The EU Ecodesign for Sustainable Products Regulation (ESPR) provides the framework for a Digital Product Passport (DPP). Textiles, particularly garments and footwear, are among the priority product groups in the first ESPR working plan. The actual fields, data carrier and level of application must still be checked against the applicable product-specific delegated act and any other relevant Union law.
This page is a preparation and evidence-mapping checklist. It does not state that a DPP has already been completed, that a product has market access, or that a platform requirement has been satisfied.
1. Confirm scope, product group and version
Create one master record for each SKU: product name, model or style number, product group, material composition, target market, sales format, production site and data version. Do not treat a brand, factory or shipment as the only data level. Article 9 of the ESPR allows product-specific delegated acts to define whether a DPP is created at model, batch or item level and how customers access it before purchase.
Record the basis for each scope decision: the regulation and version, whether the relevant delegated act is adopted, whether the product is covered, any transition arrangement, and the fields still awaiting confirmation. A field should not be described as universally mandatory when no applicable product-group rule supports that conclusion.
2. Map DPP fields and identifiers
Using the ESPR framework in Articles 10 and 11, prepare the unique product identifier, data carrier, relevant economic-operator identifiers and facility identifiers. For every field, record the source file, data owner, revision date and access level. Article 10 links the data carrier to a persistent unique product identifier; its exact position and technical requirements are determined by the applicable rules.
A practical mapping table can include: field name, value, unit or code list, level (model, batch or item), source document, document version, owner, customer visibility and business or authority access. For material composition, durability, reparability, recyclability, recycled content or substances of concern, retain the calculation, test or supply-chain basis. A generic certificate is not a substitute for product-level evidence.
3. Assemble product, operator and supply-chain evidence
Organise the file map into four groups. Product records cover specifications, BOM, fibre and trim composition, measurements and label artwork. Production records cover the site, batch or work order, process changes and revisions. Claim records cover tests, calculations and supplier statements with their scope. Page records cover the data-carrier location, customer-visible fields, languages, publication date and correction or withdrawal history.
Check the legal entity, product or material scope, model or batch, issue date, standard and permitted use of every document. A supplier document may be a source, but the supplier name alone does not prove that all obligations of the brand owner or importer have been met. Record missing evidence as an open item; do not fill the gap with platform assumptions, a universal validity period or an outcome promise.
4. Registry, access and data governance
Article 13 of the ESPR establishes a DPP Registry for at least certain unique identifiers where the applicable rules require registration. Commission Implementing Regulation (EU) 2026/1778, adopted in July 2026, sets implementation arrangements for that registry. The Registry is not a repository for publishing every internal file, and it does not by itself mean that every textile SKU must already be registered. Confirm the required data, level and access roles in the applicable product-group legislation.
Maintain an access matrix for customer-visible information, supply-chain business access, market-surveillance or customs access, internal evidence and personal data. ESPR Article 9 requires DPP data to be accurate, complete and up to date. When material, supplier, production site or page versions change, retain the reason, affected SKUs, status of the old version and the owner of the re-check.
5. Pre-publication review and boundaries
Before publication, confirm that the SKU and evidence match; every field has a source and version; units, languages and data carriers are readable; the page agrees with the internal record; and draft or not-yet-defined fields are clearly labelled. Review the target market and product group separately. Do not merge DPP preparation with PPWR, EUDR, CBAM, platform review or voluntary certification into one generic checklist.
This article is a document-preparation reference. It is not legal advice, a certification conclusion, a platform decision or a market-access promise. Sources: Regulation (EU) 2024/1781, especially Articles 9–13 and Annex III, and Commission Implementing Regulation (EU) 2026/1778.
