Chapter 4 — full chapter

4.4 Making Data Collection a Habit

The biggest risk for any fashion brand is treating DPP preparation as a one-off project. A company might spend six months building its first passport — then, six months later, a supplier changes, a certificate expires, or a product is redesigned. The passport still exists, but the information behind it may no longer be reliable. ESPR requires DPP data to stay accurate, complete and up to date, with controls over who can modify it.

Make data maintenance part of normal product management. The simplest way to do this is to use update triggers. Rather than checking everything constantly, identify the events that should trigger a review. See the examples of potential triggers below.

The principle is simple: no change, no unnecessary work; change, review the relevant data.

When developing a new product

  • Has the product information record been created?
  • Have material and supplier data been captured?
  • Has the evidence been stored?

When approving a new supplier

  • Has the supplier provided the required data?
  • Has the information been verified?
  • Who is responsible for future updates?

When changing a material

  • Does this change affect product information?
  • Does it affect labelling?
  • Does it affect environmental claims?
  • Does it affect chemical compliance?
  • Does the DPP data need updating?

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