What Data Must a Digital Product Passport Contain? Complete Data Requirements Guide

A Digital Product Passport (DPP) must contain structured data across multiple categories, from product identifiers to end-of-life handling. The exact blocks and number of attributes are specific to each product category and defined by its delegated act, but most categories share a similar set of data themes.

The Real Challenge: Most of This Data Sits With Your Suppliers

Before looking at what data is required, it helps to understand where it actually comes from. Very little of a DPP's data originates inside the brand or manufacturer placing the product on the market. Material composition, substance declarations, carbon footprint inputs, and traceability records mostly live with Tier 1 suppliers, and increasingly with Tier 2 and Tier 3 suppliers further upstream, who may have never been asked to report this kind of data before.

This is the main practical obstacle to DPP compliance: not knowing which data is required, but retrieving it from a multi-tier supply chain where formats, systems, and reporting maturity vary supplier by supplier, then making that data interoperable so it can flow into a single, structured DPP record. A brand can define its data model perfectly and still be blocked for months waiting on a Tier 2 supplier's material declaration in a usable format. Supplier onboarding, data standardization, and interoperability tooling are therefore just as important to a DPP project as understanding the attribute list itself.

The Core Data Blocks

Regardless of product category, DPP data breaks down into recurring blocks. The number of specific attributes in each varies depending on your product and whether its delegated act is finalized or still in draft.

Identifiers & DPP Information

The foundation layer. Every other data point is linked back to this record.

• Unique product identifier (GTIN, serial number, or batch/lot number)

• DPP record ID and registry reference

• Economic operator identifiers (manufacturer, importer)

Product Data & General Information

• Product model, category, and classification codes

• Place and date of manufacture

• Technical documentation references

Material Composition & Substances

• Bill of materials, including origin of critical raw materials, usually sourced from Tier 1 and Tier 2 suppliers

• Presence of substances of concern (linked to the SCIP database)

• Recycled content percentage

Environmental Footprint

• Product Carbon Footprint (PCF) and lifecycle assessment (LCA) data

• Energy and resource consumption during use

Durability & Performance Scores

Product-specific durability metrics, defined per category. For textiles, this includes robustness scores like washing resistance; for other categories, equivalents may cover mechanical durability or capacity retention.

• Robustness / durability score

• Recyclability score

Circularity & End-of-Life

• Disassembly instructions

• End-of-life handling and recycling guidance

• Repairability information and spare parts availability

Supply Chain & Traceability

• Supply chain actor identifiers, across Tier 1, Tier 2, and where relevant Tier 3

• Traceability records across production stages

• Due diligence documentation

Care, Use & Labelling

• Care instructions

• Labelling requirements

Conformity & Testing

• Compliance certifications and test reports

Product-Specific Data

Additional attributes required for particular product categories, defined by their delegated act.

Data Requirements Vary by Product Category and Delegated Act Status

Product category

Status

Notes

Batteries

Delegated act finalized under Regulation (EU) 2023/1542, applies from 18 February 2027

79 mandatory attributes across 7 blocks, plus 7 voluntary attributes

Textiles (Apparel/Garments)

Delegated act still in development under Regulation (EU) 2024/1781 (ESPR)

56 attributes across 12 blocks, based on current draft proposals (Pre-DA estimation)

Digital Product Passport requirements more broadly are established under the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, which sets out DPP provisions in its Articles 9 to 15. Battery-specific requirements instead fall under the separate Regulation (EU) 2023/1542 on batteries and waste batteries. Each product category's exact attribute list is set through its own delegated act adopted under these frameworks, not in the framework regulations themselves.

Where Each Block Typically Comes From

Mapping data blocks to the systems and roles that usually hold them helps identify who to involve early in a DPP project.

Data block

Typical source system

Usually owned by

Identifiers & DPP information

ERP, master data management

IT / digital transformation

Product data & general information

PIM

Product management

Material composition & substances

PLM, supplier declarations (Tier 1/2)

Supply chain / sourcing

Environmental footprint

LCA software, sustainability platforms

ESG / sustainability manager

Durability & performance

QMS, lab test reports

Quality / R&D

Circularity & end-of-life

PLM, design documentation

Product design

Supply chain & traceability

Supplier portals, ERP

Supply chain / procurement

Care, use & labelling

PIM, packaging specs

Product management

Conformity & testing

QMS, certification bodies

Legal / compliance officer

Mandatory vs Voluntary Data: Why Voluntary Still Matters

Every category includes a Voluntary block, informational only and not counted toward the compliance or completeness score. It is tempting to skip it entirely, but voluntary data serves two practical purposes. First, it lets brands differentiate on sustainability credentials beyond the legal minimum, which matters to B2B buyers and retailers increasingly screening suppliers on more than bare compliance. Second, categories still awaiting a finalized delegated act, like textiles, tend to see voluntary attributes migrate into mandatory ones once the act is adopted. Collecting them early avoids a scramble later.

Common Mistakes to Avoid

• Treating the textile Pre-DA estimation as final. The attribute list is based on current draft proposals and can still change before the delegated act is adopted.

• Confusing mandatory and voluntary attributes when reporting a completeness score internally, which overstates or understates real readiness.

• Assuming one product category's block structure applies to another. Batteries and textiles already show meaningfully different blocks and attribute counts; treat each category's requirements as its own list.

• Starting data collection at the brand level only, without engaging Tier 1 and Tier 2 suppliers early, which is consistently the longest lead-time item in a DPP project.

Not Sure Which Attributes Apply to You?

Because the blocks and attribute counts are specific to your product category and how far along its delegated act is, mapping your own data against the requirements can be time-consuming. DPP Pro's Data Readiness Assessment tool walks through the actual blocks for your category, attribute by attribute, and scores what you already have versus what's missing.

Currently available:

• EV Batteries: full assessment against the finalized delegated act (79 mandatory attributes across 7 blocks, plus voluntary)

• Textiles (Apparel): a Pre-DA estimation based on current draft proposals under ESPR 2024/1781 (56 attributes across 12 blocks), since the textile delegated act has not yet been finalized

More product categories will be added to the assessment as their delegated acts progress.

If you specifically need textile data requirements in depth, including JRC-sourced attribute detail, see our dedicated Fashion & Textile DPP Data Requirements Guide.

How to Use This Checklist

Start by taking stock of what data you already have in existing systems (ERP, PLM, PIM), block by block, using the ownership table above to identify who to involve. Then run the Data Readiness Assessment for your category to get a completion score, and prioritize the blocks with the most missing attributes, and the suppliers most likely to hold them, ahead of your category's delegated act deadline.