What will retailers ask brands for under the DPP? A wholesale checklist
Retail partners will need product identifiers, verified sustainability attributes, origin evidence and data feeds from their wholesale brands. A checklist of what to prepare before the textile passport applies.
KEY TAKEAWAYS Summary by the editors
- Wholesale brands should expect retailers to request passport-ready product data together with identifiers, verified claims and origin evidence, delivered through the same feeds as master data.
- Since 27 September 2026 the EU Empowering Consumers Directive (EU) 2024/825 prohibits generic environmental claims and sustainability labels not based on certification schemes or public authorities.
- Zalando moved in 2023 from a general sustainability flag to attribute-based information that must be backed by certifications, trademarks or licensed materials.
- The EU Forced Labour Regulation (EU) 2024/3015 applies from 14 December 2027 to all products and all operators, so retailers will also ask for supply chain evidence.
- Under ESPR, the textile Digital Product Passport delegated act is tentatively planned for 2027, so the final data list is not yet fixed.
Retailers will ask wholesale brands for passport-ready product data: stable product identifiers, composition and material attributes, verified sustainability claims with certificate references, origin and supplier evidence, and a working link from each article to its passport. Most of this can be requested before the textile passport is mandatory, because green-claims and forced-labour rules already push retailers to demand proof.
Why will retailers pass DPP duties to brands?
A retailer that sells a brand's products in the EU needs to show consumers and authorities accurate information, and it carries reputational and legal risk for claims on its own channels. Three rules drive the requests:
- Digital Product Passport: under ESPR, the textile delegated act is tentatively scheduled for adoption in 2027 and will define passport data for apparel.
- Green claims: since 27 September 2026 the Empowering Consumers for the Green Transition Directive (EU) 2024/825 bans generic environmental claims such as "sustainable" or "green" without recognised proof, and allows sustainability labels only if they are established by a public authority or based on a certification scheme.
- Forced labour: the EU Forced Labour Regulation (EU) 2024/3015 applies from 14 December 2027 to any product placed on or exported from the EU market, regardless of company size.
Some retailers moved early. Zalando replaced its general green flag in 2023 with more specific, attribute-based information and said sustainability claims must be "backed by explicit certifications, trademarks or licensed materials."
What is on the wholesale DPP checklist?
The checklist below groups the data retailers are most likely to request. Treat it as preparation, not as the legal data list, which will come with the textile delegated act.
| Area | What retailers will ask for | Ready when |
|---|---|---|
| Identifiers | GTIN per variant, style and colour codes, link to passport ID | Every orderable variant has a unique, stable identifier |
| Composition | Fibre composition per component, trims, recycled share | Data is structured, not free text, and matches labels |
| Claims | Each sustainability claim with certificate name, number and validity | No generic claims; every claim links to evidence |
| Origin | Country of manufacture, key processing steps, facility IDs | Tier 1 and main tier 2 facilities are named and identified |
| Due diligence | Forced-labour risk assessment, supplier declarations | Evidence can be produced per order within days |
| Care and end of life | Care instructions, repair and disposal information | Text is translated and approved for consumer use |
| Data carrier | QR code or other carrier on label or hangtag, resolving to the passport | Carrier tested through the retailer's systems |
| Data delivery | Feeds via EDI, catalogue files or APIs, with update rules | Changes reach retailers automatically, not by email |
How will the data move between brand and retailer?
Expect differences between accounts. Large platforms and department stores tend to define detailed attribute lists and validation rules, while smaller independent retailers may simply want a working passport link and correct labels. Wholesale teams should therefore keep one complete internal record per article and generate retailer-specific outputs from it, instead of maintaining separate spreadsheets per customer. Every manual copy is a future inconsistency that a retailer, a consumer or an authority may find.
Today most wholesale product data travels as catalogue or price files, EDI messages and retailer portal uploads. Passport attributes will probably follow the same routes at first, with new fields added to existing article master data. That means the bottleneck is less the format than the quality and stability of the underlying data.
GS1 standards are a common reference in apparel. GS1 UK describes the GTIN as identifying each variant by style, size, colour and fit, and GS1 Digital Link QR codes as a consumer access point to product information and the passport. The new CEN-CENELEC passport standards add rules for identifiers, data carriers, APIs and data exchange that passport platforms are expected to follow.
What questions should sales and wholesale teams be ready to answer?
- Which of our products carry claims, and can we show the certificate for each order shipped?
- Can we name the fabric mill for any style a buyer asks about?
- How quickly can we update a retailer when a certificate expires or a supplier changes?
- Do we deliver passport links per variant, and do they work in the retailer's own product pages?
- Who in our organisation answers retailer data questions, and with what turnaround time?
Where can AI help brands meet retailer requests?
AI can reduce the manual effort behind retailer onboarding. It can extract attributes from technical packs and certificates, map internal material names to retailer taxonomies, check feeds for missing or inconsistent fields before they are sent and draft consumer-facing care and composition text for review. Some brands also use language models to answer recurring retailer questionnaires from an approved knowledge base.
The limits are the same as elsewhere in compliance. AI cannot create evidence, and any claim that leaves the brand must trace to a document. Under the green-claims rules, an AI-written phrase such as "eco-friendly fabric" without recognised proof is a liability, not a time saving.
What should brands prioritise now?
Start with identifiers and claims, because they are already exposed to rules that apply today. Clean the article master, remove claims you cannot evidence, and attach certificate data to every claim you keep. Then extend supplier mapping to the main fabric mills, so that forced-labour questions from 2027 and passport requirements after the textile act can be answered from systems rather than from inboxes.
Finally, talk to your key retail accounts. Large retailers will define their own templates and timelines, and early alignment avoids building three different formats for three customers.
Frequently asked questions
Will retailers require Digital Product Passport data from brands?
Most likely, because retailers selling in the EU need accurate product information and evidence for claims. The textile passport rules are tentatively planned for adoption in 2027, but green-claims and forced-labour rules already lead retailers to ask for structured data and proof.
What sustainability claims are banned in the EU from September 2026?
Under Directive (EU) 2024/825, from 27 September 2026 generic environmental claims such as "sustainable" or "green" are banned unless backed by recognised excellent environmental performance. Sustainability labels must be based on a certification scheme or set by a public authority, and neutrality claims based on offsetting are prohibited.
How will DPP data be exchanged between brands and retailers?
Initially through existing channels such as EDI, catalogue files, retailer portals and APIs, with passport attributes added to article master data. New CEN-CENELEC standards define data exchange protocols and APIs for passport systems.
What is the most important first step for wholesale brands?
Clean product identifiers and remove or evidence sustainability claims. Every variant needs a stable identifier, and every claim needs a certificate reference, because these are exposed to rules that already apply and will form the core of passport data.
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SOURCES
- Cooley: Empowering Consumers for the Green Transition Directive, check your sustainability claims
- Zalando: Moving beyond the green sustainability flag
- Linklaters: ESG quick guide, EU Forced Labour Regulation
- GS1 UK: Powering the future of apparel with GS1 standards
- SGS: EU releases ESPR Working Plan 2025 to 2030 prioritizing textiles for sustainability
