck is clean feedstock. The textile collection and sorting system in our region is too weak to ensure a steady, high-quality supply,” said a Denim Deal member in the August 2025 meeting.

While this member’s mill has developed fabrics with 20% PCR content — and can incorporate up to 50% using long-staple fibers from sources like hotel linens — long-term viability depends on buyer commitment.

Industry research confirms this constraint. Post-consumer textiles still rely heavily on manual sorting, leading to contamination and inconsistent quality (Recover Fiber, 2023). This limits scale, especially when brand PCR targets outstrip available supply.

Manufacturers report:

• Staff time lost to duplicate data entry across portals.
• Audit fatigue from unsynchronized brand review cycles.
• Capital at risk from tech investments tied to uncertain brand orders.

Smaller mills face the greatest risk of being priced out or excluded from sustainable supply chains if these burdens are not reduced (Fashion Sustainability Directory, 2022).

The Path Forward: Towards Greater Collaboration & Shared Responsibility

1. Harmonized standards for greater collaboration
The Denim Deal could spearhead an aligned definition of PCR cotton, unified audit protocols, and a single verification platform to cut redundancy.

2. Shared digital infrastructure
A joint digital passport system that feeds all brand databases could reduce manufacturer workload dramatically (Z2Data, 2025).

3. Investment in collection and sorting
Public-private partnerships are needed to scale automated sorting and fiber identification, securing supply for all (RecyclingInside, 2023).

4. Shared responsibility
The Denim Deal confirmed, it is currently in talks with TextileGenesis and FibreTrace to align approaches for reducing the burden of traceability on manufacturers, and is developing a digital space for approved fabrics in collaboration with World Collective to ease sourcing for mills.

The Denim Deal has already proven that sector-wide commitments can accelerate PCR adoption — Dutch market share of jeans with ≥20% PCR cotton jumped from 8% in 2020 to 41% in 2022 (Amsterdam Economic Board, 2023).

But without harmonized standards, shared infrastructure, and co-investment, traceability risks becoming a burden that slows innovation rather than a lever for systemic sustainability. Manufacturers like Crescent Bahuman Limited are showing what’s possible technically; the challenge now is ensuring the system supports, rather than strains, these pioneers.

Definitions
PCR Cotton: Post-Consumer Recycled Cotton, Textiles that have been used and discarded by consumers, then collected, sorted, and recycled. It is a broader term that can be applied across industries, including packaging, paper, cotton, and plastics.
EX: A T-shirt made from old jeans collected via take-back programs.

POCR Cotton: **Post-**Consumer Recycled Cotton (specific to denim/textiles), similar to PCR, but the term POCR is used to clarify it's specifically cotton fiber from used garments, not mixed materials. It is used in more precise and technical industry-specific contexts like the Denim Deal.
EX: Jeans made from 20% POCR cotton derived from end-of-life garments.


Key References

1. Denim Deal Booklet & Technical Report, 2023 & 2024, (https://www.afvalcirculair.nl/publish/library/277/technical-report-denim-deal-20240207.pdf)
2. Amsterdam Economic Board — Denim Deal expands circular fashion movement from Amsterdam to Paris, March, 2025 – (https://www.iamsterdam.com/en/business/denim-deal-expands-circular-fashion-movement-from-amsterdam-to-paris?utm_source=chatgpt.com)
3. Inspectorio — Traceability in 2025, (https://www.inspectorio.com/blog/traceability-in-2025-evolving-from-compliance-to-strategic-advantage)
4. Z2Data — Why Supply Chain Traceability Matters More Than Transparency and Visibility in 2025, January, 2025 – (https://www.z2data.com/insights/why-supply-chain-traceability-matters-more-than-transparency-and-visibility-in-2025)
5. Recover Fiber — Textile Sorting Challenges, September, 2023 – (https://recoverfiber.com/newsroom/textile-sorting-challenges-and-strategies-for-achieving-circularity-in-the-industry)
6. RecyclingInside — Textiles Recycling: The Sorting Challenge, March, 2023 – (https://recyclinginside.com/recycling-technology/separation-and-sorting-technology/textiles-recycling-the-sorting-challenge/)
7. European Commission — Waste Framework Directive, May, 2024 – (https://environment.ec.europa.eu/topics/waste-and-recycling/waste-framework-directive_en)
8. Vogue Business, Redefining Connected Fashion with DPP Leader Certilogo, May, 2025 – (https://www.voguebusiness.com/story/events/redefining-connected-fashion-with-authentication-leader-certilogo?utm_source=chatgpt.com)

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