DPP Guide — Readiness

The ESPR Readiness Checklist for Garment Factories

Twenty-five checks that decide whether a factory can publish a compliant Digital Product Passport when the textile rules under ESPR Regulation (EU) 2024/1781 apply. Each check says what it is, why it matters, and whether it is mandatory in the regulation today, expected from the textile delegated act, or a buyer requirement that arrives through the purchase order first.

Written by the DPPLive Team · Last updated: 19 October 2026

The 25 Checks

Six areas, twenty-five checks

Status legend: MANDATORY is written in EU law today (ESPR duties apply to garments once the textile delegated act does) · EXPECTED is likely in the textile delegated act, based on the JRC preparatory work and ESPR Annexes I and III · BUYER is not in ESPR but arrives through purchase orders and audits — usually before the law does.

Check	Status	Legal basis	What passing looks like
1 · GTIN for every exported style	EXPECTED	ESPR Art. 10(1)(a) (a unique product identifier); Annex III(c) names the GTIN; GS1 Digital Link	The passport needs a persistent unique product identifier, and a GS1 GTIN per style is the identifier most EU buyers will ask for. Register with GS1 Bangladesh (or your national GS1 member organisation).
2 · Unique Product Identifier (UPID)	MANDATORY	ESPR Arts. 10 & 12	Generated per model, batch or item by your DPP platform. Decide the granularity now — see model vs batch vs item level.
3 · Economic operator identifier (EOID)	EXPECTED	ESPR Art. 12; Annex III (where the delegated act requires it)	The legal entity behind the passport. Your trade licence, BIN/TIN and address must match what the platform submits to the EU registry.
4 · Facility identifier	EXPECTED	ESPR Art. 12; Annex III (where the delegated act requires it)	Each production site that appears in a passport needs its own identifier. Factories with several units or a wash plant need one per site.
5 · Registry submission path	MANDATORY	ESPR Art. 13; Reg. (EU) 2026/1778	The Commission’s central registry has been live since 20 July 2026. Know who submits your identifiers — you, the brand, or your DPP provider — and keep the receipts. Submission guide →
6 · Exact fibre composition per style	MANDATORY	Textile Labelling Reg. (EU) 1007/2011 (already law); expected in the passport	Percentages, not descriptions. “Mostly cotton” fails; “95% cotton / 5% elastane” from the mill’s test report passes.
7 · Product specifications stored digitally	EXPECTED	JRC textile preparatory work; Annex I parameters	Weight, dimensions, size range, construction — in one record per style, not spread across tech packs and email.
8 · Care instructions (ISO 3758 symbols)	EXPECTED	JRC textile preparatory work	Not required EU-wide (unlike fibre content), but buyers expect them and some member states may require them; the passport is likely to carry them as structured data.
9 · Recycled content backed by a certificate	EXPECTED	JRC textile preparatory work; GRS / RCS chain of custody	Any recycled-content claim in a passport needs a transaction certificate. Collect them per lot from yarn and fabric suppliers.
10 · Substances of concern disclosure	MANDATORY	ESPR Art. 7(5); REACH Art. 33 (SVHC > 0.1%)	A declaration from every dye house, printer and chemical supplier covering the substances of concern ESPR defines (Art. 2(27): SVHCs on the ECHA Candidate List, certain CLP hazard classes, POPs and substances that hinder recycling), with name or CAS/EC number, location in the product and concentration (Art. 7(5)). The delegated act may set thresholds. DPP vs SCIP →
11 · Chemical purchasing to a ZDHC MRSL	BUYER	Brand chemical policies; feeds Art. 7(5) disclosure	Wet-process chemistry is the first thing EU brands screen. Require ZDHC Level 1+ certificates from chemical vendors.
12 · Certificates current and digitised	BUYER	OEKO-TEX, GOTS, GRS, ISO — buyer codes of conduct	Expired certificates are the most common audit failure that is also the easiest to prevent. Keep PDFs and expiry dates in one register. Certifications & the DPP →
13 · Lab test reports filed per style	BUYER	Buyer testing protocols; evidence for checks 6 and 10	Composition, colourfastness and restricted-substance reports are the evidence behind the passport. File them where the passport can link to them.
14 · Twelve-month energy baseline	EXPECTED	Annex I parameter (carbon footprint); Higg FEM Energy & GHG	Electricity, gas, diesel and captive generation for the last 12 months, by meter. This cannot be reconstructed later — start logging now.
15 · Product carbon footprint method	EXPECTED	Annex I; ISO 14067 / PEF apparel & footwear	Convert the baseline into kg CO₂e per garment with a declared method and the Bangladesh grid factor. Carbon footprint guide →
16 · Water use per unit or per order	EXPECTED	Annex I parameter; Higg FEM Water	Sub-meters on dyeing, washing and finishing; monthly figures against output.
17 · ETP operating and discharge logged	BUYER	DoE environmental clearance; buyer codes; Higg FEM Wastewater	pH, COD, BOD monthly, test reports filed. Baseline expectation in every EU brand code of conduct.
18 · Tier-1 supplier list documented	EXPECTED	JRC textile preparatory work (supply-chain information); buyer due diligence	Name, address and contact for every direct fabric and trim vendor. The minimum traceability layer.
19 · Tier-2 traceability for main lines	BUYER	Forced Labour Reg. (EU) 2024/3015 (applies 14 Dec 2027); CSDDD	Ask Tier-1 suppliers to disclose their spinners and mills for your best-selling styles first.
20 · Subcontractor register, disclosed	BUYER	Buyer codes of conduct; social audit protocols	Undisclosed subcontracting is the single most common audit failure in garment supply chains. Keep a register and disclose it proactively.
21 · Social audit current	BUYER	Sedex SMETA, amfori BSCI, WRAP — buyer requirement	Renew before the buyer asks. Current audit reports slot into the passport’s supply-chain section.
22 · Named DPP owner	BUYER	Governance — not in ESPR, but the most common reason passport projects stall	One person with authority to pull data from merchandising, production, stores and the wash plant.
23 · Production and order data in software	BUYER	Governance; feeds every data check above	Structured spreadsheets beat paper; an ERP or a DPP platform beats both. Digital records fill a passport in minutes.
24 · A DPP platform: data carrier, back-up copy, long-term availability	MANDATORY	ESPR Arts. 9(2)(i), 10(1)(a)–(b), 10(4), 11(e) and (g)	A data carrier (in practice a QR code) linked to a persistent unique product identifier; a back-up copy with a DPP service provider; the passport available for at least the product’s expected lifetime, also after insolvency; data integrity ensured. Version history is the usual way to show integrity, though ESPR does not name it. Build or buy — the comparison →
25 · Unsold-goods disclosure process	MANDATORY	ESPR Arts. 24–25 (destruction ban applies to large enterprises since 19 July 2026)	Applies to the brand, but stock destroyed or returned at factory level is what they will ask about. Log what happens to cancelled and rejected lots.

Reading Your Result

What the count tells you

20–25 passing

Publish-ready

You can create complete passports for your current styles today. Remaining work is fine-tuning: Tier-2 depth, carbon method documentation, faster certificate renewal. Run a pilot on one buyer programme and let the QR do the selling.

On track

12–19 passing

Building blocks in place

You have the identifiers and product data but usually miss the long-lead items — energy baseline, SVHC declarations, Tier-2. Start those this quarter; they take months and cannot be bought later.

Partial readiness

Under 12 passing

Start with the identifiers

Most factories begin here. Get GTINs, name a DPP owner, and put styles into one digital register. That alone moves six checks in a month and makes every later step cheaper.

Significant gaps

Dates That Drive the Checklist

Why now

19–20 July 2026

Registry live · destruction ban applies

The central EU DPP registry launched on 20 July 2026 (Art. 13 deadline 19 July) and the ban on destroying unsold apparel, clothing accessories and footwear has applied to large enterprises since 19 July 2026. Check 25 already binds large buyers; check 5 starts once the textile delegated act applies.

Done

2027

Textile delegated act expected

The act that turns “expected” into “mandatory” for apparel. The JRC preparatory work keeps the Annex I parameters used in checks 7–9 and 14–18.

Expected

14 December 2027

EU Forced Labour Regulation applies

Regulation (EU) 2024/3015 lets authorities stop products made with forced labour at the border. Importers will demand Tier-2 and Tier-3 traceability (checks 18–20) well before this date.

Firm date

2028–29

Textile DPP obligations expected to apply

Passports become a condition of sale for apparel placed on the EU market. Buyers are writing the requirement into 2027 contracts.

Expected

A common mistake is to treat the checklist as a single project with a single deadline. It is three projects with different clocks. The identifier and platform work (checks 1–5, 22–24) takes weeks and should be done first because everything else hangs from it. The documentation work (6–13, 20–21) takes a quarter of steady collection from suppliers. The measurement work (14–17) takes a full year, because a carbon footprint needs twelve months of meter data and there is no shortcut.

Factories that are already reporting Higg FEM to their buyers have most of the measurement work done; the numbers only need to be mapped to passport fields. Factories that are not should treat FEM and the passport as one data programme rather than two — the same energy, water and chemical records feed both.

Want the count for your own factory? The free assessment asks the same questions and gives you a scored dashboard, a category breakdown and a gap report — in English, Bangla, Vietnamese or Chinese. No signup needed.

Run the free readiness assessment

Checklist FAQ

Questions factories ask

Is this checklist the same as the free readiness assessment?

They cover the same ground. The assessment asks 20 yes / partially / no questions and turns your answers into a score, a category breakdown and a gap report. This page is the reference version: every check with its legal basis, so you can hand it to a merchandiser or a compliance officer and work through it line by line.

Which checks block publishing, and which only lower a score?

In law, no field blocks a garment passport yet: the textile delegated act will set the list. DPPLive’s own publish check already requires the GTIN (check 1), the operator and facility IDs (3–4), the exact fibre composition (6), care instructions (8), the SVHC declaration (part of check 10) and the carbon footprint (15), plus country of origin, recyclability, repairability and end-of-life instructions, because buyers ask for those first. Everything else lowers your readiness score and your standing with buyers, but does not stop a passport being published.

The textile delegated act is not adopted yet. Why collect “expected” data now?

Because the data with the longest lead time — a twelve-month energy baseline for the carbon footprint, Tier-2 mill disclosure, GRS transaction certificates — cannot be produced in the month a buyer asks. The parameters appear in the JRC preparatory work and in the ESPR Annex I list; the risk of collecting them is small and the cost of not having them is an order.

Do these checks apply to a factory that only sells to buying houses, not to EU brands directly?

Yes. The legal duty to make the passport available falls on the party placing the product on the EU market — usually the brand or importer — but they can only do that with data the factory holds. Buying houses are already passing the checklist down the chain; see our traceability guide for buying houses.

How does Higg FEM fit into this checklist?

Higg FEM is the environmental self-assessment most EU brands already require. Checks 14–17 (energy baseline, carbon method, water, wastewater) are the same numbers a factory reports in FEM. If you report FEM properly, the environmental part of the passport is largely done — see Higg FEM reporting for Bangladesh factories.

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