One Product-Data Stack for ESPR DPP and CSRD — Not Two Projects

Two regulations, overlapping data asks

COOs and compliance leads in fashion are increasingly asked to run two parallel data‑collection programmes: the European Product Sustainability Register (ESPR) DPP under Regulation (EU) 2024/1781, and the Corporate Sustainability Reporting Directive (CSRD) under Directive (EU) 2022/2464. While the legal texts differ, the data fields they require at SKU level are almost identical – unique product identifiers, material composition, carbon‑footprint numbers, manufacturer or importer details, and care/end‑of‑life instructions. The result is duplicated effort, higher operational cost, and a higher risk of inconsistent data that can undermine the limited assurance required for CSRD reports.

What the DPP already needs at product level

The ESPR DPP, defined in Articles 9‑11, mandates a machine‑readable record linked to each product via a data carrier such as a QR code, RFID tag, or data matrix. The record must contain:

• Unique product identifier (e.g., GTIN or internal SKU)
• Full material composition, broken down by fibre or component
• Environmental performance data, including the product’s carbon footprint
• Manufacturer or importer details, including contact information
• Care instructions and end‑of‑life recommendations (recycling, disposal, etc.)

This structure is already designed to be reusable across supply‑chain partners and to support downstream reporting.

What CSRD Scope 3 pulls from the same records

For fashion companies that exceed the CSRD threshold of >1,000 employees, the Directive requires reporting on Scope 3 emissions and the social‑environmental (S2) pillar of double materiality. Product‑level data is the primary source for calculating upstream and downstream Scope 3 categories such as raw‑material extraction, manufacturing, transport, and use‑phase impacts. The same material composition and carbon‑footprint figures required by the DPP feed directly into the CSRD emissions inventory, while manufacturer details support the governance disclosures required for limited assurance.

Why duplicate collection fails limited assurance

Limited assurance, now mandatory for CSRD reports from FY 2027, demands that the underlying data be reliable, traceable, and auditable. When organisations maintain separate ESPR and CSRD data‑collection streams, inconsistencies inevitably arise – for example, differing carbon‑footprint values for the same SKU or mismatched material breakdowns. Auditors will flag these gaps, increasing remediation costs and potentially delaying filing for the FY 2027 reporting period (with filing due in 2028). A single, harmonised data set eliminates the reconciliation step and provides the audit trail needed for limited assurance.

A single collection plan before 2027‑2028

Given that the textile delegated act is expected in late 2027 and the mandatory DPP window for textile and footwear runs 2027‑2028, fashion brands have a narrow window to align their data‑collection processes. A pragmatic plan includes:

1. Map the ESPR DPP fields to CSRD Scope 3 requirements. Identify one‑to‑one matches (e.g., material composition → upstream emissions) and any gaps.
2. Implement a unified data capture system. Use a single API endpoint – KadmilOS DPP API POST /api/v1/dpp – to push product records once, then reuse them for both regulatory outputs.
3. Standardise data carriers. Choose QR codes or RFID tags that can be read across the supply chain, ensuring the same identifier feeds both ESPR and CSRD reporting.
4. Establish data governance. Define roles, validation rules, and a change‑log that satisfies limited‑assurance reviewers.
5. Run a pilot before the 2027 deadline. Test the end‑to‑end flow for a representative product line, correct any mismatches, and scale.

By consolidating the collection effort now, brands avoid a rushed, dual‑track implementation when the mandatory DPP window opens.

How KadmilOS fits in

KadmilOS (kadmilos.vinket.eu) offers a purpose‑built DPP API that aligns with the ESPR structure and is ready to serve CSRD needs. By posting a single product record to POST /api/v1/dpp, brands capture all required fields – identifier, composition, carbon footprint, manufacturer data, and care/end‑of‑life instructions – in a machine‑readable format. The platform automatically generates the QR/RFID data carriers, stores the records in a compliant repository, and provides export functions that map directly to CSRD Scope 3 reporting templates. This eliminates the need for separate data‑entry systems, reduces the risk of inconsistencies, and creates the audit trail demanded by limited assurance.

In practice, a fashion brand can integrate KadmilOS into its existing PLM or ERP, trigger the DPP API whenever a new SKU is created, and rely on the same dataset for both ESPR registration and CSRD disclosures. The result is a single, coherent product‑data stack that satisfies two major EU sustainability regulations without duplication of effort.

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