18-POINT CHECKLIST · ORDERED BY DEADLINE
NOW — Assess scope1. List all SKUs you sell into EU or plan to by Feb 2027. Flag category (textile, electronics, batteries, furniture, etc.).
NOW — Map regulations2. For each category, identify which delegated act applies (textile, battery, construction, etc.). Each category has different fields.
NOW — Gather material data3. For each SKU, collect: material composition %, recycled content %, supplier country, manufacturing country, carbon footprint estimate.
Q2 2026 — Define data carrier4. Decide QR code vs. NFC tag vs. data matrix. QR is cheapest and most universal; most brands start here.
Q2 2026 — Pick a passport host5. Data must live somewhere queryable. Either self-host (build + maintain) or use a platform (ClearPort AI, atma.io, Circularise).
Q2 2026 — Verify supplier consent6. Some composition data is proprietary to your suppliers. Get written agreement to disclose what goes into the public passport.
Q3 2026 — Build first passports7. Generate passports for 5–10 highest-volume SKUs. Validate QR scan from a phone. Test readability in low light.
Q3 2026 — Translation8. Public-facing DPP content must be in the language of the sale country, or English as fallback. Automate where possible.
Q3 2026 — Accessibility9. WCAG 2.1 AA compliance on the passport landing page (alt text, contrast, keyboard nav). Non-negotiable for EU.
Q4 2026 — Print & labelling10. Update product labels, tags, or packaging to physically carry the QR. Plan a print run BEFORE Feb 2027.
Q4 2026 — Customs docs alignment11. DPP identifier must reconcile with what your customs broker files. Share the mapping with them early.
Q4 2026 — Test on retailer platforms12. If you sell on Amazon, Zalando, etc.: verify their DPP ingestion path. Many retailers require their own format.
Jan 2027 — Regulatory delegated acts final13. The EU Commission will have finalized delegated acts by then. Re-verify your data fields match exactly.
Jan 2027 — Full catalog coverage14. Every SKU entering EU must have a passport. Missing ones = held at border. No "we'll retrofit later."
Jan 2027 — Staff training15. Customer service team needs to handle DPP scan questions. Compliance team needs internal dashboard to update.
Feb 1, 2027 — GO LIVE16. Mandatory. Non-compliance = product held at EU port + fines up to €100k per violation depending on member state.
Post-launch — Data maintenance17. Material changes, recycled-content shifts, supplier swaps all require passport updates. Assign an owner.
Ongoing — Audit readiness18. Member-state authorities can audit at any time. Keep evidence chain: supplier declarations, test results, sign-offs.