Why a checklist now
ESPR (EU Ecodesign for Sustainable Products Regulation) entered into force in 2024. The framework is real but the obligations roll out per-category through delegated acts. Iron and steel, batteries, textiles, electronics, ICT, chemicals are first in line. Cosmetics and packaging follow.
The runway looks long until your category's act lands. Then it shrinks fast. Brands that have the data structure and the public Digital Product Passport already in place will glide. Brands that don't will scramble.
Here are ten questions to run through before your next packaging refresh.
The ten questions
- Do you have a GS1-allocated GTIN for every SKU you sell in the EU?
- Is your packaging artwork ready to carry a 2D barcode in the next print run, alongside or instead of the existing 1D barcode?
- Have you mapped your product story content to ingredients, materials, certifications and origin?
- Do you know which ESPR delegated act applies to your category, or that your category isn't covered yet?
- Are your sustainability claims backed by evidence you can attach as certifications on a public passport?
- Do you have a tier-1 supplier list you can disclose at the level your category requires?
- Have you confirmed batch and lot identification practice for traceability and recall?
- Can you hand a customer a recycling pathway and end-of-life instructions?
- Are your data fields stored somewhere you control and can keep current as ingredients and suppliers change?
- Do you have first-party scan analytics so you can see how the passport is being used?
What each yes points at
Yes to question 1 means you have the universal product identity layer in place. The GTIN is the anchor for everything else. Yes to question 2 means you can ship the new code on your real packaging refresh schedule, no detours. Yes to question 3 means you have the content. The platform's passport sections are already aligned with ESPR data attribute groups.
Yes to questions 4 and 5 means your category positioning is concrete. Sustainability claims without evidence get rejected by ESPR. Yes to question 6 is supply chain disclosure work that's separate from any platform decision. Yes to questions 7 and 8 is operational hygiene that lots of brands already have but never surfaced consumer-side. Yes to questions 9 and 10 is platform choice. The platform handles those last two for every workspace.
What you do with the no's
Don't try to fix all ten in a sprint. Pick the ones blocking your next print run and resolve those. The rest can layer in over the year. ESPR delegated acts have transition windows after they're adopted, so brands that have the data structure but haven't filled it completely still gain time.
The platform's EU DPP mapping page shows exactly where each ESPR data group lives in the dashboard. Read that first, then decide which of your no's matter most.