Ask a Digital Product Passport vendor whether they’re compliant and you’ll get a yes. The question is meaningless: the textile delegated act doesn’t exist yet, so there is nothing to be compliant with. A vendor claiming compliance with an unwritten rule is selling confidence.
There is now a question that isn’t meaningless. On 15 July the Commission cited six CEN/CENELEC standards for the DPP system as harmonised in the Official Journal — EN 18216, 18219, 18220, 18221, 18222 and 18223 — with EN 18239 and EN 18246 expected to follow around September, their formal vote having closed on 16 July. Harmonised means presumption of conformity. Build to them and you are presumed to meet the legal requirement.
So the useful question is no longer “are you compliant?” It’s “which of the eight EN 18xxx standards do you conform to, and how was that assessed?” — in writing.
Three of those standards reach further into your operation than most brands realise:
- EN 18219 (unique identifiers) recognises the GS1 Digital Link URI. If your products already carry GTINs, you have a recognised on-ramp — and any vendor pushing a proprietary identifier is adding a migration and a lock-in you didn’t ask for.
- EN 18220 (data carriers) governs the QR code physically on the garment. Label real estate is negotiated seasons ahead. This is the decision with the longest lead time and the highest cost of delay.
- EN 18239 (access rights) is the most under-asked question in DPP procurement. Most anxiety about passports is really anxiety about publishing a supplier list. This standard exists so data can be present but restricted. A vendor who can’t demonstrate tiered access is asking you to choose between compliance and confidentiality.
I’ve put the full set — 22 questions mapped to the eight standards, six commercial questions the standards don’t cover, eight red flags and a twelve-point scorecard — into a four-page checklist you can take into a vendor meeting.
Get the DPP Vendor Conformance Checklist →
Operator takeaway: send Section 1 to your shortlist as a written RFI this week, and forward the EN 18220 carrier question to whoever owns your labelling spec. Both answers are cheap now and expensive in 2028.