OYC recommends that bag hardware suppliers collect alloy composition, plating details and restricted-substance test reports while the final textile passport requirements remain undecided. Its guidance cautions that a buckle should not yet be described as DPP-compliant.
OYC recommends collecting six kinds of information: alloy designation and composition, plating-process details, restricted-substance test reports, batch-level traceability, factory identification and durability test data. It also advises keeping reports that can be re-issued and confirmed for each order, rather than relying on a one-off PDF.
For its own hardware, OYC says its die-cast parts use Zamak 3 zinc alloy and that composition documents are available on request. It says it can identify whether a plating line is nickel-free for each finish and support orders with third-party EN 1811 nickel-release reports. The company also says it keeps quality-control records by production run and tests plated finishes with a 48-hour neutral salt spray test.
The EU’s Ecodesign Regulation provides the legal basis for Digital Product Passports. The European Commission says passports will be introduced progressively for selected product groups, with the information required depending on the group. A passport may cover materials, safety, origin, repairability, environmental performance, reuse and recycling; OYC’s checklist does not establish which fields a bag buckle will require.
The Commission’s indicative timetable places adoption of delegated acts for textiles, aluminium and tyres in Q3–Q4 2027. Economic operators will have a transition period of at least 18 months after ESPR delegated acts are adopted.
