What ESPR specifically requires on data quality
ESPR Article 9 states that product-passport data must be accurate, complete and up to date. That is a legal obligation, not a technical recommendation. Manufacturers issuing passports for product groups covered by a delegated act are responsible for data quality — regardless of whether the data comes from ERP, PIM, PLM or supplier portals.
ESPR Article 10 connects the data carrier to a persistent unique product identifier. Further economic-operator and facility identifiers can be part of the DPP data; delegated acts and technical rules define which identifiers, mandatory fields, data carriers and granularity level apply to each product group.
Data classes that belong together
Centralization does not mean replacing every system. Nulara becomes the product-related compliance layer that references, normalizes and reuses data for passports, audits and reporting.
- Master data & identifiers: Product, variant, model, category and manufacturer — with a stable product identifier plus economic-operator and facility identifiers where the product-group act or data model requires them.
- Material data: Composition, origin, recycled content, SVHC-related substances and substance information by product group for ESPR and SCIP obligations.
- Documents & certificates: Declarations of conformity, test reports, supplier evidence and technical documentation — SHA-256 anchored and versioned.
- Reporting context: Product-level data as supporting evidence for Scope 3, resource-use, recycled-content and circular-economy disclosures in CSRD/ESRS processes, without turning DPP data into a standalone CSRD reporting duty.
From data repository to citable product entity
When product data is central, versioned and linked to sources, the same record can serve a product passport, internal approval, customer request and sustainability report — without manual re-entry or transcription errors.
Nulara structures product data so gaps become visible before a passport is issued or a report is submitted. That is the difference between an assumption and a documented fact.
Sources and next steps
The sources show why product data must stay consistent across compliance, sustainability reporting and product passports.
Read next in Nulara
- CSRD - Context for product-related data in sustainability reporting.
- Digital Product Passport - Foundations for machine-readable product-passport data.
- ESPR - Framework for delegated acts, mandatory fields and product groups.
Primary sources
- EUR-Lex: Regulation (EU) 2024/1781, Articles 9-11 and Annex III - Legal basis for data quality, product identifiers, data carriers, access rights and possible DPP data fields.
- European Commission: corporate sustainability reporting - Official context for the CSRD and European Sustainability Reporting Standards.
- EUR-Lex: Delegated Regulation (EU) 2023/2772 — ESRS - European Sustainability Reporting Standards as the frame for in-scope corporate disclosures.
- GHG Protocol Scope 3 Standard - Methodological frame for corporate value-chain emissions.
- GHG Protocol Product Standard - Methodological frame for product-level life-cycle emissions.
Frequently asked questions
- Does Nulara replace ERP, PIM or PLM?
- No. Nulara structures product-related compliance and sustainability data, can reference existing systems and makes data reusable for passports, audits and reporting.
- What are UPI, UOI and UFI in the ESPR context?
- The unique product identifier connects the data carrier to the product passport. Economic-operator and facility identifiers can be added depending on the data model and product-group act, for example as GTIN, GLN or another ISO/IEC 15459-compatible identifier.
- Why is product data relevant for CSRD?
- CSRD and ESRS reporting is company-level but can use defensible product and value-chain data for Scope 3, resource-use and circular-economy disclosures. Nulara connects product-passport fields with reporting contexts where the same sources are relevant.