DPP compliance is not a one-time task — it's an ongoing operational capability. This checklist helps you build that capability systematically, regardless of how far out your mandatory DPP date is.
Phase 1: Scope and Assess (Month 1–2)
- ☐ Identify which products are in scope — cross-reference your product catalogue with the ESPR working plan and sector-specific regulations.
- ☐ Determine mandatory dates — when does DPP become legally required for your product lines?
- ☐ Assign a DPP project owner — ideally someone who bridges legal, operations, and IT.
- ☐ Conduct a data gap analysis — for each required DPP field, document: do you have this data? In what system? In what format? How accurate is it?
Phase 2: Supplier Data Program (Month 3–5)
- ☐ Map your supply chain to at least tier-2 for regulated materials and conflict minerals.
- ☐ Send supplier data requests — material composition, substance declarations, origin certificates.
- ☐ Include DPP obligations in supplier contracts — make data provision a contractual requirement for new and renewed agreements.
- ☐ Set up a supplier portal — use D-Pass's built-in supplier questionnaire feature or integrate with your existing supplier management system.
Phase 3: Platform and Process (Month 4–7)
- ☐ Select a DPP platform — evaluate on: sector template coverage, API integration capability, multi-language support, QR code generation, verification workflow, data hosting location (EU only for GDPR).
- ☐ Define your DPP workflow — who creates drafts? Who reviews? Who publishes? Who handles updates post-launch?
- ☐ Integrate with your ERP/PLM — DPP data should flow automatically from your product management systems, not be re-entered manually.
- ☐ Set up label printing workflow — QR code generation and label template management.
Phase 4: Pilot and Validate (Month 6–9)
- ☐ Run a pilot on your highest-risk or most complex product line.
- ☐ Commission third-party verification for carbon footprint if required by your sector regulation.
- ☐ Test the consumer experience — scan the QR code with different phones, verify the public viewer loads correctly, check accessibility.
- ☐ Internal audit — spot-check 10% of generated DPPs for data accuracy against source documents.
Phase 5: Scale and Maintain (Month 10+)
- ☐ Roll out to all in-scope products.
- ☐ Establish update procedures — what triggers a DPP update? (New batch, component change, supplier change, new regulation)
- ☐ Monitor regulatory changes — subscribe to Commission updates. Delegated acts can add new required fields.
- ☐ Train relevant staff — product managers, procurement, quality, logistics all need to understand their role in the DPP lifecycle.