DPP Agent's Validator Now Checks Against EN 18216 and EN 18219–18223

When the European Commission begins enforcing the Ecodesign for Sustainable Products Regulation (ESPR), the harmonised CEN/CENELEC standards will be the technical reference for whether a Digital Product Passport (DPP) meets its requirements. In May 2026, JTC 24 published six of them: EN 18216 and EN 18219–18223. On 13 June 2026, DPP Agent's public validator was updated to test every passport against them — no waiting until day-one of enforcement to find out where the gaps are.

Update, October 2026: the validator has changed since this was written. It now runs ten checks across seven of the eight standards, and several clause citations in the table below did not hold up against the standards' text and have been dropped from the tool. The current checks are described in all eight DPP standards are published, only six are cited.

This article explains what the validator checks, how to use it, and where the report points you next.

What changed

The DPP Agent validator previously layered three checks: ESPR Base mandatory fields, CIRPASS-2 schema overlays, and category-specific mandatory rows (textiles, batteries, electronics, etc.). With EN 18216 and EN 18219–18223 published, those layers are now anchored to specific clauses of specific standards. Every PASS/FAIL row in the report cites the standard and section it derives from:

If you've used the validator before, the UX is identical — paste a public DPP URL or upload JSON, get a numeric score and a per-row breakdown — but the report now points you at the published standard text for every issue, so a brand's IT team can dispute or fix each finding against an authoritative source.

What the validator actually checks

The validator runs five passes, each independent:

1. ESPR Base mandatory subset

The baseline set of fields we check on every DPP regardless of category: GTIN, product name, brand, country of origin, economic operator identifier, technical documentation reference, manufacturer identifier and facility identifier (ESPR Annex III), TARIC commodity code, batch/lot, serial number. Eighteen rows total. ESPR itself sets no single field list for every product — Annex III lists what delegated acts may require, and each delegated act sets the binding list — so this is a baseline, not a legal minimum.

2. CIRPASS-2 schema overlay

For brands that have implemented the CIRPASS-2 reference shape (nested JSON-LD with economicOperator, manufacturer, circularity, etc.), the validator walks the nested path and emits the same PASS/FAIL rows the ESPR check produced, plus the standards citations live alongside.

3. Category-aware mandatory overlay

Textiles get the AGEC traceability rows: composition, supplier journey steps, microfibre data, care symbols. Batteries get carbon footprint, capacity, recycled content. Electronics get repair score and energy class. Footwear inherits the textile rows plus leather sourcing. The overlay reads from DPP_SCHEMAS and MANDATORY_BY_CATEGORY, so adding new ESPR delegated acts is a config change, not a code change.

4. Brand vs Economic Operator vs Manufacturer separation

ESPR Article 2(46) defines the economic operator — six roles, from manufacturer to dealer. Article 2(42) defines the manufacturer as whoever makes a product, or has it made, and markets it under their own name or trademark. The factory that physically sews it is a different party, identified in the passport by a unique facility identifier (Annex III). These are different fields. The validator now enforces the separation: a passport that puts the same identifier into both gets flagged. Twist & Tango's parent company, Eliasson & Lundgren AB, markets the shirt under its own trademark, so it is the manufacturer in ESPR's sense — but it is not the facility where the shirt is sewn, Dibella in India. The validator catches that conflation.

5. Public URL probe (linkset + landing page)

The validator hits the DPP's public URL with content negotiation and a GS1 linkset request (Accept: application/json, ?linkType=all) and records what it gets back. EN 18222 §4.2 specifies how a passport should respond — the validator surfaces every missing or malformed response.

How to use it

1. Go to dppagent.com/validate
2. Pick URL for a public DPP, JSON for a draft you haven't published, or Compare against to test against ESPR Base / CIRPASS-2 / AGEC overlays
3. Read the report top-down — the percentage at the top is the share of mandatory rows you've satisfied; the table below shows every individual row with PASS / FAIL / PARTIAL and the source standard clause

If you're already a tenant on DPP Agent, the same checks run inline as you build a DPP in Create DPP. The 'Show mandatory' toggle in the enrich step restricts the view to the rows our ESPR baseline marks as mandatory; the 'Show encouraged' toggle adds Article 7 encouraged rows.

What the report tells you to do next

Every FAIL row in the validator report links to either:

• The fix path inside Create DPP — "Click here to edit this field"
• The published DPP Agent documentation — "How do we get this from our PIM?"
• The relevant section of the published standards — for IT-security review

This is the difference between finding the gap and closing it. A brand that runs the validator on its public DPP, hands the report to engineering, and works through the FAILs in order should reach 100% conformance inside a sprint. A brand that waits until enforcement to discover the same gaps will be debugging them under regulatory pressure, with sales channels paused while the rework happens.

Why this matters before enforcement

ESPR's textile delegated act is expected in 2027 (indicative), and its requirements apply at least 18 months after it enters into force. From then — not before mid-2028 — garments in its scope placed on the EU market need a DPP. The market-surveillance authorities will not have the bandwidth to coach individual brands through their first compliance attempt — they will issue notices and pull non-compliant SKUs from the shelf. The validator exists so brands can find every gap, against the actual published standard text, while there is still time to fix them.

Test your DPP at dppagent.com/validate. The report is free, no signup required.

Related reading

• EN 18216–18223: the six CEN standards that define a compliant DPP
• CIRPASS-2: the EU-funded project that prototyped DPP architecture
• GS1 Digital Link: the URL syntax DPP runtime layers expect
• How to create a Digital Product Passport