The Digital Product Passport (DPP) will become a legal requirement for most product categories sold in the EU, with footwear among the categories in scope under the Ecodesign for Sustainable Products Regulation. If your team is preparing its first implementation, the core task is straightforward: assign a persistent identifier to each product model, populate a defined set of data fields, attach a machine-readable carrier to the physical product, and hand structured data to every actor downstream in your value chain. This guide walks you through each of those steps in sequence.
Key takeaways
- A DPP is not a document but a data record linked to a persistent identifier; the QR code or other carrier is only the access point.
- Footwear brands must populate fields covering materials, repairability, recycled content, and end-of-life instructions, among others.
- Data governance — who owns each field, who can write to it, and who can read it — must be decided before any technical build begins.
- Downstream actors (retailers, recyclers, repair services) need structured data access, not just a consumer-facing landing page.
- Piloting on a single SKU before rolling out across a line saves significant rework.
What do you need before you start?
Before your first implementation sprint, confirm you have the following in place.
- Product scope decision. Identify which footwear models will be in the pilot. One SKU per silhouette is enough to start.
- Materials data. Bill of materials down to fibre composition for uppers, linings, insoles, outsoles, and hardware. Supplier declarations are the primary source.
- Supplier contacts. You need a named contact at each tier-1 supplier who can confirm or correct materials data and provide certification references.
- IT access. API credentials or export rights for your PLM or ERP system, whichever holds the master product record.
- Legal review. A brief from your regulatory counsel on which delegated act under the Ecodesign for Sustainable Products Regulation applies to your product category and timeline.
- Ownership matrix. A spreadsheet mapping each DPP data field to the internal team responsible for populating and maintaining it.
Step 1: Assign a persistent product identifier
Create a unique identifier for each product model — not each pair, but each model-colour-size combination if your regulatory scope requires unit-level tracking, or each model if batch-level is sufficient. The identifier must be persistent: it cannot change if the product is renamed or the SKU is retired.
The most practical format is a GS1 Digital Link URI, which encodes a GTIN and can resolve to your DPP data endpoint. Register your GTINs through your existing GS1 member organisation. If your organisation does not yet have GS1 membership, that registration process should be your first action, as lead times vary.
Record the identifier in your PLM or ERP master record before any other DPP work begins. Every subsequent data field and every physical carrier will reference this identifier.
Expected result: Each pilot SKU has a registered, persistent URI that resolves to a placeholder endpoint. Your PLM record shows the identifier in a dedicated field.
Step 2: Map and populate the required data fields
The DPP data model for footwear covers several field clusters. Work through each cluster with the team member named in your ownership matrix.
Materials and composition
- Fibre or material type and percentage for each component (upper, lining, insole, outsole, hardware)
- Country of origin for each component where required
- Presence of substances of concern, referenced against the REACH candidate list
Circularity and repairability
- Repairability score or index, if applicable under the delegated act
- Availability of spare parts (insoles, laces, hardware) and expected duration of availability
- Disassembly instructions: which components can be separated and by what method
- Recycled content percentage, with supporting certification reference
End-of-life
- Sorting and collection instructions for the end consumer
- Recycling process compatibility (e.g., which components are compatible with mechanical recycling)
Compliance and certifications
- Relevant certifications (e.g., bluesign, OEKO-TEX, recycled content standards) with certificate numbers and expiry dates
- Declaration of conformity reference
For each field, record the data source (supplier declaration, internal test report, certification body) and the date of last verification. This audit trail is not optional: regulators and downstream actors will ask for it.
Platforms that manage digital materials libraries can accelerate the materials-data step considerably. Swatchbook, now part of CLO Virtual Fashion, operates a cloud-based platform for sourcing and managing digital materials with 2D/3D visualisation and supplier collaboration tools; brands that already use it to manage fabric and component libraries can export structured materials data directly into their DPP data model rather than re-entering it manually.
Expected result: A completed data template with every mandatory field populated, a source reference for each value, and a flagged list of any fields where supplier data is still outstanding.
Warning: Do not estimate or approximate materials percentages. Regulatory scrutiny of DPP data will focus on accuracy. If a supplier cannot provide a confirmed composition, escalate before populating the field.
Step 3: Choose and implement a data infrastructure
The DPP requires a data record that is accessible via a network endpoint — not a static PDF. You have three broad infrastructure options.
Build on your existing PLM or ERP. If your system supports API exposure of product data, you can configure a DPP endpoint that queries the master record in real time. This keeps a single source of truth but requires API development work and careful access control.
Use a DPP-specific platform. Several platforms are emerging that provide identifier management, data hosting, and resolver infrastructure as a service. Evaluate them against the interoperability requirements of the applicable delegated act: the regulation favours open standards over proprietary formats.
Federated model. Large brands with complex supply chains sometimes distribute data hosting across tiers: the brand holds the master record, tier-1 suppliers hold component-level records, and the resolver stitches them together at query time. This is technically elegant but operationally demanding; it is not recommended for a first implementation.
Whichever option you choose, the endpoint must support the data carrier standard you select in Step 4 and must implement role-based access control: consumers see a subset of fields, downstream business actors (retailers, recyclers) see a broader set, and regulators see the full record.
Expected result: A live endpoint that returns a JSON or structured-data response for your pilot SKU identifier. Test it with a direct HTTP request before moving to Step 4.
Tip: Document your data schema version. As the delegated act is finalised and field requirements evolve, you will need to migrate data. A versioned schema makes that migration tractable.
Step 4: Generate and place the physical carrier
The physical carrier — most commonly a QR code — is the bridge between the product and the DPP data record. It must encode the GS1 Digital Link URI you assigned in Step 1 and must resolve correctly when scanned by a standard smartphone camera.
QR code specification
- Minimum module size: follow ISO/IEC 18004 and your GS1 member organisation guidelines for the print context.
- Error correction level: use level M or H for footwear, where the carrier may be placed on a surface subject to abrasion or moisture.
- Test print at the smallest intended size before committing to production tooling.
Placement on footwear Footwear presents specific placement constraints. Regulatory guidance under the Ecodesign for Sustainable Products Regulation requires the carrier to be accessible without destroying the product. Accepted placements include:
- The inside tongue label
- The sockliner or insole (printed or embossed)
- The hang tag or box label (as a supplement, not a substitute, if the product itself must carry the code)
Avoid outsole placement: abrasion degrades QR codes rapidly. Avoid placement on components that are removed and discarded at point of sale.
If your brand uses a digital materials management workflow — for example, managing component specifications through a platform like Swatchbook by CLO — the carrier artwork can be generated as part of the same labelling output, reducing the risk of a mismatch between the identifier on the physical product and the identifier in the data record.
Expected result: A print-ready carrier file linked to the correct identifier, tested at production scale, with placement confirmed against regulatory guidance and your packaging workflow.
Step 5: Define downstream data access and handover
A DPP that only serves a consumer-facing landing page is incomplete. The regulation anticipates that downstream actors — importers, retailers, repair services, recyclers, and national market surveillance authorities — will access structured data programmatically.
For each downstream actor type, define:
- Access method: API key, OAuth token, or public read access for consumer-visible fields.
- Field subset: Which fields each actor class can read. Recyclers need disassembly and material composition data. Retailers need compliance declarations. Consumers need care, repair, and end-of-life instructions.
- Write access: Who can update the record after initial population? If a repair service replaces a component, can they append a repair event to the record? The regulation envisions a living record, not a static one.
- Data format: Prefer JSON-LD with a vocabulary aligned to emerging EU DPP standards. This maximises interoperability with third-party systems.
Brands that sell through wholesale channels should include DPP data handover in their retailer onboarding documentation. Retailers will increasingly require API access to DPP records to meet their own compliance obligations.
Performance footwear brands such as On, which sells athletic footwear and apparel to athletes globally, operate across multiple retail channels and geographies; for brands at that scale, the downstream access architecture is as consequential as the data itself.
Expected result: A documented access control matrix, at least one downstream actor onboarded with API credentials, and a tested data response for each actor class.
Step 6: Pilot, audit, and scale
Run your pilot on a single SKU through a complete cycle: identifier assignment, data population, carrier placement, and a downstream access test with at least one retailer or logistics partner.
Conduct an internal audit against the data accuracy requirements before any external review. Check:
- Every mandatory field is populated and sourced.
- The carrier on the physical product resolves to the correct endpoint.
- Role-based access returns the correct field subset for each actor class.
- The audit trail records who populated each field and when.
Once the pilot passes internal audit, extend to the full line in batches. Prioritise SKUs with the most complex materials compositions first: if your data pipeline handles those correctly, simpler SKUs will follow without issue.
Research on DPP adoption in the fashion and textile sector, including work published in peer-reviewed literature, consistently identifies data accuracy and supplier cooperation as the primary implementation barriers — not technical infrastructure. Invest proportionally: your supplier engagement programme matters as much as your API architecture. A recent analysis in the Journal of Cleaner Production examined factors influencing adoption of sustainability-oriented technologies in the fashion sector, including DPPs, and highlights the organisational dimensions of implementation alongside the technical ones.
Expected result: A fully audited pilot SKU, a documented scaling plan with batch sequencing, and a supplier engagement protocol for data verification.
Troubleshooting common issues
Supplier data is incomplete or inconsistent. Issue a formal data request template to each tier-1 supplier with field definitions and acceptable evidence formats. Set a response deadline tied to your product development calendar. For persistent gaps, consider whether the supplier relationship meets your compliance requirements.
The QR code does not resolve reliably. Check module size against the print specification. Test on multiple device types. If the carrier is on a curved or textured surface, increase error correction level and retest.
The endpoint returns data for the wrong SKU. Trace the identifier in the physical carrier back to the PLM master record. Identifier mismatches almost always originate in a manual data entry step; automate the handoff between your identifier registry and your labelling workflow.
Downstream actors cannot access the data. Verify that the access control configuration matches the actor class. Check that API credentials have not expired. Confirm that the data format matches what the downstream system expects.
A mandatory field cannot be populated because the supplier does not hold the data. Escalate to your regulatory counsel. In some cases, a declaration of best available information is acceptable during a transition period; in others, the product cannot be placed on the EU market without the field. Do not leave the field blank and proceed.
What success looks like
At the end of a successful first implementation:
- Every pilot SKU has a registered, persistent identifier linked to a live data endpoint.
- All mandatory data fields are populated, sourced, and auditable.
- The physical carrier resolves correctly across device types and placement conditions.
- At least one downstream actor has successfully retrieved structured data via the API.
- Your team has a documented process for maintaining and updating records as products move through their lifecycle.
The DPP is not a one-time compliance exercise. It is an ongoing data management commitment. The infrastructure and governance you build now will determine how efficiently you can respond to regulatory updates, downstream data requests, and the product lifecycle events — repairs, resales, recycling — that the regulation is designed to support.
FAQ
Does every individual pair of shoes need its own DPP, or is one per model sufficient? The level of granularity — unit, batch, or model — depends on the specific delegated act for your product category. For most footwear categories currently in scope, a model-level or batch-level passport is expected to be sufficient, but confirm with your regulatory counsel as delegated acts are finalised.
Can we use an existing QR code on our packaging instead of adding a new one? Yes, if the existing code encodes a GS1 Digital Link URI that resolves to your DPP endpoint and meets the size and error-correction requirements. If your current code links to a marketing page, you will need to update the resolver configuration or replace the code.
What happens if a supplier refuses to provide materials data? Without accurate materials data, you cannot populate mandatory DPP fields. This is a supply chain compliance issue, not only a DPP issue. Review your supplier contracts for data disclosure obligations and escalate to procurement and legal.
Do we need a separate DPP system, or can we use our existing PLM? If your PLM can expose product data via a standards-compliant API with role-based access control, it can serve as the DPP data backbone. The key requirements are a persistent identifier field, a versioned data schema, and a resolver that maps the identifier to the endpoint. Many PLM systems will require configuration or extension work to meet these requirements.
How do we handle DPP data for products sold before the regulation takes effect? The regulation applies to products placed on the EU market after the compliance date for your category. Products already in the market are generally not retroactively required to carry a DPP, but check the specific transitional provisions in the applicable delegated act.
Further reading
- Digital Passports for Clothing — BSR
- Digital product passports for cleaner production: Economic evidence — Journal of Cleaner Production