Technical notes
Digital Product Passport: what it requires from your data
The EU Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) has been in force since July 2024. Among other things it introduces the Digital Product Passport, or DPP: a set of product information reachable from a physical data carrier applied to the product itself.
This note looks at it from the data side: which data is needed, where it sits today in a small business, and what can be prepared without waiting for the regulatory details.
Timing and sectors
The regulation is a framework: concrete requirements come per product group, through subsequent delegated acts. The Commission's working plan places textiles and apparel among the first groups. The delegated act for textiles is expected no earlier than 2027, and obligations will apply after a transition period.
Exact dates and the list of mandatory data depend on the delegated act. What follows is the common structure already defined in the regulation.
The four elements of the passport
| Unique identifier | Distinguishes the product. Depending on the delegated act it may refer to the model, the batch or the individual item. |
|---|---|
| Data carrier | The physical carrier leading to the identifier: typically a QR code, possibly NFC or RFID. It must comply with open standards. |
| Content | Information on materials, composition, origin, substances, use and care instructions, repairability, end of life. With different access levels for consumers, operators and authorities. |
| Registry | A European registry of identifiers, run by the Commission, linked to customs controls. |
Where this data sits today
In a small fashion or craft business the necessary data usually already exists, but it is scattered: composition is on the sewn-in label and the supplier's specification, origin is in the delivery note or invoice, production steps are in the memory of whoever did them, repairs are not recorded anywhere.
The passport does not require inventing new data. It requires having it structured, linked to an identifier and updatable over the product's life.
What can be prepared today
- One identifier per object. Even if the delegated act only requires the model, an item-level identifier covers all higher levels. The reverse is not true.
- An open data carrier. A QR with a URL, preferably in GS1 Digital Link format, is readable by anyone and does not tie you to a vendor.
- Structured data at the source. Supplier, article code, composition and origin recorded at receiving, when the document is on the table, not reconstructed later.
- An event history. Production steps, repairs and returns recorded on the object: this is the life-cycle information the passport aims to make visible.
- Exportable data. The passport will probably be published through third-party services. Having the data in an open, documented format avoids re-entering it.
Using the data before the obligation
The same data the passport will need is useful now in daily work: checking incoming goods, stock counts, availability across sites, repair history. Collecting it for current operations means the basis for the passport is already available when the obligation applies.