Correction, 16 September 2026: clarified fibre names, care-labelling duties, identifier and format choices, and access rights. This correction covers those passages only.
Digital Product Passport (DPP) data requirements define exactly what information manufacturers and brands must collect, structure, and publish for every product sold in the EU. No product-specific ESPR delegated act has been adopted yet (as of February 2026), but the framework regulation, the European Commission's December 2025 textile preparatory study, and the Battery Regulation (Regulation (EU) 2023/1542) together reveal roughly 16 data categories across three confidence tiers — near-certain, expected, and possible — that let brands start collecting the right data now without over-investing in requirements that may change.
What Data Does a Digital Product Passport Require?
Every Digital Product Passport must contain product-level information that enables consumers, recyclers, and regulators to understand a product's composition, environmental impact, and end-of-life options. The ESPR (Regulation EU 2024/1781) sets the framework in Articles 8 through 12, but the specific data fields for each product type are defined in delegated acts — secondary legislation adopted by the European Commission.
As of February 2026, no product-specific ESPR delegated act has been formally adopted. However, the Commission's preparatory studies, the ESPR framework text, and existing regulations (like the Battery Regulation) give us a clear picture of what to expect.
Not all DPP data requirements are confirmed yet. This guide uses a confidence framework (Tier 1, 2, 3) to help you prioritize what to collect now versus what to wait on. Distinguishing between confirmed and expected requirements prevents both under-preparation and wasted investment.
What Are the Three Tiers of DPP Data?
We categorize expected DPP data into three tiers based on how confident we are that they will be required. This framework helps brands prioritize their data collection efforts.
Tier 1: Core Product Data (Start Now)
Use this checklist to organize existing product data. Some entries reflect current legal duties; the final textile delegated act will determine the DPP fields.
| Data Category | What to Collect | Why Collect It |
|---|---|---|
| Product identification | Existing model, SKU, batch or serial identifiers; GTIN where assigned | ESPR requires a unique DPP identifier; textile details remain to be specified |
| Economic operator details | Manufacturer name, brand, importer, EU responsible person | ESPR Annex III(j)–(k) lists importer and responsible-operator information among DPP data; required for market surveillance |
| Material composition | Fibre names from Annex I to Regulation (EU) 1007/2011; percentages by weight | Existing composition-labelling duty for products in scope |
| Recycled content | Percentage of recycled material by weight | ESPR framework explicitly lists this |
| Country of manufacture | Country where final assembly occurred | Standard supply chain data; referenced in ESPR |
| Care instructions | Washing, drying and ironing guidance; ISO 3758 symbols where used | Useful product information; Regulation 1007/2011 does not require care labels |
| Substances of concern | Chemicals above REACH thresholds, SVHC declarations | Required under REACH Regulation (EC) No 1907/2006 |
| Compliance and certifications | CE marking status, OEKO-TEX, GOTS, or other certifications | ESPR conformity requirements |
The Commission’s textile-labelling FAQ (§§2.3 and 6.7) confirms that there are no harmonized EU wash/care-labelling rules. Product-specific safety instructions may still be required. For composition labels, Article 5 and Annex I of Regulation (EU) 1007/2011 govern fibre names.
If you do nothing else, audit your product data against this Tier 1 list. Most of this information already exists somewhere in your supply chain — the challenge is digitizing and structuring it, not generating it from scratch.
Tier 2: Expected Requirements (Prepare, Don't Perfect)
These data categories are referenced in the ESPR framework and the Commission's December 2025 textile preparatory study. They are very likely to be required, but the exact methodology or thresholds will only be defined in the delegated act.
| Data Category | What to Collect | What's Still Undefined |
|---|---|---|
| Carbon/environmental footprint | Per-product carbon footprint data | Whether a footprint is required at all — and as a performance class or absolute value — plus calculation methodology (PEF vs. simplified LCA) |
| Durability | Expected product lifespan, pilling/abrasion/color fading resistance | Specific test standards and minimum thresholds |
| Repairability | Repair instructions, spare part availability | Scoring methodology and categories |
| Recyclability | Mono-material percentage, disassembly guidance | Design-for-recycling assessment criteria |
| End-of-life guidance | Recycling instructions, collection points, take-back programs | Level of specificity required |
What "prepare, don't perfect" means: Start mapping where this data would come from in your supply chain. Identify which suppliers would need to provide it. But don't invest heavily in carbon footprint calculations until the methodology is confirmed — the delegated act might require a simplified approach that costs far less than a full Product Environmental Footprint (PEF) assessment.
Tier 3: Possible Requirements (Monitor)
These data categories appear in the broader ESPR framework and in CIRPASS-2 pilot findings (CIRPASS-2 Consortium, 2025), but their inclusion in the textile delegated act is less certain. The exact scope depends heavily on the final delegated act text.
| Data Category | What It Might Include | Likelihood |
|---|---|---|
| Manufacturing processes | Dyeing, weaving, finishing methods used | Medium |
| Supply chain traceability | Production stages and locations | Medium (phased rollout proposed) |
| Water usage | Water consumption in manufacturing | Medium |
| Energy consumption | Energy used in production | Medium |
| Social impact | Labor conditions, certifications | Lower |
| Animal welfare | For products using leather, wool, down | Lower |
Where Do DPP Data Sources Agree and Diverge?
Three authoritative sources inform our understanding of textile DPP data requirements: the ESPR framework regulation itself (EU 2024/1781), the European Commission's December 2025 textile preparatory study, and the Battery Regulation (Regulation (EU) 2023/1542) as the only fully specified DPP to date — the one case where the law already lists the contents item by item. Comparing these sources reveals where the requirements are effectively locked in — and where significant uncertainty remains.
| Data Category | ESPR Framework (2024/1781) | Dec 2025 Textile Preparatory Study | Battery Regulation (2023/1542) | Convergence Level |
|---|---|---|---|---|
| Product identification | Persistent unique identifier (Article 10) | Identifier details subject to the textile delegated act | Required — unique battery ID | Common principle; identifier schemes and granularity vary |
| Material composition | Referenced as core data category | Fibre data under consideration; Annex I names govern existing composition labels | Required — cell chemistry, material breakdown | Shared data category; exact requirements vary |
| Manufacturer/economic operator details | Required (Annex III(j)–(k)) | Required | Required — manufacturer + placing-on-market entity | Full convergence — collect now |
| Substances of concern | Referenced — links to REACH | Required — SVHC declarations | Required — hazardous substances | Full convergence — collect now |
| Carbon/environmental footprint | Referenced as expected data | Included — methodology TBD | Required — verified by third party, performance class, scale set by the delegated act | Partial convergence — collect data, but whether and how a footprint is required for textiles is still being assessed |
| Recycled content | Referenced | Included — percentage by weight | Required — cobalt, nickel, lithium, lead recovery % | High convergence — collect now |
| Durability/performance | Referenced — delegated act will specify | Included — pilling, abrasion, color fading resistance | Required — state of health, cycle history, degradation | Low convergence — metrics differ dramatically by product type |
| Supply chain traceability | Referenced — scope left to delegated acts | Proposed phased rollout (2027/2030/2033) | Required — full due diligence, but from 18 Aug 2027 | Divergent — textiles get phased approach; batteries require full traceability once due diligence starts |
| Repairability | Referenced | Included — repair instructions, spare parts | N/A for batteries (different lifecycle) | Textile-specific — no battery precedent to reference |
| End-of-life/recycling | Referenced | Included — collection points, recyclability | Required — dismantling instructions, recovery rates | High convergence — collect now |
These sources identify useful categories to prepare, but do not establish a common identifier scheme, granularity or complete list of textile DPP fields. Reuse existing product data and follow the textile delegated act for final requirements. Carbon footprint and supply chain traceability are the categories with the most remaining uncertainty — invest in data collection infrastructure for these, but do not over-invest in methodology until the delegated act confirms the approach.
How Will Supply Chain Traceability Be Phased In?
One of the most challenging data categories is supply chain traceability. The December 2025 preparatory study proposes a phased rollout:
| Phase | Timeline | What You Need |
|---|---|---|
| Phase 1 | At delegated act adoption (~2027) | Key processes and production locations |
| Phase 2 | 2030 | Expanded details per production stage with confidentiality controls |
| Phase 3 | 2033 | Complete documented supply chain with controlled access |
This phased approach is good news for small brands. You do not need full raw-materials-to-retail traceability on day one. Start with your Tier 1 suppliers (the factories you contract directly) and expand from there.
Send your direct suppliers a data request now. Ask for: factory location, key manufacturing processes used, material sourcing countries. Even basic responses create a foundation you can build on when exact requirements are defined.
What Are the DPP Data Format Requirements?
The DPP is not a PDF or a paper document. It is structured, machine-readable digital data.
PassportCraft’s data format
ESPR Article 10 requires machine-readable data, open standards and interoperability. The textile delegated act will specify the data carrier and detailed requirements. PassportCraft uses the following implementation; it is not a universal legal format.
| Component | PassportCraft implementation | Notes |
|---|---|---|
| Structured data | JSON-LD with Schema.org vocabulary | Machine-readable product information |
| Product identifier | GTIN | Required to publish in PassportCraft |
| Item identifier | GTIN + serial number | Optional for textile passports |
| Data carrier | QR code | Opens the passport through a GS1 Digital Link URL |
| URL structure | GS1 Digital Link | https://domain/01/{GTIN}/21/{serial} when a serial is supplied |
Access Tiers
ESPR Articles 9(2)(f) and 11(b) leave actors’ access rights and the data they can access to the applicable delegated act. They do not assign every field to three fixed tiers. A service may organize access as follows, but the textile rules will determine the legal permissions.
| Tier | Who Can Access | What They See |
|---|---|---|
| Public | Any consumer scanning the QR code | Information intended for public access |
| Restricted | Recyclers, repairers, distributors | Data shared with authorized parties |
| Authority | Market surveillance, customs | Data required for the competent authorities |
Classify information according to applicable legal duties and authorized access. In PassportCraft, textile disassembly instructions are public; the ESPR framework does not require that field to be restricted.
What Should You Do Right Now?
Based on the tier framework, here is what to prioritize in 2026:
Do now (Tier 1 — organize existing product data):
- Audit your product data against the Tier 1 table above
- Digitize material composition data for every SKU
- Check the identifiers already assigned to your products. PassportCraft requires a valid GTIN to publish; ESPR does not impose a blanket requirement to obtain a GS1 company prefix.
- Verify substances of concern compliance (REACH/SVHC)
- Confirm which EU-established operator is responsible for your product (if selling from outside the EU) — your EU importer usually qualifies
Do this quarter (Tier 2 — expected requirements):
- Map where environmental footprint data would come from
- Assess durability/repairability data availability for your products
- Send data requests to Tier 1 suppliers
- Evaluate DPP platform options
Wait and monitor (Tier 3 — possible requirements):
- Watch for the textile delegated act publication (expected late 2027)
- Track CEN/CENELEC harmonized standards (six published May 2026, cited as harmonized by Decision (EU) 2026/1736 in July 2026; two more expected September 2026)
- Monitor CIRPASS-2 pilot outputs for textile-specific recommendations
How DPP Data Requirements Differ by Product Category
While this guide focuses on textiles, DPP data requirements will vary by product category. Here is how the key categories compare:
| Data Category | Textiles | Batteries | Electronics | Furniture |
|---|---|---|---|---|
| Material composition | Required | Required | Required | Required |
| Carbon footprint | Expected | Required, but not on 18 Feb 2027 | Expected | Expected |
| Recycled content | Expected | Required, but not on 18 Feb 2027 | Expected | Expected |
| Repairability | Expected | N/A | Required (score) | Expected |
| Supply chain traceability | Phased | Required (due diligence), but from 18 Aug 2027 | Expected | Expected |
| Substances of concern | Required (REACH) | Required | Required (RoHS) | Required |
| Care instructions | Future DPP requirement not finalized | N/A | N/A | Expected |
| End-of-life guidance | Expected | Required | Expected | Expected |
| DPP Deadline | ~2028/2029 | Feb 2027 | ~2028-2030 | ~2029/2030 |
The EU Battery Regulation is the most advanced — battery passport requirements are the most specific and the deadline (February 2027) is the earliest. Textile requirements will follow a similar pattern but with some differences in emphasis (care instructions, fiber composition, fashion-specific durability metrics). Three cells in the batteries column above carry a qualifier: the Commission's guidance says the carbon footprint and the recycled-content shares are not to be filled on 18 February 2027, and Article 48(1) does not start battery due diligence until 18 August 2027. We set out what a battery passport actually needs on day one field by field.
Frequently Asked Questions
What data is required for a textile Digital Product Passport?
The exact data fields will be defined in the textile delegated act (expected late 2027). Based on the ESPR framework and the December 2025 preparatory study, textile DPPs are expected to require material composition, product identification, economic operator details, substances of concern, care instructions, durability and repairability information, recyclability guidance, and supply chain traceability data; environmental footprint data is under assessment.
Do I need to collect data for products already on the market?
DPP requirements apply to products placed on the market after the delegated act's application date. Products manufactured and sold before that date are not retroactively required to have a DPP. However, any existing inventory that is first placed on the market after the deadline would need one.
How granular does the data need to be — per product, per batch, or per unit?
The ESPR supports three granularity levels: model, batch, and item. The textile delegated act will specify which level is required. The JRC's May 2026 proposal — still subject to the impact assessment — makes batch and model identifiers mandatory, with the DPP instantiated at batch level; item-level unique serials (SGTIN) would be optional for brands that want them, for example for resale or authentication. A batch-level approach means one DPP per production batch rather than per individual garment.
What happens if I don't have complete supply chain data?
Start with what you have. The phased traceability rollout means Phase 1 (at adoption) requires only key processes and production locations — not full raw-materials-to-retail tracking. Work with your direct suppliers to collect available data now. Many brands will find that their Tier 1 suppliers can provide basic process and location data even if deeper upstream data is unavailable.
Is there a standard format for DPP data?
ESPR requires machine-readable, interoperable data. The textile delegated act will specify the carrier and detailed requirements. PassportCraft uses JSON-LD and GS1 Digital Link, but these are not blanket formats prescribed by ESPR for every product. The CEN/CENELEC JTC 24 standards covering data formats, APIs, and interoperability were originally targeted for March 2026 (European Commission Standardisation Request M/616, 2024); that deadline was missed, but six were published in May 2026 (with two more still in draft) and cited in the Official Journal as harmonized by Commission Implementing Decision (EU) 2026/1736 in July 2026.
Can I use my existing ERP or PLM system for DPP data?
Your ERP or PLM system may contain much of the required data, but it likely isn't structured in the required format. Most brands will need a DPP-specific platform that integrates with their existing systems to transform product data into compliant DPP format. The good news: DPP platforms are designed to pull data from existing systems rather than requiring you to re-enter everything.
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