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: Near-Certain Requirements (Start Now)
These data categories are either directly specified in the ESPR framework text or are already required under existing EU legislation. Every brand should be collecting this data today.
| Data Category | What to Collect | Why We're Confident |
|---|---|---|
| Product identification | Model number, SKU, batch or serial number, GTIN | ESPR Article 10 mandates unique identifiers |
| Economic operator details | Manufacturer name, brand, importer, EU responsible person | ESPR Article 9; required for market surveillance |
| Material composition | Fiber types (per ISO 2076), percentages by weight | Already required under EU Textile Labelling Regulation 1007/2011 |
| 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, ironing guidance (per ISO 3758) | Already required on garment 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 |
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 | 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. 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 (GTIN, serial) | Required (Article 10) | Required — GS1 identifiers | Required — unique battery ID | Full convergence — collect now |
| Material composition | Referenced as core data category | Required — fiber types per ISO 2076, weight % | Required — cell chemistry, material breakdown | Full convergence — collect now |
| Manufacturer/economic operator details | Required (Article 9) | 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 A–E | Partial convergence — collect data, but methodology for textiles not confirmed |
| 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 from day one | Divergent — textiles get phased approach; batteries require full traceability immediately |
| 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 |
The pattern is clear: product identification, material composition, economic operator details, substances of concern, and recycled content are fully converged across all three sources. These are safe investments regardless of the final delegated act text. 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.
Expected Data Format
| Component | Standard | Notes |
|---|---|---|
| Structured data | JSON-LD with Schema.org vocabulary | Primary format for machine-readable DPP data |
| Product identifier | GTIN (14 digits) via GS1 | Model-level identification |
| Item identifier | SGTIN (GTIN + serial number) | Item-level identification (if required by delegated act) |
| Data carrier | QR code (ISO/IEC 18004) | Physical tag encoding a GS1 Digital Link URL |
| URL structure | GS1 Digital Link | https://domain/01/{GTIN}/21/{serial} |
Access Tiers
DPP data is not all public. The ESPR mandates three access levels:
| Tier | Who Can Access | What They See |
|---|---|---|
| Public | Any consumer scanning the QR code | Product identity, environmental metrics, care instructions |
| Restricted | Recyclers, repairers, distributors | Chemical composition, bill of materials, dismantling instructions |
| Authority | Market surveillance, customs | Full compliance documentation, audit trails, confidential sourcing |
This means you will need to classify each data field by access level. Sensitive commercial information (supplier identities, exact formulations) goes behind restricted access — not visible to consumers.
What Should You Do Right Now?
Based on the tier framework, here is what to prioritize in 2026:
Do now (Tier 1 — confirmed requirements):
- Audit your product data against the Tier 1 table above
- Digitize material composition data for every SKU
- Ensure you have a GS1 Company Prefix and GTINs assigned to products
- Verify substances of concern compliance (REACH/SVHC)
- Confirm your EU Responsible Person designation (if selling from outside the EU)
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 2027)
- Track CEN/CENELEC harmonized standard publication (expected March 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 | Expected | Expected |
| Recycled content | Expected | Required | Expected | Expected |
| Repairability | Expected | N/A | Required (score) | Expected |
| Supply chain traceability | Phased | Required (due diligence) | Expected | Expected |
| Substances of concern | Required (REACH) | Required | Required (RoHS) | Required |
| Care instructions | Required | 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).
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 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, environmental footprint data, care instructions, durability and repairability information, recyclability guidance, and supply chain traceability data.
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. Early indications from the CIRPASS-2 project (CIRPASS-2 Consortium, 2025) suggest batch-level will be the default for textiles, with item-level for certain product types. 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?
Yes. DPP data is expected to use JSON-LD with Schema.org vocabulary, making it machine-readable and interoperable. Product identification follows GS1 standards (GTIN for products, GLN for locations). The data carrier (physical tag on the product) will be a QR code encoding a GS1 Digital Link URL. Eight harmonized CEN/CENELEC standards covering data formats, APIs, and interoperability are expected by March 2026 (European Commission Standardisation Request M/616, 2024).
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.
