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Every DPP guide tells you to “start collecting data.” Very few tell you exactly which data, how detailed it needs to be, and, crucially, which fields you can safely deprioritise right now.
The result is that brand owners either try to collect everything at once (and get overwhelmed) or wait for the final delegated act text (and lose valuable preparation time). Neither approach helps you understand the DPP data requirements that actually matter right now.
This guide gives you the full picture. We’ve cross-referenced three authoritative sources, the ESPR framework regulation itself, the European Commission’s December 2025 textile preparatory study, and the EU Battery Regulation as the only fully specified DPP to date, and organised every expected data field into three confidence tiers. So you know exactly what to collect now, what to prepare for, and what to set aside.
Table of Contents
How to read this guide
We organise data fields into three tiers based on how confident we are that they’ll be required in the textile delegated act.
- Tier 1, Near-certain. These fields are either directly stated in the ESPR framework or already required under existing EU legislation. Start collecting this data today, regardless of what happens with the delegated act.
- Tier 2, Highly likely. These fields appear in the ESPR framework and the Commission’s preparatory studies. They’re very likely to be required, but the exact methodology or format will only be confirmed in the delegated act. Prepare the infrastructure to collect this data, but don’t over-invest in specific methodologies yet.
- Tier 3, Possible. These fields appear in broader EU policy discussions and CIRPASS-2 pilot findings, but their inclusion in the first textile delegated act is uncertain. Monitor these, don’t invest yet.
Tier 1, Start collecting now
Product identification
Every product needs a globally unique identifier. For fashion, this means a 13-digit GTIN (Global Trade Item Number) registered through GS1, our GTIN and GS1 explainer walks you through the process. Each variant, each unique combination of style, colour, and size, needs its own GTIN.
You also need to record your product name, brand name, and product type or category (e.g., “t-shirt,” “jacket,” “dress”). These fields sound basic, but they need to be structured and consistent across your catalogue, not written differently on every product listing.
Where this data lives today: Your e-commerce platform (Shopify, WooCommerce), your product spec sheets, or your GS1 account.
What “good” looks like: GTIN: 7612345678901 | Product: Classic crew-neck t-shirt | Brand: Your Brand | Category: T-shirts
Material composition
A detailed breakdown of every fibre used in your product, by percentage. Not “cotton blend”, the exact split. If the garment has multiple distinct components (a polyester shell with a cotton lining, for example), each component should be listed separately.
This is already a legal requirement under EU Regulation 1007/2011 for textile labelling. The DPP takes it digital and makes it machine-readable.
Where this data lives today: Your tech packs, fabric supplier spec sheets, or mill test certificates.
What “good” looks like: Main fabric: 95% organic cotton, 5% elastane | Lining: 100% recycled polyester | Ribbing: 97% cotton, 3% elastane
Common mistakes to avoid: Listing composition for the “main fabric” only and forgetting linings, trims, or elastic components. Rounding percentages so they don’t add up to 100%. Using vague terms like “other fibres” instead of naming them.
Care instructions
Washing temperature, drying method, ironing guidance, bleaching restrictions, and professional care instructions. You already have these on your garment labels. For the DPP, they need to be in a structured digital format, not a photograph of your care label, but actual data fields.
Where this data lives today: Your care labels, product listings, and tech packs.
What “good” looks like: Machine wash: 30°C | Do not tumble dry | Iron: low temperature | Do not bleach | Professional dry clean: perchloroethylene
Substances of concern (SVHC declaration)
Under REACH regulation, brands must declare whether their products contain any Substances of Very High Concern above 0.1% by weight. This isn’t a new requirement, it’s an existing legal obligation. The DPP makes it visible and auditable.
For most garments made with standard materials from reputable suppliers, the answer is straightforward: no SVHCs above the threshold. But you need documentary evidence, not just your assumption. Request an SVHC compliance statement from your fabric and trim suppliers, our guide on getting data from reluctant suppliers can help if they push back.
Note that the scope of “substances of concern” under the ESPR is broader than just the REACH SVHC list. Over 4,600 substances currently fall within the ESPR definition, and this number is expected to grow as new hazard categories (endocrine disruptors, PFAS) take effect. For now, a REACH SVHC statement is the minimum baseline.
Where this data lives today: Supplier quality documentation, OEKO-TEX certificates, or test reports.
What “good” looks like: A written statement from your fabric supplier confirming REACH SVHC compliance, ideally with a reference to the candidate list version date.
Economic operator identification
The name, trade name, postal address, and contact details of the entity that places the product on the EU market. This might be your brand, your EU-based distributor, or your importer. The DPP needs to clearly identify who is legally responsible.
Where this data lives today: Your business registration documents and company contact information.
Country of manufacturing
The country where the finished garment was assembled. Not “Made in EU”, the specific country. If your products are made across multiple countries, each product’s DPP should reflect the correct one.
Where this data lives today: Your production records, purchase orders, and supplier agreements.
Tier 2, Prepare the infrastructure
Recycled content
The percentage of recycled materials used in the product, by weight or by fibre type. If your t-shirt uses 30% recycled polyester and 70% conventional cotton, that breakdown needs to be recorded.
The methodology for calculating and verifying recycled content hasn’t been finalised yet. For now, collect whatever data your suppliers can provide and note whether it’s based on supplier declaration, certification (e.g., Global Recycled Standard), or mass balance.
Action now: Ask suppliers whether the fibres they provide contain recycled content, and at what percentage. Record their responses even if they’re approximate.
Environmental impact indicators
Carbon footprint per product (in kg CO2 equivalent), water consumption, and potentially a Product Environmental Footprint (PEF) score. The exact calculation methodology is the biggest open question in the textile DPP, the delegated act might require a simplified approach, a full PEF assessment, or something aligned with the French Ecobalyse framework.
Action now: Don’t commission expensive LCA studies until the methodology is confirmed, see our LCA for fashion DPP overview for what’s expected. Instead, ensure you have the underlying data that any methodology would need: product weight, material composition, manufacturing locations per production stage, and transport distances. If your DPP platform offers built-in LCA estimation, use it for a baseline, but don’t treat the numbers as final.
Durability information
How long the product is designed to last, its resistance to pilling, colour fastness, dimensional stability, and seam strength. These metrics are well-established in textile testing standards (ISO and EN norms) but haven’t historically been consumer-facing.
Action now: If you commission fabric testing as part of your quality control process, you likely already have some of this data. Check your fabric test reports for pilling resistance, colour fastness, and tensile strength results. If you don’t do formal testing, this can wait until the delegated act specifies what’s required.
Supply chain traceability
Manufacturing locations for each production stage, not just final assembly, but where the fabric was woven, where it was dyed, where the yarn was spun. The depth of traceability required is still being debated, but the direction is clearly toward multi-tier disclosure.
Action now: Map your Tier 1 and Tier 2 suppliers with names, locations, and processing stages. Our supply chain mapping guide walks you through this in detail.
Recyclability and end-of-life guidance
Whether the product can be recycled, through which stream, and what the consumer should do when they’re done with it. Mono-material garments (100% cotton, 100% polyester) are generally recyclable through textile recycling streams. Blended fabrics are more challenging.
Action now: Assess your product range and note which items are mono-material vs. blended. Write a clear end-of-life statement for each product type. If you offer a take-back programme, document it.
Tier 3, Monitor, don’t invest yet
Full PEF scoring
A comprehensive Product Environmental Footprint score covering 16 impact categories (climate change, water use, ecotoxicity, land use, and more). This is technically demanding and expensive to calculate properly. It may appear in a later DPP phase (around 2030) rather than the first wave.
Repairability scoring
A structured rating of how repairable the garment is, availability of spare parts, access to repair instructions, ease of disassembly. The EU has introduced repairability scoring for electronics, and a similar framework for textiles has been discussed, but the specifics are far from finalised.
Microplastic shedding data
Data on microfibre release during washing. This is referenced in the EU’s broader textile strategy, and the preparatory study has examined it, but whether it becomes a mandatory DPP field in the first phase is uncertain.
Social and labour data
Worker conditions, wages, and labour certifications at manufacturing facilities. While this data is critically important and is the focus of the EU Forced Labour Regulation (applicable from December 2027), it’s not yet clear whether it will be embedded in the DPP data model or handled through a separate compliance mechanism.
Who sees what: the three access levels
Not all DPP data is public. The ESPR mandates three access levels, and understanding them is important for protecting sensitive commercial information.
Public access. Visible to anyone who scans the QR code. This includes consumers, media, NGOs, and anyone else. Product identification, material composition, care instructions, and environmental data will be in this category.
Restricted access (authorised stakeholders). Visible to regulators, market surveillance authorities, and recyclers, but not to the general public. Detailed supply chain information and chemical compliance data are likely to sit here.
Controlled access (notified bodies). Visible only to specifically authorised entities for enforcement purposes. Sensitive commercial data like specific formulations or proprietary processes might be at this level.
The practical implication: you won’t be forced to publish your supplier names on a consumer-facing passport page unless you choose to. But you will need to have that data available for regulatory verification if requested.
A DPP data requirements checklist
Use this as a working document. For each product in your catalogue, check off what you already have and identify what you’re missing.
Tier 1 (collect now):
- GTIN assigned (one per variant)
- Product name and brand name in consistent format
- Material composition with exact percentages per component
- Care instructions in structured format
- SVHC/REACH compliance statement from suppliers
- Economic operator name and contact details
- Country of final garment assembly
Tier 2 (prepare infrastructure):
- Recycled content percentage (if applicable)
- Product weight
- Manufacturing locations per production stage (Tier 1 and Tier 2 suppliers)
- Fabric test results (pilling, colour fastness, tensile strength) if available
- End-of-life and recyclability statement
- Transport distances (rough estimates for LCA input)
Tier 3 (monitor only):
- Full PEF environmental scoring
- Repairability assessment
- Microfibre shedding data
- Social/labour compliance data at facility level
Most brands find they already have 60–70% of Tier 1 covered. The remaining gaps are usually SVHC statements from suppliers (one email to fix) and properly assigned GTINs (one registration to complete). That’s not a mountain. That’s a weekend.
The most important principle: honest data beats perfect data
If there’s one thing to take away from this guide, it’s this: you don’t need perfect data to publish a useful, compliant DPP. You need honest data.
A passport that says “95% organic cotton, 5% elastane, manufactured in Portugal, REACH compliant, no LCA data available yet” is infinitely more valuable, legally and commercially, than one that either fabricates data or sits unpublished because you’re waiting for everything to be perfect.
The DPP is designed to evolve. Your first passport will have gaps. That’s expected. What matters is that you start, that you’re truthful about what you know and what you don’t, and that you build a system for improving your data over time. When you’re ready, our step-by-step DPP creation guide picks up right where this article leaves off.
See what structured product data looks like in a live DPP.
Ready to audit your data?
Frequently asked questions
Will I get fined for having incomplete data in my DPP?
The enforcement regime will depend on the final delegated act and how EU Member States implement it. In the first phase, the regulatory focus is likely to be on ensuring DPPs exist and contain the core mandatory fields rather than on penalising minor data gaps. That said, publishing false or misleading data is a very different matter, accuracy is more important than completeness. An honest gap is far better than a fabricated number.
Do I need to recollect all my data if the delegated act changes the requirements?
Not necessarily. The Tier 1 data fields (material composition, product identification, care instructions, SVHC compliance) are converged across all authoritative sources and are very unlikely to change. Tier 2 fields might see adjustments to methodology or format, but the underlying data (product weight, supplier locations, recycled content) remains the same. The risk of “wasted work” is low if you focus on collecting factual product information rather than investing in specific reporting frameworks.
My supplier gives me fabric composition as a range (“50–55% cotton”). Is that acceptable?
For a DPP, you need a fixed number, not a range. Fabric composition naturally varies slightly between production batches, but the data in your passport should reflect the intended composition based on the fabric specification. Ask your supplier for the target composition from their spec sheet (e.g., “52% cotton, 48% polyester”) rather than a test-result range.
What counts as “recycled content”, pre-consumer or post-consumer?
Both can count, but they should be distinguished. Pre-consumer recycled content (factory offcuts reprocessed into fibre) and post-consumer recycled content (garments or bottles collected and reprocessed) have different environmental implications. The delegated act is expected to require brands to specify the type and proportion of recycled content. For now, record what your supplier tells you and note whether it’s pre-consumer, post-consumer, or a mix.
Do trims and hardware (buttons, zippers) need their own composition data?
For the main DPP fields, trims are typically included as part of the overall product composition. A metal zipper on a cotton jacket doesn’t need its own data row, but the jacket’s material composition should note “zinc alloy zipper” or similar. Where trims become more important is in the SVHC declaration, metal components, plastic coatings, and nickel-plated hardware may contain substances of concern that need to be assessed. Start by noting what materials your trims are made of and where they’re sourced.
I sell the same fabric across multiple products. Do I re-enter the data for each?
No, this is where a DPP platform with a material library saves significant time. You enter your fabric data once (composition, supplier, certifications) and link it to every product that uses it. When a fabric changes or a certification is updated, you update it in one place and it propagates across all linked products. If you’re managing this in spreadsheets, you’ll end up with inconsistencies. A proper platform eliminates that risk.
This guide reflects expected DPP requirements as of April 2026. Exact data fields will be confirmed in the textile delegated act. Stay informed.
This article has been reviewed for accuracy by the Wetrack team.
Some illustrations may be AI-generated in which case they are labeled. Report any issue.