The Digital Product Passport (DPP) for textiles is a mandatory, digital container under the EU Ecodesign for Sustainable Products Regulation (ESPR), effective for textiles by 2028. This guide explains:
- What DPP is and how to calculate how many you need;
- The essential difference between DPP requirements for finished products and raw materials;
- The mandatory data your DPP must include (Data Matrix);
- The critical role and responsibilities of the certified DPP Operator;
- A practical compliance checklist for your business;
- Why Fluxy.One is the go-to solution for fast, compliant DPP deployment.
1. How Many DPPs Do You Need?
- Model-Level DPP: One DPP per unique product variant identified by GTIN (Global Trade Item Number). Variants consider model, size, and color.
- Batch/Lot-Level: For finished products, batch/lot information is not a separate DPP. Batch data appears in commercial and customs documentation (packing list, invoices) but references the same model-level DPP.
- Item-Level: Individual item tracking (e.g., RFID, serialized units) is reserved for advanced phases post-2030 and is not currently mandatory.
Example:
A T-shirt line with 3 sizes and 4 colors = 12 DPPs (one per SKU), regardless of how many batches are produced.
2. Raw Materials: Mandatory DPP + LOT
Raw materials (fibers, chemicals, components) are subject to stricter traceability:
- Each batch/lot of raw material must have a unique DPP linked to both the GTIN and the specific batch/lot number.
- This is because chemical composition, compliance certificates (REACH, hazard substances) may differ between batches.
- Customs and regulators require batch-level verification for raw materials, unlike finished goods.
Example:
Cotton fiber batch LOT-001 from India may differ chemically from LOT-002 imported from Pakistan, each requiring a distinct DPP.
3. Mandatory Data in Your DPP — The Data Matrix
| Category | Required Data |
|---|
| Product Identification | GTIN, product/model name, manufacturer info, manufacturing date & place, country of origin, importer details |
| Material Composition | Fiber types & percentages, chemical additives (CAS), recycled and virgin content percentages, hazardous substances |
| Supply Chain | Supplier/factory IDs and locations, environmental certifications (ISO 14001, etc.), production & transport data |
| Environmental Impact | Carbon footprint (cradle-to-gate), water use, recyclability score, hazardous content summary, methodology used (PEF, ISO) |
| Social Compliance | Due diligence statements, labor certifications (SA8000, SMETA), living wage records, child labor declarations, conflict minerals |
| Performance & Safety | Technical specs, test certificates, care instructions, packaging info, end-of-life guidance, chemical safety sheets (SDS) |
| Batch-Specific | Batch/lot number, production and import dates, batch certifications, supplier confirmations, quality audits |
Incomplete or missing data may lead to border delays or shipment refusal.
4. The Role and Obligations of the DPP Operator
The DPP operator is a licensed, certified entity responsible for:
- Secure, GDPR-compliant hosting of all DPP data for the product lifecycle plus at least 10 years after;
- Geo-redundant storage and scheduled backups within the EU jurisdiction;
- Integration with the EU centralized DPP Registry, enabling real-time access for regulators and supply chain actors;
- Maintaining data integrity via encryption, digital signatures, audit logs, and protection against cyber threats;
- Ensuring business continuity and data portability, allowing migration to another operator without data loss;
- Legal accountability: failure to provide accessible, complete DPP results in automatic product blocking at EU borders or markets.
5. Batch Handling across the Supply Chain
- For finished goods: QR codes link to model-level DPP only; batch info is recorded in documents accompanying each shipment.
- For raw materials: Every batch (GTIN + LOT) requires individual DPP creation, test certificates, and compliance declarations.
- Customs scan QR to retrieve model DPP; batch data is verified via documented batch numbers on invoices and packing lists.
6. Responsibility Matrix
| Role | Responsibilities |
|---|
| Manufacturer | Provide accurate product and material data and certifications |
| Exporter | Collect & verify supplier data; create DPPs; assign batch IDs; manage export docs and QR codes |
| Importer | Verify DPP and batch info on arrival; maintain traceability; respond to regulatory checks |
7. Compliance Action Checklist
- [ ] Count SKUs, colors, sizes & annual batch volumes.
- [ ] Register GTINs through your GS1 national authority.
- [ ] Build a supplier and production site master list including certifications.
- [ ] Collect data requests and confirm supplier compliance (use timestamped verifications).
- [ ] Audit data completeness using the Data Matrix.
- [ ] Verify batch-record policies meet DPP and customs requirements.
- [ ] Select a certified, EU-compliant DPP operator.
- [ ] Launch a pilot on a sample set of SKUs and batches.
- [ ] Ensure all products and batches bear compliant QR codes.
- [ ] Test integration and compliance with customs and the EU DPP Registry.
- [ ] Train relevant teams (logistics, compliance, sales) on DPP workflows.
- [ ] Retain all data and audit trails for at least 10 years.
8. Why Choose Fluxy.One?
- Designed for SMEs but scalable to large enterprises.
- AI-driven onboarding supports data from Excel, ERP, scanned documents, and emails.
- Rapid pilot deployment—DPP and QR generation in days, no heavy IT needed.
- Certified EU hosting with secure, resilient long-term backup.
- Full API integration for any ERP or supply chain system.
- Automated regulatory updates and compliance reporting.
- Seamless EU Registry integration and GS1 Digital Link compatibility.
- Audit-ready transparency, perfect for customs, retailers, and market surveillance.
9. Final Recommendations
- DPP implementation is not just regulatory compliance; it is a market enabler and competitive advantage.
- Always engage a certified operator.
- Plan early, collect accurate data, and pilot thoroughly.
- Understand your product portfolio in terms of GTINs and batches.
- Build transparency to gain consumer and regulator trust.
Launch your compliant journey today. Discover how Fluxy.One simplifies DPP compliance at Fluxy.One
References & Regulatory Links
- EU Commission, ESPR Regulation
- Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030
- GS1 Digital Product Passport Standards
This guide is based on ESPR 2024/1781 and the latest EU standards as of late 2025. Consult your legal or regulatory advisor for detailed implementation advice.
