.avif)
Introduced under the European ESPR regulation, the digital product passport represents a major shift in information requirements within the European Union. While this tool is still under development, it will be rolled out progressively, with the first products concerned as early as 2027. Manufacturers and other economic operators in the EU affected by this first wave therefore need to start preparing for compliance now. This article covers the definition of the DPP, its rollout timeline and the data it must include.
1. What is the Digital Product Passport (DPP)?
The DPP is a digital information record linked to a physical product placed on the European market or used within the EU. This digital file was introduced in Articles 9 to 15 of Regulation (EU) 2024/1781 of 13 June 2024 (ESPR) on ecodesign requirements for sustainable products. The DPP is thus the EU's main tool for meeting the information obligations set out in the ESPR.
The digital product passport provides a range of data about the item it is attached to. This includes information on the product's environmental impact, its compliance, composition, durability and circularity potential. Hosted online, the DPP must be accessible via a data carrier physically present on the product or its packaging (e.g. a QR code). While some of its features are already known, it is worth noting that this digital tool is still under development.
2. What is the purpose of the DPP?
The purpose of the DPP is to make certain product sustainability information easily accessible to the various players in the value chain. In line with open data principles, it strengthens transparency requirements, with the ultimate aim of encouraging ecodesign practices across all sectors. The digital product passport informs each user according to their specific needs.
Authorities use it to check that products placed on the European market comply with applicable regulatory requirements. Consumers can check the environmental impact, repairability or recyclability of the goods they are considering buying. The DPP thus helps align publicly available data with society's growing demand for transparency. Digital product passports are also very useful for waste management operators, repairers and refurbishers.
They find useful information there to better handle products during repairs or at end of life. More broadly, the digital product passport is a standardisation tool that facilitates data sharing and collaboration throughout the value chain. Future DPP requirements are expected to seek a balance between the need for transparency and the protection of companies' sensitive information.
3. Who is affected by the DPP?
Eventually, most physical products placed on the European market or used within the European Economic Area could be required to have their own DPP. This includes finished products, but also components and intermediate products. However, its rollout will happen progressively. Specifically, a product must have its own DPP where:
- A delegated act adopted under Article 4 of the ESPR regulation and covering the product in question requires it;
- Any other European regulation, particularly sector-specific, makes the DPP mandatory for that product.
-
Responsibility for ensuring a digital product passport complies with regulations lies with the company that places the product on the European market. This is mainly the product's manufacturer or its importer into Europe. Other economic operators, such as distributors and retailers, also have due diligence obligations. Unlike other regulatory frameworks on sustainability information, such as the CSRD directive, companies of all sizes are affected by the ESPR and the DPP.
The European regulation does, however, provide for some exemptions from ecodesign requirements, and therefore from the disclosure of information required via a digital product passport. Exempted items include food, animal feed, medicines and motor vehicles. Products intended solely for defence or national security purposes are also exempt from the DPP requirement.
4. Provisional timeline for the first products subject to the DPP
Some mandatory digital passport dates are already known, particularly for products governed by sector-specific regulation outside the ESPR. At the same time, the ESPR's 2025-2030 work programme sets out the products that must be prioritised for a delegated act. By extrapolation, it is therefore possible to estimate the dates by which the first DPPs under the ESPR are likely to be required. It is worth remembering, however, that the digital product passport is simply a tool for achieving compliance.
Each delegated act associated with the ecodesign requirements for a given product will specify whether and how it uses the DPP. Below are the known dates for the first mandatory DPPs, along with estimated dates for delegated acts on priority products.
There is no precise application date for DPPs covering construction products. However, the CPR Working Plan for 2026-2029, available online, sets out which products will be dealt with as a priority. Other regulatory frameworks incorporate certain elements of the digital product passport without fully adopting it. These include the regulation on critical raw materials (CRMA) and the one on packaging and packaging waste (PPWR).
It is also worth noting that some products originally listed as priorities in the ESPR regulation (Article 18.5) were ultimately excluded from the first wave of delegated acts. Examples include detergents, paints and lubricants. Footwear, considered to have less impact than the products in the table above, will be the subject of a separate study. The same applies to chemical products, which require detailed analysis given how varied they are.
5. What information is expected in the DPP?
The data to be included in digital passports varies depending on the product. Each delegated act adopted under Article 4 of the ESPR, or any other sector-specific European regulation that uses it, will specify the mandatory information to include. Annex III of the ESPR regulation sets out a non-exhaustive list of the types of data that may be required in digital product passports. Below are some of the key pieces of information the DPP may contain.
5.1 Product identification and general information
To facilitate traceability and avoid any ambiguity, each DPP includes a unique product identifier. A unique identifier is also required for the economic operator associated with the product, and another for the manufacturing facility. The user manual, specific instructions, warnings or safety information may also be required in the DPP.
5.2 Product performance
Data on a product's performance may include information such as its energy efficiency, resource consumption and carbon footprint. The product's environmental footprint, calculated for example using the Product Environmental Footprint method, may also be required. More broadly, any of the product parameters listed in Annex I of the ESPR regulation may be requested in this category.
5.3 Product composition
The main materials used in the product and their origins are described in the digital passport. The presence of substances of concern and the proportion of recycled or renewable content or materials may also appear in the DPP.
5.4 Product durability and circularity information
A digital product passport will generally include information on the product's repair, reuse and refurbishment options. Instructions relating to recycling or end-of-life disposal of the product may also be required. In some cases, certain durability data requested may take the form of an index (repairability index, durability index, etc.).
5.5 Product regulatory compliance
The digital product passport naturally includes any information useful for demonstrating its regulatory compliance. This may include the EU declaration of conformity, relevant technical documentation or the necessary compliance certificates.
6. What does a company actually need to do to comply?
A company affected by the DPP must start by determining which of its products are subject to the digital passport requirement. To do this, it needs to refer to the applicable regulations (e.g. ESPR, battery regulation, construction regulation, etc.) and their associated delegated or implementing acts. This makes it possible to identify all the items requiring a DPP, the information required, and the compliance deadlines.
Once this work is done, the company needs to carry out a gap analysis between the data required and the data it already has. It is advisable to map out all internal and external information sources useful for meeting the regulatory requirements. To gather the required data, it may be necessary to use methods such as life cycle assessment (LCA) or its carbon-only version, the PCF (product carbon footprint).
ESG management platforms such as Sami can help considerably with this data collection and analysis work. Once the regulatory information has been gathered, the company subject to the requirement creates its digital product passport. It is possible to use an external service provider to help meet the technical requirements associated with the DPP. If the organisation chooses to host its own DPPs, it will still need to entrust a backup copy to an independent third party. The company is also responsible for integrating the passport access carrier into the production process.
7. Why prepare for the Digital Product Passport now?
Although the first wave of mandatory digital product passports isn't expected before 2028 (excluding batteries), it is essential for affected companies to start preparing now. Indeed, achieving compliance with the DPP and with ecodesign information requirements in general is likely to come with a number of challenges. Collecting and mapping the various required data points can be a long and complex process.
Comparing and selecting a DPP registry provider, implementing the access carrier and final testing of the passport are also time-consuming steps. To avoid any risk of penalties for non-compliance, it is therefore advisable to start preparing as early as possible. While waiting for the specifications of upcoming delegated acts, companies can base their work on the data listed in the ESPR regulation.
Implementing future ecodesign and DPP creation requirements now also means getting ahead of competitors. Even against a backdrop of CSRD rollback, sustainability information remains a priority today for investors, consumers and stakeholders generally. Finally, collecting and analysing data for future DPPs is an opportunity to identify waste and optimise the production chain.
DPP (Digital Product Passport) FAQ
What is the digital product passport?
The digital product passport is an online identity record linked to a product subject to European ecodesign requirements. It includes a number of mandatory and optional data points, depending on the type of item concerned. The digital product passport is accessible to all players in the value chain via an access carrier (e.g. a QR code) placed on the item or its packaging.
Is the DPP mandatory?
The DPP is mandatory whenever a delegated act on ecodesign requirements for a product, or any other sector-specific EU regulation, specifies this. It's important to note that not all products will necessarily be required to have a digital product passport. Eventually, though, most physical goods sold or used in the EU could be affected by the digital passport. Exempted goods include: medicines, food products, motor vehicles and products intended solely for defence and internal security.
What does a digital product passport contain?
A digital passport includes data on the compliance, environmental performance, composition and circularity of the associated product. The list of required information is set out in the delegated acts adopted under Article 4 of the ESPR regulation or any other regulatory framework, particularly sector-specific ones.
When are the first DPPs expected?
The first digital product passports are expected on 18 February 2027. They cover industrial batteries over 2 kWh, electric vehicle batteries and batteries for light means of transport. The next mandatory DPPs could cover iron and steel, at the earliest in 2028, i.e. 18 months after the estimated adoption date of the corresponding delegated acts.
What penalties apply for non-compliance with the DPP requirement?
Penalties for non-compliance with the DPP requirement are not yet known. Each member state, including France, will need to decide on the various levels of penalties it considers appropriate for different non-compliance situations. Article 74 of the ESPR regulation specifies that member states are empowered to impose, at a minimum, fines, as well as time-limited exclusion from public procurement procedures.
Does the DPP requirement apply to non-European products?
Yes, the digital product passport requirement applies to all products placed on the European market or put into service within the EU, regardless of their origin.
Mission Décarbonation
Don't miss the latest climate news and stay ahead of regulatory changes
Explore ALT Impact's best practices to reduce your organzation's digital footprint
The pratical implementation rules fo the Digital Product Passport are currently being developed
Energy-elated products covered by the Ecodesign Directive will progressively fall under the ESPR Regulation
Leard more
Les commentaires