The first field-by-field DPP access map is public, and it copies battery rules that do not exist yet
Tomorrow at 23:59 Brussels time the public consultation on the first ESPR product delegated act closes. It is about steel, not clothes, and almost nobody in fashion has read the document behind it. They should: it contains the first field-by-field map of who is allowed to see what inside a digital product passport - and it builds that map on battery rules the Commission has still not written.
What is closing tomorrow
On 20 May 2026 the Commission opened feedback on Ecodesign requirements for iron and steel products, the delegated act that turns the Ecodesign Regulation (EU) 2024/1781 into concrete obligations for a real product group. Feedback closes on 12 August 2026, and adoption is indicatively planned for the fourth quarter of 2026. Steel gets there first: apparel textiles have been sitting in the same register since 18 December 2025 without opening for feedback at all.
Behind the consultation sits a 105-page Joint Research Centre study, Study on DPP content for iron and steel products under ESPR, published in March 2026. It is the document that proposes what the passport must actually contain. If you want to know how the Commission thinks about passport data when it stops speaking in principles, this is where it stops.
The part worth stealing: a field-level access map
Everyone in this market says "tiered access" and then stops. The JRC study does not stop. It publishes a table assigning an access level to every single proposed data field. Simplified, here is what it proposes for steel:
- Public. Unique product identifier, GTIN, customs codes, product category and grade, manufacturer name and address, country of origin, manufacturing date, substances of concern, the carbon footprint declaration, the recycled content declaration.
- Legitimate interest only. Carbon footprint calculation parameters, the detailed pre- and post-consumer recycled material split, mill test certificate parameters, the purchase order.
- Authorities only. Conformity declarations and certification for both carbon footprint and recycled content, plus the manufacturer's contact details.
Read the pattern rather than the rows, because the pattern is what will follow you into your own category:
The number is public. The method is restricted. The certificate belongs to the authorities.
Your declared footprint is a public claim. The energy inputs and assumptions behind it, which would let a competitor reconstruct your process economics, sit behind a role. The paperwork proving you did not make the number up goes to market surveillance, not to the internet. The study is explicit about why: composition, process data and sourcing "may reveal technical know-how, enable estimation of production costs, or conflict with contractual chain-of-custody arrangements".
And it copies a rulebook that does not exist yet
Here is the uncomfortable part. The study says plainly that access levels should be defined field by field "following the precedent set in the Battery Regulation (Article 77 and Annex XIII)". It then adds a footnote conceding that in the battery case the Commission still has to specify who counts as a person with a legitimate interest, in a separate implementing act.
That act was due on 18 August 2026. That is seven days away. As of today it is still a planning entry in the Commission's own register, with no draft published and no feedback period opened - we wrote up the state of that file last week and nothing has moved since.
So the sequence is: batteries define the access model, steel inherits it before it is finished, and textiles will inherit it from steel. The middle tier - the one that decides whether a stranger claiming to be a recycler gets your composition data - is being propagated across sectors while its definition is still blank. That is not a reason to panic. It is a reason to stop treating "who sees what" as a vendor feature and start treating it as the part of your architecture most likely to change under you.
Batch, not item - now confirmed twice
The other finding travels well. For steel, the study proposes the heat number as the mandatory batch-level identifier, with item-level identification optional and reserved for specific products where customers already demand it. The reasoning is cost: retrofitting systematic item-level traceability onto production that currently identifies at batch level is estimated at at least around EUR 100 000 per installation plus ongoing operating cost, while reusing existing batch identifiers and adding QR marking was assessed as low to medium effort.
That is the same conclusion the apparel study reached for clothes, and the same thing we tell small brands: one passport per production run, not one per garment. Two very different industries, two independent preparatory studies, the same answer. If a vendor is selling you item-level serialisation as a DPP requirement, they are selling you something the regulator's own analysts have twice declined to require.
What a fashion brand should do with a steel document
- Sort your data by tier now, on paper. Which fields are a public claim, which are the workings behind a claim, which are proof for an authority. That exercise costs an afternoon and survives whatever the delegated act says.
- Publish declarations, not workings. If you already show a footprint or a recycled content figure, keep the calculation inputs separate in your data model from day one. Merging them is easy later; unmerging them under deadline is not.
- Design at batch level. Item level is a decision you can add for a capsule drop, not a foundation you should build on.
- Assume your supplier detail lands in the restricted tier, not the public one. Both studies point that way. Building your passport on the assumption that everything is public is how brands end up refusing to publish anything at all.
If you want to say something, tomorrow is the day
The consultation is open to anyone, including companies outside the steel sector, on the Commission's Have Your Say portal under Ecodesign requirements for iron and steel products. It closes 12 August 2026 at 23:59 Brussels time. Downstream users of steel, and anyone who will inherit this access model in a later delegated act, are legitimate respondents.
Everyone else: nothing here is an obligation yet. The steel act is expected in Q4 2026, and with the usual transition period the obligations land around 2028. Your own date is in the deadline calendar.
To see what the public tier actually looks like on a product page, our free passport generator builds a live one with a working QR code in about a minute.
FAQ
Does this consultation affect my clothing brand?
Not directly. It is about iron and steel products. It matters because it is the first time the Commission's analysts have converted the Ecodesign Regulation's general passport requirements into a concrete field list with access levels, and later acts, including apparel, are expected to follow the same structure.
What are the three access levels?
Public information available without authentication, information restricted to notified bodies, market surveillance, customs and the Commission, and information available only to persons with a legitimate interest, such as recyclers.
Is my carbon footprint going to be public?
On the steel proposal, the declared value is public and the calculation parameters behind it are restricted to legitimate interest, on the reasoning that inputs and assumptions can reveal operational efficiencies. Whether the textile act mirrors that is not decided yet.
Do I need a unique code on every single item?
Not according to either preparatory study. Steel proposes batch-level identification with item level optional; the apparel study recommends batch as the minimum granularity. Item-level serialisation remains a business choice, not a stated requirement.
When do steel obligations actually start?
The delegated act is indicatively expected in Q4 2026. Obligations follow after the transition period, which puts real compliance around 2028. The act, not the consultation, is the date to watch.