What is required for a Digital Product Passport
Once a Digital Product Passport (DPP) obligation applies, compliance is evaluated based on the information made available for each individual product, not on internal systems, reports, or general disclosures.
This page outlines what regulators, retailers, and inspectors expect to see in practice when a textile or apparel product is assessed for ESPR compliance.
Product-level (not brand-level)
Digital Product Passports are required at product (SKU) level.
This means:
Each distinct product must have its own passport
Variants with different materials or construction require separate records
A single brand-level page or statement does not satisfy this requirement
In practice, regulators assess the data linked to the specific physical product being inspected, not general disclosures made elsewhere.
Publicly accessible records
A Digital Product Passport must be:
Directly accessible when a product is scanned or inspected
Available without internal system access or logins
Linked to the physical product via a persistent identifier (typically QR code)
Internal dashboards, compliance platforms, or supplier portals may support your internal processes, but they do not replace an externally accessible passport.
Defined data categories for textiles and apparel
For textile and apparel products, Digital Product Passports are expected to include defined categories of information, which typically cover:
Product identification (SKU, model, version)
Material composition (including percentages where applicable)
Manufacturing and processing stages
Countries of processing
Chemical treatments where required
Durability, repair, and care guidance
Recycling and end-of-life instructions
The exact required fields are defined through ESPR and its delegated acts and may be refined over time.
Supplier-declared information
Much of the required data originates from suppliers.
For compliance purposes:
Supplier responses must be recorded as declared information (not assumptions)
Data sources should be explicitly attributable
Assumptions or inferred values should be clearly identified or avoided
Known limitations must be documented transparently
This structured declaration approach is what supports regulatory defensibility under ESPR.
Structured and consistent data
Regulatory compliance is evaluated on clarity and consistency, not on volume.
This means:
Material percentages should sum correctly
Terminology should be consistent across products
Units, formats, and references should be normalized
Updates should be versioned over time
Unstructured documents, PDFs, or free-text supplier emails may contain useful information, but they do not constitute a compliant passport on their own.
Living records
A Digital Product Passport is not a one-time submission.
In practice:
Information may change as suppliers revise declarations
Regulatory guidance may be updated
Products may be modified or withdrawn
Passports should therefore be:
Updateable
Versioned
Timestamped
Static reports or snapshots do not meet this requirement over a product’s lifecycle.
What does not qualify as a Digital Product Passport
To avoid confusion, the following do not constitute a Digital Product Passport on their own:
Brand-level sustainability pages
Supplier certificates without product linkage
Internal compliance dashboards
Material libraries not tied to specific products
Marketing or transparency claims without structured data
These elements can support compliance, but they do not replace a product-specific, inspectable passport.
General requirements
In practical terms, Digital Product Passport compliance requires:
A product-specific record
Public accessibility via a persistent link
Defined data fields relevant to textiles and apparel
Explicit attribution of supplier-declared information
Ongoing maintenance over time
Meeting these requirements ensures that when a product is inspected, its compliance information can be reviewed directly and without ambiguity.
Specific requirements
What is required can vary depending on product type, materials, and regulatory phase-in timing.
If you are unsure what data is required for your specific products, or how existing supplier information maps to ESPR requirements, this can be clarified before any implementation work begins.
Meeting these requirements ensures that when a product is inspected, its compliance information can be reviewed directly and without ambiguity.