Your product category doesn't have a delegated act yet. Textiles: expected 2027. Furniture: 2028. That's not a reason to wait – it's a reason to start now with what's already known. Here is exactly what to collect from your suppliers, and where to find it.
The honest answer: earlier than the delegated act.
Here's the maths. Once a delegated act is published for your product category, you get 18 months to comply. That sounds reasonable. But those 18 months are for building and registering your Digital Product Passport – not for collecting the underlying data. Data collection from suppliers takes 6 to 12 months on its own, sometimes longer if your supply chain has more than one tier.
Put those together and the picture changes. If the textile delegated act comes in mid-2027 and compliance is required by end of 2028, a brand that starts data collection in mid-2027 is already six months behind where they need to be.
The brands that will meet their compliance date without a crisis are the ones that started collecting data before the act arrived. Not because they had a crystal ball – because a significant portion of what every DPP will require is already defined in EU law.
More than most brands realise – and it's already written down.
ESPR (Regulation (EU) 2024/1781), Article 9 and Annex III define categories of information that Digital Product Passports must contain. These apply to all product categories covered by the regulation – not just those with a delegated act already in place. The delegated act for your category will add product-specific fields on top of this base. It will not replace it.
The clearest proof of this is the Battery Passport, the only fully adopted DPP in EU law today, mandated under Regulation (EU) 2023/1542 from 18 February 2027. Based on a comparison of Battery Regulation data requirements with ESPR Annex III categories, the majority of Battery Passport fields map directly to what ESPR defines for all products: manufacturer identity, material composition, substances of concern, recycled content, carbon footprint where required by sector, and end-of-life instructions. The remaining fields are battery-specific – state of health, charge cycles, chemistry type. That category-specific layer is exactly what your delegated act will define for textiles, furniture, or whatever your category is.
This means the base is knowable now. The JRC methodology report JRC145830, published March 2026, confirms this structure: data requirements for DPPs divide into elements that follow from ESPR itself, and elements that will be specified category by category. Brands that collect the ESPR-level base today are not doing speculative work. They are doing the work that would be required regardless.
Seven things. All of them follow from ESPR Annex III. None of them require a delegated act to justify asking.
The company that physically made the product – not your brand name, not your trading name. This needs to be the legal entity. It is on every invoice, certificate of conformity, and customs declaration your supplier has ever issued.
Where the product was physically produced. For a garment assembled in Portugal from Turkish fabric, the answer is Portugal. Already on most product labels and in all shipping documentation.
What the product is made of, expressed as percentages. For a cotton-polyester shirt: 60% cotton, 40% polyester. For an upholstered chair: beech frame, polyester foam, linen cover – with percentages for each. Your supplier has this. It is part of their own production documentation and, if they sell to EU retailers, they've almost certainly provided it before.
Whether the product contains any chemicals from the REACH regulation Substances of Very High Concern (SVHC) list at concentrations above 0.1% by weight. A simple yes or no, with substance names where applicable. Any supplier already selling into the EU market is required to know this.
What share of the materials came from recycled sources. The answer may be zero – that's a valid answer and needs no further documentation. But it needs to be a stated, verifiable zero, not an unknown.
If your supplier already holds any third-party certificates for their materials – laboratory test reports, sustainability standards, or verified recycled content schemes – ask for copies. These documents often cover fields 4 and 5 at once, and a verified certificate carries more weight than a supplier's own declaration.
How the product should be disposed of, recycled, or disassembled at the end of its life. For most products this already exists in some form – on labels, in packaging inserts, in product documentation. What's needed for DPP is a structured, text-based version that a system can read.
How long the product is designed to last under normal use. Usually stated in warranty terms or product specifications. If your supplier has no answer, that conversation is worth having independently of DPP – expected lifetime is increasingly relevant under the broader ESPR ecodesign framework.
These seven fields won't build a complete DPP. But they are the foundation every DPP will need, and they are fields your supplier can provide without waiting for any regulatory text.
For independent brands starting to organise this data, {ZeroBox} gives you a structured place to collect and store it by product – with a GS1 Digital Link QR code that's ready to connect to a full DPP when your delegated act arrives. Start free at zero.flxy.io
The category-specific layer – and it's real work, but it builds on what you've already collected.
For textiles, the delegated act is expected to add: fibre composition in full detail, care and washing instructions in machine-readable format, microplastic release data, and repairability information including whether spare parts or repair services are available. Our textile DPP data fields guide covers what's expected in more detail.
For furniture: disassembly instructions, chemical composition of surface treatments and coatings, wood certification data where applicable.
For iron and steel (delegated act expected 2026 under the ESPR Working Plan COM(2025)187 final): recycled scrap content per heat, carbon intensity data, production route information.
None of this can be collected today with certainty because the exact field definitions aren't finalised. What can be done is identifying which suppliers will need to provide this data and starting that conversation – so that when the act arrives, you're not introducing yourself to a factory contact for the first time under deadline pressure.
One product. Seven fields. This week.
Take the simplest product in your range – fewest components, clearest supply chain, most straightforward composition. Work through the seven fields above. Check what you already have, what needs to be requested, and what is genuinely unknown.
If you've already done the exercise in our DPP readiness guide, you know which products have data gaps. This list tells you specifically what those gaps are and what to ask for.
The point isn't to produce a DPP this week. It's to find out now – not under deadline pressure – where your actual preparation stands. Most brands discover they already have more than they thought. Some discover supplier relationships that need attention before any compliance date forces the issue.
Either way, knowing is better than waiting.
If you'd like help mapping your product category against what's already required – and what's coming – book a free consultation with the Fluxy.One team. Book a free consultation
Coming up next: packaging has its own data layer. Under PPWR (Regulation (EU) 2025/40), every packaging unit placed on the EU market will carry a data carrier with recyclability, material composition, and reuse information – and that data can sit inside the same DPP infrastructure as your product data. In the next article we'll break down exactly which packaging data fields PPWR requires and how they connect to your DPP. Follow us on LinkedIn to get it first, or bookmark the Fluxy.One blog for the full series.
EU product regulations continue to develop through delegated acts and implementing measures. Data requirements discussed in this article follow from ESPR Annex III (Regulation (EU) 2024/1781) and the Battery Regulation (EU) 2023/1542 as the only fully adopted DPP framework in EU law. Category-specific fields will be confirmed when delegated acts for each product group are adopted. This article is for orientation, not legal advice. Fluxy.One is an EU Digital Product Passport platform for manufacturers, importers and exporters. {ZeroBox} is Fluxy.One's entry-level solution for independent European brands.
Fluxy.One — the transparency infrastructure for the global economy.
Book Free Demo
Privacy is important to us, so you have the option of disabling certain types of storage that may not be necessary for the basic functioning of the website. Blocking categories may impact your experience on the website. More information
Privacy is important to us, so you have the option of disabling certain types of storage that may not be necessary for the basic functioning of the website. Blocking categories may impact your experience on the website. More information
