ESPR readiness checklist
Work this in order. Most programmes that stall did so because they selected a platform before they knew which attributes they were missing, and then discovered the gap was in tier 3.
Identify every product group you place on the EU market
Obligations attach to groups, not to products individually.
Confirm which delegated act covers each group, and its expected date
Roughly eighteen months from adoption to enforcement.
List the passport attributes that group’s data set requires
Mark each attribute as held, partial or missing
Partial is the dangerous category — it hides behind an average.
Name an internal owner for every missing attribute
A team, not the compliance function by default.
Identify which supplier tier actually holds each missing attribute
Usually tier 2 or 3, where you have no direct contract.
Decide the issuance level per group: item, batch or model
Changing it after launch means reissuing every carrier.
Choose the data carrier and confirm it survives the product’s working life
Define which audience may read which attribute before publishing anything
Retrofitting access control to a published passport is not possible.
Agree how a published passport gets corrected, and who signs off
Corrections are normal; an architecture that prevents them is the problem.
Confirm the data remains available if your vendor contract ends
Ask for a full export in GS1 and W3C formats during evaluation.
Send us your product groups and we will mark up which delegated acts reach them and which attributes you are likely missing. Ask for it.
Battery passport 2027 checklist
The only mandatory product passport with a fixed date in EU law. From 18 February 2027 an in-scope battery cannot be placed on the market without one, so this list is a countdown rather than a plan.
Confirm which of your batteries exceed 2 kWh or fall in the LMT and EV categories
Assign a unique identifier per battery unit, not per model
The battery passport is item-level.
Capture cell chemistry, format, rated capacity and nominal voltage
Establish a state-of-health feed from the battery management system
This is a live value, not a specification sheet entry.
Calculate the carbon footprint declaration per kWh by life-cycle stage
Requires third-party verification.
Obtain recycled cobalt, lithium, nickel and lead shares from the cell supplier
Per the harmonised calculation method.
Publish the supply chain due diligence policy and its verification report
Document the dismantling sequence, fixings and safe handling
This is what a recycler reads; get it reviewed by one.
Specify extinguishing agents and hazard information for first responders
Laser-mark or otherwise apply a QR code that survives the operating environment
A printed label will not last.
We will review your battery data set against Annex XIII and tell you what is outstanding. Ask for it.
Supplier data collection checklist
Almost every blocked passport traces to a supplier who was never asked properly. The failure is rarely refusal — it is a request that arrived as a spreadsheet with no context, to someone with no compliance team.
Group the request by attribute set, not by product
One mill supplying eleven styles should get one request.
Identify the actual person who holds the data, not the account manager
Usually a production or technical manager.
State which regulation requires each attribute
A named instrument gets a faster answer than a policy reference.
Give a worked example of an acceptable answer for each field
Set a due date that accounts for the supplier’s own upstream chase
Offer a route for the supplier to say "we do not measure that"
Otherwise you get a plausible number instead of a gap.
Record who asserted each value, so provenance survives into the passport
Track response rate per campaign and per tier
Tier 3 is where completeness collapses.
Escalate contractually only after a second request has failed
Re-run the campaign when the candidate list or the data set changes
Substance screening goes stale roughly twice a year.
We will draft the first campaign with you, using your own product group’s attribute set. Ask for it.
Passport platform evaluation checklist
Written to be used against us as much as anyone. Every item is a question with a checkable answer, and a vendor who deflects on the export and access questions is telling you something.
Ask for a full data export in GS1 and W3C standard formats, before signature
Portability you have not tested is a promise, not a property.
Confirm identifiers are GTIN and GLN rather than vendor-internal keys
Confirm supply chain events are EPCIS 2.0 with Core Business Vocabulary terms
Ask to see a raw event.
Confirm claims are W3C Verifiable Credentials that verify without the vendor
Ask how attribute-level access control is configured, and see it demonstrated
Not a public page plus a private database.
Ask what happens to your passports if the contract ends
Ask whether any customer token or wallet is required
The correct answer is no.
Ask how a published passport is corrected, and whether the history is retained
Confirm the platform tracks delegated acts and flags newly in-scope products
Check the vendor cites regulations by legal identifier rather than by nickname
It is a proxy for whether they have read them.
Use this against us. If you want the scoring sheet we use internally, ask and we will send it. Ask for it.
EUDR due diligence checklist
The obligation is geometric rather than documentary. Most EUDR programmes fail on plot geometry rather than on paperwork, because a point on a large estate evidences nothing about where the crop grew.
Identify every product containing cattle, cocoa, coffee, oil palm, rubber, soya or wood
Including derived products.
Collect geolocation for every plot of production
Use a polygon rather than a point for any plot above four hectares
Article 9(1)(d).
Verify no plot was converted after 31 December 2020
The cut-off is fixed regardless of local legality.
Confirm production complied with the law of the country of origin
Run and document a risk assessment per supply chain
Apply mitigation where risk is not negligible, and record it
Lodge a due diligence statement in the EU Information System before placing on market
Carry the DDS reference downstream to your customers
They need it for their own statement.
Re-assess when a supplier, plot or country risk classification changes
Send us a supplier list and we will identify which commodities pull you into scope. Ask for it.
PPWR packaging readiness checklist
PPWR applies from August 2026 and its grades carry a fee consequence, so this is a cost exercise as much as a compliance one. Work component by component, not pack by pack.
Inventory every packaging component per product, including closures and labels
Record material, weight and recycled content for each component
Assess the design-for-recycling grade A to E per component
Grades D and E need redesign before 2030.
Check each component against the recycled content thresholds for its material
Complete the minimisation assessment showing no further reduction is possible
Apply the harmonised separation pictogram for each separable component
A labelling obligation in its own right.
Identify components that could move into a reuse system
Model the eco-modulated fee impact of each grade in each market
This is where the redesign business case comes from.
Confirm your producer responsibility registrations cover every market you supply
We will grade a representative pack and show you the fee delta from a redesign. Ask for it.
Substances of concern screening checklist
The threshold applies to each article, not to the assembled product. That single distinction accounts for most of the notifications that turn out to have been required after all.
Break the product down into articles as REACH defines them, not into assemblies
Obtain a full material declaration per article from the supplier
Screen against the current candidate list, not a cached copy
It updates roughly twice a year.
Calculate concentration per article by weight, not across the product
A 0.4 % fastener does not fall below threshold by being small.
Flag every substance above 0.1 % w/w for notification
Submit a SCIP notification and record the submission number
Separate from the Article 33 duty.
Communicate safe-use information to recipients down the chain
Record which audiences may read the substance data in the passport
Recyclers and regulators, not the consumer view.
Re-screen on each candidate list update and on any material change
Send a bill of materials and we will show you where the notifications would fall. Ask for it.
Textile passport readiness checklist
Textiles are an ESPR priority group and the sector where passport data does the most commercial work — resale, repair and EPR fee reduction all draw on the same attributes.
Record fibre composition by mass, including recycled and regenerated fractions
Using generic fibre names.
Capture country of origin for spinning, weaving, dyeing and making-up separately
Not a single "made in".
Obtain restricted substance screening for the dyeing and finishing stages
Record the SVHC declaration and its SCIP reference where above threshold
Document care, repair and durability, including trim and spare-part availability
Establish fibre-to-fibre recyclability of the finished article including trims
Trims are usually what blocks it.
Record unsold consumer textiles discarded and their treatment
ESPR Art. 24–25; destruction is banned.
Confirm EPR registration in every market you sell into
France, the Netherlands and others already require it.
Choose a carrier that survives laundering for the garment’s life
Usually a printed care-label QR.
We will map one style end to end and show you where the data actually stops. Ask for it.
Passport launch readiness checklist
Run this before the first passport is publicly resolvable. Several of these items cannot be fixed afterwards without reissuing carriers or republishing data you would rather not have published.
Confirm every required attribute for the product group is present
Confirm no personal data or commercial term is in the record
Check the actual payload, not the intent.
Verify each audience view serves only what that role should read
Test the consumer view as an anonymous request.
Verify the data carrier resolves correctly from a cold device
Confirm the resolver serves the right language for each target market
Check every claim in the passport names its issuer and method
Confirm the correction and version history process works end to end
Confirm the passport still resolves if your CMS or website is down
Record the launch state so a later dispute can be settled by evidence
This is what anchoring is for.
We will run this against a real passport with you before you publish it. Ask for it.
CSRD circularity data checklist
ESRS E5 asks for resource inflows and outflows at a level of detail most companies discover they cannot evidence. Passport data covers a surprising amount of it, if it was collected with this in mind.
Quantify material inflows by mass, split by virgin and secondary
Split secondary inflows into pre- and post-consumer
They are not interchangeable in disclosure.
State the chain-of-custody model behind every recycled content figure
Mass balance is not segregated.
Quantify outflows: products, packaging and waste by treatment route
Record durability and reparability characteristics per product group
Evidence take-back and resale volumes against product identity
Reconcile the product-level figures to the entity-level disclosure
Auditors will ask; the reconciliation is the work.
Document the method and boundary for every quantitative claim
Retain the evidence chain for each figure, not just the figure
We will show you which ESRS E5 datapoints your passport data already answers. Ask for it.
Battery passport readiness checklist
The battery passport is the most demanding in EU law because part of it changes while the product is in service. Work the supplier items first — they originate outside your organisation and cannot be produced internally at any price.
Confirm which battery category each product falls into
Portable, LMT, industrial or electric vehicle — obligations differ.
Establish whether the pack is bought in or built in house
If bought in, most required data sits with a supplier.
Obtain cell chemistry and rated capacity from the cell supplier
Request cradle-to-gate carbon footprint with a stated boundary
Dominated by the cell plant energy mix, which you do not control.
Request recycled content by material with its custody model
Physically segregated and mass balanced are different claims.
Obtain due diligence evidence for cobalt, lithium, nickel and graphite
Several tiers upstream of the cell maker.
Confirm the battery management system exposes state of health and cycle count
Without a data path there is no live attribute.
Design the in-service data route for products outside the dealer network
Second and third owners are the case the requirement turns on.
Verify portable batteries are removable and replaceable by the end user
A sealed pack is a compliance problem, not a styling choice.
Decide how a repurposed pack references the original record
The repurposer becomes an economic operator in their own right.
Send us a pack specification and we will mark up which attributes your cell supplier has to provide and which you already hold. Ask for it.
Before you send a supplier data request
Supplier goodwill is finite and a badly framed request spends it for nothing. Every item here raises response rates measurably, and the whole list costs less than one round of chasing non-responders.
Cut the request to the attributes you actually need now
A short specific request outperforms a comprehensive questionnaire.
Name the regulation behind each attribute in the request itself
A supplier who understands why answers differently.
Check whether another team has already asked this supplier recently
Two requests months apart get worse answers than one.
Accept their existing format rather than mandating your template
Translation is your cost and it is smaller than no response.
State explicitly who will see the data and who will not
Permissioned access is what unlocks confidential answers.
Ask for the measured value, not a pass or fail conclusion
A conformity verdict cannot populate a passport attribute.
Include the reference period you need the figure to cover
Give a deadline aligned to their reporting cycle, not yours
Confirm the request routes to somebody who holds the data
Procurement contacts frequently cannot answer technical questions.
Tell them what happened to the last submission they made
An exchange gets answered faster than a demand.
We will review a draft supplier request and mark up what will not get answered and why. Ask for it.
Packaging data readiness checklist
Packaging obligations attach to components rather than products, which is why pack-level records fail. Build the component structure before populating anything — twenty packs recorded correctly are worth more than two thousand recorded at the wrong level.
List every physically separable component of each pack
Body, closure, liner, label, sleeve, carton, transit film.
Record the material of each component, not the pack
Record the empty weight of each component
Producer responsibility fees are calculated on this.
Record the attachment method between components
Separability decides recyclability more than material does.
Record decoration and inks, including sleeve coverage
A full-body sleeve can defeat optical sorting entirely.
Distinguish consumer packaging from transport packaging
They are reported separately under producer responsibility.
Note which components consumers actually separate in practice
Idealised separation produces a recyclability figure no market achieves.
Map each pack to the markets it is placed on
Fees and collection differ by member state.
Identify the disposal guidance that applies per market
What local collection accepts, not what is technically recyclable.
Assign an owner for keeping specifications current after artwork changes
Pack data goes stale at every redesign.
Send a pack specification and we will show you what a component-level record would look like for it. Ask for it.
Passport data quality audit
A passport publishes your data quality to everybody, which is a different exposure from internal reporting. These checks find the failures that schema validation passes over, because they produce values that are structurally valid and wrong.
Group similar products and examine each attribute distribution
Outliers reveal unit errors validation cannot catch.
Investigate outliers rather than correcting them automatically
Some are real and are the most interesting findings.
Check for repeated identical values across unrelated products
Usually a placeholder that was never replaced.
Record when each value was established and by whom
Set an expected refresh interval per attribute and monitor age against it
Stale data looks exactly as complete as current data.
Verify each attribute has a named authoritative source system
Two sources means values change with whichever ran last.
Confirm each attribute is held at the required granularity
A material group average cannot fill a per-product attribute.
Confirm the value is addressable, not a number inside a document
Check that provenance distinguishes measured from estimated values
Publishing an estimate as a measurement is a misrepresentation.
Replace completeness targets with provenance and primary-data measures
Completeness targets create pressure to fabricate.
We will run this audit against a sample of your product records and report what it finds. Ask for it.
Resolver operations readiness
A resolver outage is a compliance failure for every product in the field, not a degraded experience. These are the commitments that outlive the product line, and all of them are cheaper to decide now than to retrofit.
Host on a dedicated subdomain no marketing team will restructure
The identifier is printed and can never change.
Remove anything changeable from the identifier scheme
No version numbers, product line names or reorganisable codes.
Separate resolution from rendering
A site redesign must never touch identifier resolution.
Size capacity against cumulative products sold, not current sales
Load keeps rising after a product is discontinued.
Define caching policy per attribute type
Never cache recall or safety status.
Monitor from outside your network, in the markets you sell into
Internal checks pass while consumers abroad fail.
Test a full record export including history at least annually
An untested export is an assumption, not a capability.
Document the retention period and where records survive a migration
Maintain an inventory of every identifier scheme already marked
Including schemes inherited through acquisition.
Agree what happens to resolution if the vendor relationship ends
Read the contract answer before signing, not after.
We will review your resolver architecture against this list and flag what will not survive ten years. Ask for it.
Textile passport readiness checklist
Most of what a textile passport needs is already tested somewhere in the supply chain. The work is retrieving measured values rather than commissioning new testing, and changing what suppliers return so the next season arrives ready.
Record fibre composition by weight per garment, not per range
Blends decide which recycling route is available.
Record elastane content explicitly even at low percentages
A few per cent blocks most recycling routes.
List trims separately: zips, buttons, rivets, prints, labels
Each must be removed before processing.
Retrieve measured durability values rather than pass or fail verdicts
A specification saying "pass" cannot fill an attribute.
Identify which durability properties matter for each product type
Pilling for knitwear, abrasion for outerwear.
Record dye class and whether colour can be stripped
Establish country of manufacture at each processing stage
Spinning, weaving, dyeing and making up may differ.
Check whether any component brings EUDR into scope
Leather trims and viscose both can.
Change the supplier specification to require measured values
This is what makes next season cheaper than this one.
Register with producer responsibility schemes per market
Textile EPR is national, not EU-wide.
Send us a tech pack and we will mark up which passport attributes it already answers and which it does not. Ask for it.
Electronics passport readiness checklist
Electronics carry more existing obligations than almost any category, and the data sits in four systems that do not share a product identifier. Consolidation is most of the work and it pays for itself before any new requirement arrives.
Confirm which existing regimes already apply to each product
RoHS, WEEE, energy labelling, batteries, radio equipment.
Establish a single product identifier shared across those systems
This is the step that unlocks everything else.
Convert substance conformity conclusions into concentration values
Passport attributes need numbers, not verdicts.
Record which RoHS exemption each product relies on, by entry number
Exemptions expire and renewal is not automatic.
Track exemption expiry dates as redesign deadlines
Locate the battery, capacitors and any mercury for treatment guidance
This is what a recycler needs before handling it.
Record end-of-production dates per model
They start the spare parts obligation clock.
Publish repair documentation and fault code meanings
The cheapest available improvement to a repairability score.
Confirm no functioning replacement part is rejected by software pairing
Ask component suppliers about critical raw material content
Magnets, displays, capacitors and semiconductors carry most of it.
We will map your existing RoHS, WEEE and energy label data against passport attributes and show the gap. Ask for it.
Green claim review checklist
Run this over every environmental claim currently on packaging, in advertising and on your site. Claims made before substantiation rules tightened are the ones most likely to fail, and they are still in market.
List every environmental claim currently in use, including on pack
Artwork claims are the ones teams forget.
For each, identify the recognised method behind the figure
A self-defined calculation is not substantiation.
Check the claim states its scope explicitly
"Recycled" meaning the pack, the product or one component.
Verify comparative claims treat both sides equivalently
Different boundaries make a comparison meaningless.
Remove generic claims with nothing specific behind them
"Eco-friendly" and "green" carry no defensible meaning.
Check any recyclability claim against actual local collection
Technically recyclable is not the same as collected.
Review offset-based neutrality claims specifically
These are constrained more tightly than other claims.
Confirm the supporting data is current, not from launch
Check no circularity score is presented as an environmental score
Material flow and impact are different measures.
Record where the evidence for each claim is held and who owns it
A challenge arrives with a deadline.
Send us your current claim set and we will flag which will not survive a substantiation challenge. Ask for it.
Construction product passport readiness
Construction starts ahead of most sectors because declared performance data already exists. The work is structural — turning documents into data — rather than analytical, and the environmental characteristics are where new effort lands.
Confirm which harmonised technical specification covers each product
Identify the AVCP system assigned to each product family
It determines what evidence stands behind a declared value.
Convert declarations of performance into structured records
Keyed to a product identifier, not filed by project.
Establish which products have current EPDs and which have expired
EPDs carry validity periods that lapse quietly.
Record the lifecycle modules each environmental figure covers
A1–A3 is not comparable with A1–C4.
Record the declared unit alongside every environmental figure
Per kilogram and per square metre are different declarations.
Decide the declared unit by how designers specify, not how you manufacture
Record how the product is fixed, not only what it is
Fixing method decides whether it can be reused.
Establish how a product identifier survives to installation
The record breaks at the site, not at the factory.
Plan how original declared performance stays retrievable for decades
This is what makes structural reuse possible at all.
We will review a declaration of performance and show what a structured version would carry. Ask for it.
Circular procurement criteria review
Most sustainability criteria in tenders produce paperwork rather than change. This list separates the criteria that alter supplier behaviour from the ones that reward whoever writes the most persuasive bid response.
Check each criterion names a measurable property with a method
"Committed to sustainability" changes nothing.
Confirm you can verify the answer without auditing every bidder
Unverifiable criteria reward assertion, not performance.
Weight the criteria enough that a bid can actually lose on them
A token section nobody scores changes no behaviour.
Replace bespoke questionnaires with standard questions
Suppliers answer forty versions of the same question otherwise.
State how each answer will be verified, in the tender
Evaluate on total cost of ownership, not purchase price
Durability is unaffordable in a purchase-price frame.
Check no requirement eliminates every credible bidder
These get waived at award, which teaches suppliers to ignore them.
Publish where the thresholds are going in future cycles
Suppliers invest against a trajectory, not a surprise.
Require recycled content claims to state their custody model
Segregated and mass balanced are different claims.
Ask for the passport rather than a bespoke data return
It is the answer that serves every one of their customers.
Send us a draft tender and we will mark up which criteria will change supplier behaviour and which will not. Ask for it.
EUDR due diligence readiness
Geolocation is the item that decides whether this is achievable, and it is the one furthest from your direct suppliers. Start there and the rest follows; start anywhere else and you discover the gap after building everything around it.
Identify every product containing a covered commodity
Cattle, cocoa, coffee, palm, rubber, soya and wood.
Check for derivatives, not only the raw commodity
Palm-based surfactants and leather trims both count.
Establish your role: operator or trader
Obligations differ substantially between them.
Map each commodity back to the plot of production
This is the hardest item and it gates everything else.
Obtain geolocation coordinates for each plot
Polygons above a size threshold, points below it.
Verify production predates or complies with the cut-off date
Confirm compliance with the producing country’s relevant laws
Legality is a separate test from deforestation-free.
Assess risk and document the assessment
The obligation attaches to the process, not the outcome.
Prepare to submit a due diligence statement per consignment
Decide how geolocation data is protected commercially
It reveals sourcing relationships competitors would value.
Send us a bill of materials and we will identify which components bring EUDR into scope. Ask for it.
A passport programme in its first 90 days
The order matters more than the pace. Every item here is chosen because it reveals whether the next one is feasible, and because none of them depends on knowing the final attribute list.
Name one accountable owner with regulatory rather than technical authority
The blocking decisions are compliance calls.
List product groups placed on the EU market and check the working plan
Open the supplier conversation before anything else
Longest lead time, and it runs at contract pace.
Pick one product family for an end-to-end pilot
Choose a complex one — simple products hide the problems.
Map every attribute for that family to a source system
Record which attributes have no source, no owner or wrong granularity
This list is the actual deliverable of the pilot.
Resist fixing pilot data by hand to show progress
It proves only that manual production is possible.
Establish a resolvable product identifier scheme
Independent of any delegated act.
Build a material-level bill of materials for the pilot family
Serves packaging and EPR reporting immediately.
Quantify what fragmented compliance reporting already costs annually
This is the budget argument that does not depend on future rules.
We will run a 90-day readiness review with your team and produce the gap list. Ask for it.
Circularity design review checklist
Run this at design freeze, not after. Every item is a decision that becomes permanent once tooling is committed, and most of them cost nothing at the point where they are still reversible.
Count the distinct fastener types across the product
Tool changes dominate disassembly time.
Time how long it takes to reach the most commonly failing part
A morning with a stopwatch changes design behaviour.
Check high-value components are not behind everything else
Batteries, boards and motors should be reachable early.
Identify every permanent joint between dissimilar materials
Metal inserts in plastic are the archetype.
Confirm the battery can be removed without destroying the product
Check whether any coating or laminate prevents material separation
Establish whether components are shared with other models
Shared architecture lets repairer experience transfer.
Confirm no functioning replacement part is rejected by software
Document the separation sequence while the design is fresh
Nobody will reconstruct it in fifteen years.
Record joining methods per interface in the product record
It lets a recycler triage before handling the product.
We will run this review against one of your products and quantify the disassembly time. Ask for it.
Product data for CSRD reporting
CSRD figures face assurance, which changes the standard of evidence from persuasive to defensible. These are the product-level inputs that entity-level reporting depends on and that are usually assembled last.
Establish which ESRS datapoints depend on product-level data
E1 and E5 carry most of the connection.
Identify the proportion of Scope 3 Category 1 resting on supplier-specific data
This proportion is what shows progress, not the total.
Record the method and boundary behind every product footprint used
Distinguish measured, supplier-declared and estimated values
Assurance will ask, and averaging hides the difference.
Align passport and Scope 3 supplier requests into one approach
Asking twice gets worse answers the second time.
Record resource inflows and outflows at product level for E5
Check circularity metrics state what they measure and exclude
A flow metric is not an impact metric.
Prepare the data quality disclosure alongside the numbers
ESRS requires it, and provenance is what evidences it.
Confirm figures reported externally match what the passport publishes
Two disagreeing numbers is worse than one imperfect one.
Establish who signs off product figures for assurance
We will map your ESRS datapoints to the product data that has to feed them. Ask for it.
Passport contract terms to check before signing
A passport commitment outlives most software contracts, because products in the field keep being scanned after the relationship ends. These are the clauses that matter in year five and that nobody reads in year one.
Confirm full data export including version history, in a named format
Not a report — the records themselves.
Establish who owns the identifiers if the contract terminates
They are printed on products you have already sold.
Agree a resolution wind-down period after termination
Products do not stop being scanned when a contract ends.
Confirm the availability commitment reflects a compliance obligation
Check who is liable if a resolver outage causes a compliance failure
Establish who tracks regulatory change and adds new attributes
Confirm it is included rather than chargeable per act.
Confirm retention matches the regulatory period, not the contract term
The obligation outlasts the relationship.
Check whether supplier data can be exported by the suppliers themselves
Agree how a record from three years ago is produced for an audit
Confirm access scope is enforced server-side and test it
Ask for an unauthenticated API response during evaluation.
We will answer all of these about our own contract in writing, unprompted. Ask for it.