What Data Must a Digital Product Passport Contain? ESPR Requirements Explained

DPP data: what the regulation says vs. what delegated acts specify

The Ecodesign for Sustainable Products Regulation (ESPR), formally Regulation (EU) 2024/1781, establishes the legal framework for Digital Product Passports (DPPs). However, the specific data fields required for textiles are not yet fully codified in the primary regulation. Instead, Article 9 of the ESPR mandates that the European Commission adopt delegated acts to specify the exact content of DPPs for each product category.

For the fashion and textile sector, this means there is a distinction between the general structural requirements currently in force and the category-specific mandates that will follow. The delegated act for textiles is expected to be finalized by late 2027. Until then, compliance teams must prepare for the general framework outlined in Articles 9–11 of the ESPR, which defines the minimum structural elements applicable across all covered products. Understanding this two-tiered approach is critical: you must build your data architecture to satisfy the general ESPR structure now, while remaining agile enough to ingest the specific, granular requirements that will arrive with the textile delegated act.

Core data fields in every ESPR DPP

Based on the general ESPR structure, every DPP must contain a standardized set of core data fields. These fields ensure that the passport serves as a reliable source of truth for the product’s lifecycle. The following elements are mandatory under the general framework:

• Unique Product Identifier: A unique ID linked to a data carrier (such as a QR code, RFID tag, or data matrix). This identifier must be unique to the individual product unit, not just the SKU.
• Material Composition: Detailed breakdown of fiber types and their origins. This includes the percentage of each material and the country of origin for raw materials.
• Technical and Safety Information: Data relevant to product safety, including chemical composition, flammability standards, and any known hazards.
• Manufacturer and Importer Details: Legal entity information, including name, address, and contact details of the manufacturer or the importer responsible for placing the product on the EU market.
• Instructions for Use and Care: Digital equivalents of care labels, including washing temperatures, drying instructions, and maintenance guidelines to extend product life.
• End-of-Life Instructions: Guidance on disassembly, recycling pathways, and proper disposal methods to facilitate circularity.

Note that supply chain information is currently not fully specified for textiles in the general framework. The upcoming delegated act will likely define the depth of traceability required, potentially extending to specific tiers of the supply chain.

Environmental performance data: what to measure

A critical component of the ESPR DPP is environmental performance data. This section moves beyond static material lists to dynamic metrics that assess the product’s sustainability profile. Key metrics include:

• Durability: Expected lifespan of the product under normal use conditions. This may involve standardized testing results or manufacturer estimates based on material properties.
• Repairability: Information on the ease of repair, including the availability of spare parts and instructions for common repairs. This supports the right to repair initiatives within the EU.
• Recyclability: Data on the product’s design for recycling, including the separation of materials and the technical feasibility of recycling processes.
• Carbon Footprint: Quantified greenhouse gas emissions associated with the product’s lifecycle, typically measured in CO2 equivalent. This data must be calculated according to recognized methodologies to ensure comparability.

These metrics require robust data collection from suppliers and internal production processes. Brands should begin mapping these data points now, as the delegated act will likely mandate specific calculation standards and verification requirements.

Data carriers: QR codes, RFID, and identifiers

The DPP is accessed via a data carrier attached to the product. The ESPR requires that these carriers use unique identifiers compliant with ISO/IEC 15459 standards. This ensures interoperability and security across the EU DPP registry.

• QR Codes: The most common and cost-effective solution for most fashion products. They are easily scannable by consumer smartphones and suitable for high-volume items.
• RFID Tags: Preferred for luxury or high-value items where non-line-of-sight scanning is beneficial. RFID allows for efficient inventory management and authentication, reducing counterfeiting risks.
• Data Matrix Codes: Another 2D barcode option, often used in industrial contexts but applicable in fashion for specific supply chain tracking needs.

The choice of carrier depends on the product category, price point, and operational requirements. However, regardless of the carrier type, the underlying identifier must be registered in the EU DPP registry to ensure authenticity and traceability.

Public vs. restricted data access tiers

Not all DPP data is accessible to the general public. The ESPR establishes a tiered access model to balance transparency with commercial confidentiality and data security.

• Public Tier: Consumer-facing data, such as material composition, care instructions, and basic environmental performance metrics (e.g., carbon footprint summary). This data is accessible via the data carrier without authentication.
• Restricted Tier: Sensitive data, including detailed supply chain information, proprietary manufacturing processes, and specific chemical formulations. Access to this tier is restricted to authorized entities, such as regulators, recyclers, and authorized service providers, often requiring digital identity verification.

Brands must implement role-based access controls within their DPP systems to ensure that restricted data is only visible to authorized users. This is crucial for protecting intellectual property while meeting regulatory transparency requirements.

How to structure your data collection now

Given the timeline for the textile delegated act, brands should adopt a phased approach to data collection. First, establish a centralized data model that aligns with the general ESPR structure. This includes defining data schemas for material composition, environmental metrics, and supply chain details. Second, integrate with suppliers to begin collecting raw data, particularly for carbon footprint and material origin. Third, pilot your DPP system with a limited product range to test data accuracy and consumer usability.

For technical teams, this involves setting up APIs that can ingest structured product data and generate compliant DPP records. For example, a system might accept a POST request to an endpoint like /api/v1/dpp with structured product data, returning a DPP record and a compliant data carrier URL. This ensures that your infrastructure is ready to scale as the delegated act requirements become more specific. By aligning your data architecture with the CEN/CENELEC EN 18xxx standards for technical interoperability, you ensure that your DPPs will be compatible with the EU DPP registry and other stakeholders in the circular economy ecosystem.