DPP: where you should be right now

Hey Sustainability Managers,

Let’s do some math.

You have somewhere between 200 and 500 SKUs. Let’s say it’s textiles or electronics, or furniture, the categories currently sitting at the front of the ESPR queue.

You need, for each SKU: material composition down to fiber or component level, country of origin for each material, supplier-verified data (not self-declared, verified), substances of concern screening, durability and repairability parameters and eventually a carbon or environmental footprint score.

Multiply that by 200-500 product lines, each with its own supplier mix, its own bill of materials, its own version history.

Now ask yourself honestly: how long would that take your organization, starting today, working at a realistic pace?

If your answer is “a few months,” I would like to introduce you to reality, because reality disagrees.

Let’s be precise, because precision is the entire point of this newsletter and vague timelines are how companies talk themselves into waiting.

The ESPR (Regulation (EU) 2024/1781) entered into force in July 2024. It’s the framework. It does not, by itself, tell you what data your DPP needs to contain, that comes from product-specific delegated acts, published category by category.

Here’s where things stand as of mid-2026.

Batteries are the only category with a confirmed, binding deadline: EV batteries, industrial batteries above 2 kWh, and light means of transport batteries must carry a battery passport from 18 February 2027. This is not ESPR technically, it sits under the separate Battery Regulation (EU) 2023/1542, but it’s the working blueprint for everything that follows. The lessons learned from battery passport implementations are creating the template that will inform the rollout of DPPs for textiles, electronics and other sectors.

For textiles, the delegated act is not finalized yet. The ESPR Working Plan confirms textiles as a priority with an indicative adoption date of 2027, while industry analyses anticipate a Commission proposal in late 2026 with formal adoption following shortly after. The compliance deadline itself is often phased in over 12-24 months after the delegated act is adopted, but the exact timeline for textiles remains to be determined.

What is confirmed: the revised Waste Framework Directive, in force since October 2025, requires EU Member States to establish Extended Producer Responsibility schemes for textiles and footwear within 30 months, with eco-modulated fees tied to sustainability characteristics. And the destruction ban for unsold textiles already applies to large enterprises from Q2 2026.

So even before the DPP delegated act lands, the financial and regulatory pressure is already live.

On infrastructure: the EU DPP Registry,the centralised index of Unique Product Identifiers that resolves a scanned QR code to your data, is targeted for operational launch by July 2026. This is the architecture every future DPP, regardless of category, will plug into.

I want to be honest about something most DPP content won’t tell you: the sources tracking this space disagree with each other. Some claim the textile and electronics delegated acts are already finalized and stable. Others, including the JRC’s own preparatory study process, describe them as still in development, with formal adoption expected late 2026 into 2027. I’d treat any claim of “finalized requirements” for textiles or electronics with real skepticism right now. What’s not in dispute is the direction and the infrastructure deadline.

I understand the objection.

“We don’t know the exact data fields yet. Why would we build infrastructure for requirements that might still change?”

It’s a reasonable-sounding argument. It is also, in my professional experience, almost always wrong.

The delegated act defines the exact data schema, which fields, which format, which verification level. It does not invent the underlying data from nothing. Material composition, supplier identity, country of origin, process data, substances of concern, this is the same data foundation that underpins basically every category under ESPR. Battery, textile, furniture, electronics: the universal fields overlap by 70-80%.

What changes between categories is the layer on top: specific performance metrics., category-specific thresholds, reporting granularity.

If you wait for the delegated act before starting data collection, you are not saving effort. You are deferring the hardest, slowest part of the entire project (supplier engagement and data governance) to the exact moment when your compliance clock starts running.

Ssupplier engagement is the part that breaks timelines, not the software and not the QR code generation. The actual process of getting 200-500 SKUs’ worth of suppliers to hand over verified, structured, machine-readable data.

I’ve watched this happen with battery passport implementations already. Brands that started data governance in 2024 are walking into February 2027 calmly. Brands that waited for “more clarity” are now running compressed, expensive, panic-mode projects with six-figure consultancy bills and supplier relationships under strain.

Textiles and electronics are about to relive the exact same story, on a larger scale, because the category is more fragmented and the supply chains are deeper.

Let me give you the realistic phasing, based on what I see working and failing across the clients I support.

Phase 1: data audit and gap mapping (should already be underway)

Before anything else, you need to know what you have and what you don’t. For each SKU category, map: which data exists in PLM, which exists in procurement systems, which lives in someone’s personal spreadsheet, and which doesn’t exist anywhere yet. In my experience, with 200-500 SKUs, this phase alone takes 2-3 months if you have decent internal systems and significantly longer if your product data is scattered the way most companies’ product data actually is.

Phase 2: supplier engagement and data governance (the slow part)

This is where projects die or survive. You need a structured way to request, validate, and continuously update supplier data, not a one-off questionnaire. Tier-1 suppliers are manageable. Tier-2 and beyond is where things fall apart, because most companies have never had to ask their supplier’s supplier for anything. Budget 6-9 months minimum for a first meaningful pass across 200-500 SKUs, longer if your supply base is fragmented or globally distributed.

Phase 3: pilot on a representative subset

Don’t attempt full-portfolio rollout first. Pick 10-20 SKUs that represent your typical complexity, different material types, different supplier tiers, different product categories if you sell across more than one. Run the full data flow end to end: collection, structuring, verification, data carrier generation, consumer-facing output. This tells you what breaks before you scale it across hundreds of SKUs. Realistic timeline: 6-12 weeks once Phase 2 data starts flowing.

Phase 4: scale and systems integration. Once the pilot validates the model, you scale to the full portfolio while integrating with your PLM, ERP, and compliance systems so this becomes operational infrastructure, not an annual manual exercise. This is also where you decide on a DPP platform and I’d strongly caution against choosing one before Phase 1 and 2 are underway, because you’ll choose based on assumptions instead of your actual data reality.

Add it up. For a company with 200-500 SKUs starting from a typical baseline, meaning decent but fragmented product data, no formal supplier data governance process, you are looking at 12-18 months to reach genuine operational readiness. Not “we have a PDF,” operational readiness: systems that can produce, update, and defend a DPP on demand.

If your category deadline lands in 18-24 months from delegated act adoption, and your internal runway is 12-18 months, you do the math on how much margin you actually have. For textiles, if the delegated act adopts in late 2026 or early 2027 as currently expected, and compliance follows 12-24 months later, your real-world working window, accounting for the time it takes any organization to mobilize after a regulation actually publishes, is tighter than it looks on a slide.

If you’re reading this in mid-2026 with 200-500 SKUs in textiles, electronics or furniture, here’s my honest assessment:

You should already have completed or be actively running, your data audit and gap mapping. You should have identified your tier-1 suppliers and begun structured data requests, even with incomplete certainty about final field requirements, because the overlap with universal DPP fields is large enough to justify starting now. You should have a named cross-functional owner, not a single person carrying this alongside their existing job. And you should have at least scoped a pilot subset of SKUs, even if you haven’t run it yet.

If none of that is true yet, you are not too late. But you are behind where the realistic timeline requires you to be, and every month of delay compresses an already tight runway into something closer to crisis management.

That’s all for now

Catch you next week,

Gianluca

PS: If you would like to have a free assessment of your DPP pilot, book your session at info@gianlucamanago.com (only 20 slots available, first come first served)