Reviewed as of 2026-07-22 · Educational · Not legal advice
What this checklist is
This is a product-ops readiness list used by the free DPP Readiness Checker. It focuses on concrete gaps — identifiers, carriers, materials data, hosting, and ownership — not digital-maturity Likert surveys.
It is not an official EU assessment and does not replace legal filing, registry registration, or counsel review. Use it to prioritise internal work, then take the interactive checker for a scored briefing.
Product-ops checklist
1. No stable unique product identifier
Without a public, durable ID scheme, a Digital Product Passport has nothing reliable to attach to.
Do next: Pick an identifier standard (e.g. GTIN now, serial/item IDs for units) and assign ownership in ops/PLM.
2. Identity stops at SKU or batch
Model/batch IDs may cover early compliance floors, but instance IDs unlock recall, authenticity, and per-unit experiences.
Do next: Plan serialization at pack-out even if your first category act starts at model level.
3. No on-product data carrier
ESPR expects a machine-readable carrier on the product, packaging, or documents that encodes the unique ID.
Do next: Choose QR, Data Matrix, and/or NFC placement that survives the product’s life; avoid carton-only as the sole link.
4. Carrier won’t survive product life
Marketing QRs or outer-carton codes often fail wash, abrasion, or post-unbox use.
Do next: Move the carrier onto a durable label or embedded tag and document reprint/reassign process.
5. Materials data isn’t structured
Composition is a baseline passport field. Conflicting tech-pack vs care-label data is a common failure mode.
Do next: Reconcile BOM % into one system of record per SKU and version it by season.
6. Recycled content lacks evidence
Claims need a method and batch-level proof — certificates in email threads don’t scale.
Do next: Link certifications (e.g. GRS/RCS) to SKUs/batches and store them where ops can retrieve them.
7. Care data isn’t reusable digitally
Care instructions should live as structured product data, not only ink on a sewn-in label.
Do next: Export care (e.g. ISO 3758-style) into PLM/PIM and expose it on the product’s digital record.
8. Origin data is incomplete
Country/facility origin is often known only for final assembly, not upstream components.
Do next: Map origin fields you can defend today; extend supplier asks for the rest by priority SKU.
9. No repair or service path for owners
Circular-use guidance helps owners and supports the “connected product” story even when a formal repair score is hard.
Do next: Publish spare-parts contacts, repair partners, or care/repair guidance on the product record.
10. Supplier attributes don’t scale
Hard DPP fields live upstream of Tier 1. Ad-hoc emails for hero styles won’t cover the line.
Do next: Add structured data asks to supplier contracts or a portal; start with top-volume SKUs.
11. No updateable hosted record
The carrier encodes an ID/URI; the record behind it must persist and accept corrections.
Do next: Host product data at a stable URL with access control — avoid season microsites that go dark.
12. EU economic operator is unclear
The placer on the EU market is accountable for DPP existence and accuracy.
Do next: Name the manufacturer, importer, or authorised representative and document the mandate.
13. No digital owner channel after sale
Not a legal DPP checkbox — but a connected passport without an owner relationship wastes the physical touchpoint.
Do next: Add registration, warranty, or care capture so taps become a reachable audience.
14. EU placement not in scope today
If you never place goods on the EU market, ESPR DPP obligations may not apply — but timelines and buyer expectations still shift.
Do next: Revisit if EU wholesale, marketplaces, or distribution partners enter the plan.
15. No named DPP owner
Passport readiness stalls when data quality and timelines have no accountable role.
Do next: Assign a named owner (ops/compliance/product) with a RACI for ID, carrier, and materials fields.
16. No backup if the DPP system fails
ESPR Art. 10(4) expects economic operators to keep passport data available — including when a service provider is down. One of None is not your legal service provider of record.
Do next: Document a failover: export/backup of passport data, alternate host, or contractual uptime with your vendor.
17. Substances / due-diligence data is thin
Battery and textile passport waves lean on substance and due-diligence evidence — not marketing material lists. No invented mandatory date here.
Do next: Map substance fields you can defend today; start supplier due-diligence asks on priority SKUs.
18. Carbon / footprint prep is missing
Product footprint asks often arrive with wholesale questionnaires before a delegated act hardens — prep beats scramble.
Do next: Pick a footprint method for hero SKUs and store results where ops can retrieve them.
Sources
Related guides
Take the free readiness check
About 4 minutes. Get a score, category timeline (confirmed vs expected), and a prioritised gap checklist.
Educational readiness check only — not legal advice. Category timelines change as delegated acts are adopted. Confirm obligations with counsel for your product group.