Digital Product Passports (DPPs) are part of the EU’s recent sustainability efforts. They will play a significant role in establishing a circular economy – by enabling sharing key product information essential for product sustainability. Soon, DPPs will be mandatory for every product on the EU market.
The first Ecodesign for Sustainable Product Regulation (ESPR) delegated acts, including DPP standards, are expected to enter into force around mid-2027. Economic operators will then have 18 months to comply with the outlined requirements.
Implementation will require considerable effort, from data gathering to administration and bureaucracy. At the same time, new opportunities will open up regarding consumer relationships and enhancing business operations. Therefore, economic operators should act now to stay ahead of the game.
This article explains what a Digital Product Passport is, and aims to give an insight into what affected economic operators need to consider for implementation.
What is a Digital Product Passport?
The Digital Product Passport is a key component of the EU’s Ecodesign for Sustainable Product Regulation (ESPR), an initiative to improve the environmental sustainability, circularity, and performance of products on the EU market.
The DPP, in particular, is part of the effort to transform a global linear economy, where products become waste at the end of their lifecycle, into a circular economy, where waste is prevented by reusing and recycling resources.
DPPs will serve as digital records of product lifecycles, containing information relevant for manufacturers, treatment facilities, consumers, and others. This will include information on:
- Materials and their origins
- Updates on product changes
- Repair activities
- Recycling capabilities
- Substances of concern
- User manuals, instructions, warnings, or safety information
- Disposal recommendations
These digital records will be digitally accessible through a data carrier that links to a unique identifier (UDI). DPP content will be stored in individual online repositories, and businesses will be tasked with maintaining them. The specific format and presentation of this content is yet to be determined in the ESPR delegated acts.
The DPP will apply to all products on the EU market, regardless of their origin. Even small businesses will have to comply. However, the ESPR acknowledges the need to minimize administrative burdens for small and medium-sized businesses (SMEs). Therefore, Member States and the EU Commission will have to assist SMEs with financial support, adequate guidance, and specialized training, among other things.
Key elements of a Digital Product Passport
Specifications for DPP content will vary depending on the product category, as will be specified in the ESPR delegated acts. However, some key elements every DPP should or may include are:
- Unique Product Identifier (UID): a unique string of characters, providing a web link to its Digital Product Passport
- Global Trade Identification Number (GTIN): a number standardized in ISO/IEC that identifies trade items
- Compliance documentation: a declaration of conformity, technical documentation, and conformity certificates
- Relevant commodity codes: a standardized numerical system that classifies goods and services for trade, such as TARIC
- Unique facility identifiers (UFI): a specific code assigned to facilities involved in the import or export of goods
These key elements ensure that actors along the value chain can easily access and understand product information.
Implementation and compliance
Businesses affected by the ESPR will need to consider several aspects concerning DPP content, technical infrastructure, data management, and legal obligation.
Responsibilities
Businesses and organizations that sell products on the EU market are responsible for ensuring that they have a DPP.
Penalties
Economic operators who fail to maintain accurate and up-to-date information will be penalized. The type of penalty will depend on the responsible Member State.
Data requirements
The DPP will include product-specific information defined through delegated acts under the ESPR. Businesses can start preparing by gathering as much data as possible about their products’ lifecycles.
Access to information
Affected economic operators must ensure that all actors along the product value chain can easily access and understand relevant product information. This means that they will have to use a data carrier that is readable by manufacturers, consumers, and national authorities alike – such as a barcode. Thanks to mobile barcode scanner software, they can quickly access a product’s DPP, without the need for dedicated scanner devices.
Data carriers
As with other DPP specific requirements, the ESPR delegated acts will define requirements for suitable data carriers.
Part of a DPP’s content will be a Unique Product Identifier (UID). A suitable data carrier will have to be able to connect to the UDI, while being visibly present on the product, its packaging, or accompanying documentation. Besides that, it must be readable to all actors involved. To ensure comprehensive access, online sellers must receive a digital copy of the data carrier.
For this to happen, global and interoperable standards are needed. The GS1 Digital Link is one such standard. It encodes the most widely adopted product identifiers, like GTIN, in a web address, and is typically encoded in GS1 QR codes.
These data carriers can be printed on product packaging, labels, manuals, and documentation. They can also connect to various resources through the GS1 Digital Link. When scanning the same QR code, a customer would receive different information than a manufacturer. This is an important feature for compliance with privacy regulations, protecting data from unauthorized access.
Accuracy and authenticity
Enterprises have to ensure that the information included in a DPP is authentic and reliable.
Updates
DPPs may need to be updated when new regulations come into force. Enterprises need to keep themselves informed so they can react in a timely manner.
Affected product groups
DPPs are not required for all products, but only for those set in the ESPR product-specific delegated acts. However, the European Commission is still working on the ESPR Working Plan to determine which product groups will be prioritized for DPP implementation. It plans to adopt the first ESPR Working Plan in the first half of 2025.
In November 2024, the ESPR published a Joint Research Centre (JCR) study about product prioritization that came to the following conclusion:
- Textiles and footwear,
- furniture,
- tires,
- bed mattresses,
- detergents,
- paints and varnishes,
- lubricants,
- cosmetics,
- toys,
- fishing gears,
- absorbant hygiene products,
- iron and steel,
- commodity chemicals,
- non-ferrous, non-aluminium metal products,
- aluminum,
- plastic and polymers,
- pulp and paper, and
- glass
are potential priorities for the first ESPR Working Plan.
Batteries are regulated separately, but the battery passport specified in the batteries regulation is supposed to be fully interoperable with the DPP required by the ESPR.
Actors related to these product groups should start thinking about DPP implementation as early as now.
Benefits of implementing DPPs
Undoubtedly, implementing Digital Product Passports for all products on the EU market will require huge effort from all actors involved in the product lifecycle. The earlier all parties involved begin to think about implementation, the better.
On the flip side, a standardized tracing system has benefits for product traceability, resource management, and maintaining consumer relationships.
Enhanced transparency and deeper understanding of supply chains
The Digital Product Passport will gather data about a product’s origin, materials, and environmental impact – centralized in one digital record. This enhances identifying potential bottlenecks throughout the product lifecycle, and thus enables manufacturers to react swiftly. They will be able to optimize processes, while ensuring a sustainable supply chain.
Gaining consumer trust
Through Digital Product Passports, consumers will be able to make informed decisions about their purchases. With one scan using their standard smartphones, they will learn how a product has been sourced, about its production points, and possible repair and recycling instructions. Providing this transparent and verifiable information fosters trust among consumers, especially when companies pioneer in implementing DPPs and actively advertise their usage.
Establishing circular business models
Digital Product Passports open up new opportunities for circular business models. Based on the improved access to relevant data, businesses can start providing improved repair services, and use recycling and remanufacturing to establish product-as-a-service activities.
Timeline for implementation
Even though a timeline for implementation is not yet final, some dates are clear.
The ESPR came into effect on July 18, 2024. The first ESPR delegated acts, including provisions on DPP, are expected to enter into force around mid-2027. Businesses will then have at least 18 months to comply with the ecodesign requirements outlined in the delegated acts. Those who start now will gain a competitive edge regarding consumer trust, process optimization, and new business opportunities.
Conclusion
The EU is on the road to establishing an improved sustainable and circular economy – and it is moving fast. With the ESPR delegated acts not yet fully specified, economic actors must start making plans to prepare for the significant change they will bring.
Digital Product Passports will act as a catalyst for positive change in sustainability and business operations. Businesses can turn to organizations such as GS1, which are already working on solutions, for implementation considerations.
For a more comprehensive understanding of the Digital Product Passport initiative, please refer to the full text of the New Ecodesign for Sustainable Products Regulation.
