Digital Product Passports (DPPs) are part of the EU’s current sustainability efforts. They will play a significant role in establishing a circular economy. By collecting all key product information in one place, they foster product sustainability. Soon, DPPs will be mandatory for most products 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.
The implementation will require considerable effort, from data gathering to administration and oversight. At the same time, DPPs create new opportunities to enhance customer relations and business operations. Therefore, businesses should act now to stay ahead of the game.
This article explains what a Digital Product Passport is, and what affected organizations 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 made digitally accessible through a data carrier and a unique identifier (UDI). DPP content will be stored in decentralized online repositories, and businesses will be tasked with maintaining them. The specific format and presentation of this content, however, is yet to be determined in the ESPR delegated acts.
The DPP will apply to all products on the EU market regardless of origin, though some product groups are exempt. Even small businesses will have to comply. However, the ESPR acknowledges the need to minimize administrative burdens for small and medium-sized enterprises (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
The DPP content will vary by product category, as will be specified in the ESPR delegated acts.
However, there are some key elements that every DPP should or may have to include:
- Unique Product Identifier (UID): a unique string of characters, linking a product to its online Digital Product Passport
- Global Trade Identification Number (GTIN): a number standardized by GS1 and ISO/IEC that identifies trade items
- Compliance documentation: declaration of conformity, technical documentation, and conformity certificates
- Relevant commodity codes: standardized numerical systems that classify goods and services for trade, such as TARIC
- Unique facility identifiers (UFI): a specific code assigned to facilities involved in a product’s value chain
- Substances of concern: materials or substance in the product that may be hazardous or hamper reuse and recycling
These key elements ensure that actors along the value chain can easily access and understand product information.
DPP implementation and compliance
Businesses affected by the ESPR will need to consider several aspects concerning DPP content, technical infrastructure, data management, and legal obligations.
Responsibilities and penalties
Businesses and organizations that sell products on the EU market are responsible for ensuring that they have a DPP. Economic operators who fail to maintain accurate and up-to-date information are liable for penalties set by the responsible EU 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 and their impacts.
Access to information
All actors along a product’s value chain must be able to 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, anyone can quickly access a product’s DPP, without the need for dedicated scanner devices.
Data carriers
Crucially, individual products are linked to their DDP through a unique product identifier (UID). For easy access, the UID should be visibly present on the product, its packaging, and accompanying documentation.
This requires a suitable data carrier for the UID. While the exact requirements will be defined in the ESPR delegated acts, there are some general criteria.
The data carriers will have to be:
- able to provide access to the DPP,
- readable to all actors involved, and
- suitable for physical and digital labeling.
For all 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, especially the GTIN, in a web address (URI). The data carrier is typically a GS1 QR Code.
Barcode data carriers can be printed on product packaging, labels, manuals, and documentation. Through the GS1 Digital Link system, they can connect to different resources, depending on who scans them. An end customer would access a different set of information from a manufacturer.
This has usability and security reasons, but also ensures compliance with privacy regulations. The DPP can contain personal information – about previous owners, for instance – and it is important to protect this 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, an EU Joint Research Centre (JCR) study about product prioritization identified the following priority candidates for the first ESPR Working Plan:
- 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
- alumininum
- plastic and polymers
- pulp and paper
- glass
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.
Businesses involved in these product groups should start thinking about DPP implementation now.
Benefits of implementing DPPs
Undoubtedly, implementing Digital Product Passports for all products on the EU market will require a huge effort. The earlier all parties involved in an affected product’s lifecycle begin to think about implementation, the better.
On the flip side, this standardized 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.
With the unique product ID, stakeholders can record and trace every individual item’s history. This simplifies identifying potential bottlenecks throughout the product lifecycle, and thus enables manufacturers to react swiftly. They will be able to optimize processes while at the same time contributing to a more sustainable supply chain.
Gaining consumer trust
Through Digital Product Passports, consumers will be able to make informed decisions about their purchases. With one scan, 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 in general – and has particular benefits for those companies that pioneer in implementing DPPs and actively advertise their usage.
Establishing circular business models
Digital Product Passports open up new opportunities for circular business models. With better access to relevant data, businesses can provide better repair services, improve recycling and remanufacturing, and establish product-as-a-service activities.
Timeline for implementation
Even though the 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.
However, those who start now will have a competitive edge regarding consumer trust, process optimization, and new business opportunities.
Conclusion
The EU is pushing for a more sustainable and circular economy – and it is moving fast. While the ESPR delegated acts are not yet fully specified, economic actors must start preparing now for the significant change they will bring.
Digital Product Passports will catalyze 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 Ecodesign for Sustainable Products Regulation.
