Where the obligation actually reaches you
Under the Ecodesign for Sustainable Products Regulation, the legal duty sits with the economic operator placing the product on the EU market — the importer or authorised representative. If you manufacture outside the Union, you are not the addressee of the regulation.
That is a narrow comfort. The importer cannot produce a passport out of nothing; every field in it describes something that happened in your factory or your supply chain. So the duty travels upstream as a contractual data request, and it arrives earlier than the regulatory deadline because your customer needs time to assemble what you send.
In practice, manufacturers hear about DPP through a purchase order condition or a supplier questionnaire, not through a legal notice. By the time the law bites, the commercial selection has already happened.
Answer once, reuse everywhere
The expensive failure mode is answering each buyer separately. Forty customers with forty formats turns a data problem into a staffing problem, and the answers drift apart — which is worse than not answering at all, because inconsistent declarations are exactly what a market surveillance check looks for.
The structure that avoids this is a single per-SKU record you maintain, from which every buyer format can be produced. The record holds the field and the evidence behind it: not just "65% recycled polyester" but the supplier declaration that supports it and the date it was issued.
- One record per SKU, not one answer per customer
- Evidence attached to fields, so a claim can always be traced to a document
- Versioning, so a buyer asking in 2028 gets what was true in 2028
- An identifier your buyer's systems already understand — a GTIN in GS1 Digital Link
Why the identifier matters more than the format
Buyers change systems. Portals get replaced. What survives is the identifier: if your data is attached to a GTIN encoded in GS1 Digital Link, any buyer, retailer or customs system can find it without you rebuilding an integration.
This is also where the two deadlines converge. GS1's Sunrise 2027 has retail moving from striped barcodes to 2D codes carrying Digital Link, so the same square that satisfies your buyer's DPP requirement is the one their retailer needs at checkout. A manufacturer who prints a plain marketing QR solves neither.
Turning readiness into a commercial advantage
There is a short window in which this is a differentiator rather than a baseline. European brands are auditing their supply base now, and the question they are asking is not whether you are compliant — you are not the legal addressee — but whether sourcing from you creates work for them.
A supplier who can return structured, evidenced, per-SKU data on request removes a cost from the buyer's project. That is a concrete reason to be chosen over a competitor of equal price and quality, and it lasts until readiness becomes universal.
What to build first
Start with the products you already ship to European customers, not your whole catalogue. For those, assemble composition and origin per SKU, attach whatever evidence exists, and make sure each product has a correct, current GTIN. Master data errors here are the single most common source of delay, and they are invisible until someone asks.
Then ask one buyer what format they want, and produce it from the record rather than assembling it by hand. If that works, the second and third buyer cost you almost nothing.
Questions manufacturers ask
Do we need to be a GS1 member?
You need valid GTINs for the products you supply. In most cases those come from a GS1 member organisation in your country, and in many supply relationships the brand already assigns them. The important part is that the number is correct and current — not who issued it.
Our buyer uses their own portal. Why build anything?
Because the next buyer will use a different one. Building around the buyer's portal means rebuilding for every customer; building around your own per-SKU record means exporting into any portal that appears.
How far up our own supply chain does this go?
As far as the data does. Recycled content and substance declarations originate with your material suppliers, so the request you receive becomes a request you send. Starting that conversation early is the difference between a slow first round and a missed deadline.