ESPR readiness checklist for RMG factories
A Digital Product Passport is only as good as the data behind it. This is the field-by-field list a textile passport needs, where each value normally comes from in a Bangladeshi factory, and the failure mode that most often makes it unusable.
Work through it for one style, not your whole catalogue. A single complete passport tells you more about your gaps than a partial pass over everything.
1. Identity — what the product is
| Field | Usually comes from | Common failure |
|---|---|---|
| Product identifier | Buyer PO / style number | Different identifier used by buyer, factory and lab |
| Style details | Tech pack | Only in PDF, never as fields |
| HS code | Commercial invoice | Held by the shipping desk, never linked to the style |
| Product weight | Spec sheet / packing list | Recorded per carton, not per garment |
| Economic operator | Buyer contract | Unclear who takes responsibility for placing on the EU market |
2. Composition — what it is made of
| Field | Usually comes from | Common failure |
|---|---|---|
| Fibre composition | Tech pack, fabric supplier declaration | Written five different ways; percentages not summing to 100 |
| Recycled content | Supplier declaration, GRS certificate | Claimed but not evidenced to the specific lot |
| Substances of concern | Chemical test report (e.g. REACH, ZDHC) | Report covers fabric, not the finished garment |
| Microplastic release | Fabric testing | Rarely tested at all today |
3. Circularity — what happens to it after
| Field | Usually comes from | Common failure |
|---|---|---|
| Durability / robustness | Physical test reports | Tested to buyer's protocol, not a comparable standard |
| Repairability | Construction detail | No one has ever been asked to record it |
| Recyclability | Composition plus trims | Mixed fibres and hardware make it unanswerable |
| Care instructions | Care label artwork | Exists as an image, not as data |
4. Provenance — who made it, and where
| Field | Usually comes from | Common failure |
|---|---|---|
| Manufacturing steps | Production plan | Subcontracted steps undocumented |
| Facility per step | Order allocation | Known informally, never recorded per order |
| Fabric supplier | Purchase order | Known one tier up; the mill is not |
| Trim / accessory suppliers | Trim card, BOM | Treated as too minor to trace |
| Country of processing | Supplier records | Inconsistent country naming across documents |
5. Proof — evidence tying it together
| Field | Usually comes from | Common failure |
|---|---|---|
| Test reports | Third-party lab | Not linked to the order or style they cover |
| Certifications | GOTS, OEKO-TEX, GRS and similar | Expired, or scoped to a facility rather than the product |
| Declaration of conformity | Compiled at export | Assembled manually per shipment and not reproducible |
The pattern worth noticing. Read down the failure column and almost none of it says "we don't have this." It says the data is in the wrong form, held by the wrong department, or not linked to the product. That is a data problem, not a sustainability one — which is good news, because it is far cheaper to fix.
How to score yourself
For each field above, mark one of three states:
- Structured — the value exists as a field, linked to the style, and you could export it today.
- Held — you have the document, but a human would need to read it and type the value in.
- Missing — nobody has the answer, and getting it requires asking a supplier.
Most factories score heavily in Held. That is the useful finding: the gap between Held and Structured is automatable, whereas the gap between Missing and Held requires supplier conversations that take months. Start the Missing ones now and let the Held ones be solved by tooling.
Where Trazir fits
Trazir scores exactly this checklist automatically. It reads the documents a factory already produces, extracts the fields, links them to the right order and style, and shows which items are structured, partial or missing — per style, before a buyer asks.
See how it works, or read what the EU Digital Product Passport requires for the background behind this checklist.