Overview of the EU Digital Product Passport Regulation
Date of publication: November 7th, 2024
In Europe, the ongoing shift toward sustainability has placed a growing emphasis on product transparency. At the forefront of the European Commission’s latest regulatory green initiatives is the Digital Product Passport (DPP). The DPP regulation is a new scheme aimed at enhancing the transparency and traceability of product information throughout the entire product lifecycle.
Set to launch in 2026, the DPP is expected to redefine how businesses operate, offering a roadmap to greater efficiency, compliance, and sustainability in retail. Businesses should start preparing for this transformation now to stay ahead of the regulatory curve.
Overview
The DPP is one of numerous regulatory initiatives introduced under the
EU Ecodesign for Sustainable Products Regulation (ESPR)
. The ESPR is part of The Green Deal, excluding only food, feed and pharmaceutical products. The ESPR aims to enhance transparency across product value chains by providing comprehensive information about each product’s origin, materials, environmental impact, and disposal recommendations, thereby supporting environmentally friendly business practices. The DPP is designed to close the gap between consumer demands for transparency and the current lack of reliable product data.
Once the ESPR goes into effect, it will require "nearly all products sold in the EU to feature a digital product passport.” This means that even businesses outside the EU must comply if they wish to sell their products within the EU market.
The DPP is a digital document provided to stakeholders, which will include essential details such as a unique product identifier, compliance documentation, and information on substances of concern. It will also provide user manuals, safety instructions, and guidance on product disposal. It can be accessed through a QR code, NFC chip, or RFID tag. By offering a detailed digital record of a product’s lifecycle, the DPP will enhance supply chain management, ensure regulatory compliance, and help companies identify and mitigate risks related to authenticity and environmental impact.
Objectives driving the initiative
The primary goal of the DPP is value retention. Keeping products and materials at the highest quality for the longest amount of time possible. And at the end of their lifecycle, they are remanufactured or recycled to the highest quality. Another main goal of the DPP is to give (and simplify) access to relevant information for all stakeholders.
Other goals worth mentioning include:
- Improved product safety: Enhance consumer protection by providing accurate and timely information on product safety and performance, including certifications, test results and instructions.
- Increased transparency: Facilitate the traceability of products throughout the supply chain, enabling better monitoring and enforcement of EU regulations. It will provide detailed product data, such as origin, materials, environmental impact, recyclability – all accessible electronically at all stages of the value chain.
- Simplified compliance: Reduce the administrative burden on businesses by providing a standardized, digital format for product information across the ESPR and other EU regulations.
- Environmental and social benefits: Encourage sustainable production and consumption practices by providing information on environmental and social impacts, such as carbon emissions, resource use and recyclability.
- Traceability: Enables tracking of a product’s lifecycle—from raw materials to disposal—improving supply chain visibility and accountability.
- Circular economy: Encourages longer product lifespans by detailing repairability, reusability, and the presence of hazardous materials, reducing waste.
- Digital transformation: Utilizes technologies like blockchain and IoT to provide real-time, verifiable access to product data across the supply chain.
- Data security and privacy: Protects sensitive data from bad actors while maintaining transparency for regulatory and sustainability purposes.
Impacted parties
The responsibility for ensuring compliance with DPPs extends beyond the borders of the EU. Not only will finished products sold in the EU need to adhere to DPP regulations, but also any components, materials, or semi-finished goods involved in their production, regardless of their origin. This will force suppliers and manufacturers worldwide to gather and submit the DPP data for their products destined for the European market.
The EU has identified several priority categories for both finished end-use products and intermediate materials and components. These will be among the first required to create DPPs for goods produced. These priorities include sellers of batteries, textiles (garments and footwear), iron and steel, aluminum, furniture (including mattresses), tires, detergents, paints, lubricants, chemicals, and electronics. The commission has the power to extend the list of currently prioritized categories in the future to include products such as toys, cars and construction-related materials.
Businesses engaged in product sales within the EU market will be obligated to furnish a DPP encompassing the final product as well as its constituent components. While this regulation pertains specifically to the EU, its ramifications will extend globally.
Interested parties can include the following:
- Manufacturers and producers: Companies producing goods for the EU market, including those in the European Economic Area (EEA).
- Importers: Businesses importing products into the EU/EEA.
- Distributors: Companies involved in the distribution of products within the EU/EEA.
- Retailers(selling products to end-consumers in the EU/EEA)
- Consumers: the DPP will tell them where a product was sourced, what it’s made of, or how environmentally friendly it is. This transparency allows consumers to make decisions that reflect their priorities, such as choosing eco-friendly or ethically sourced products.
How it will work
Keep in mind that the official standards still need to be set. The EU still needs to define the DPP framework and processes, but these areas will give you an idea of what to expect. Data collected and shared in the DPP will focus on three key areas:
- Performance - metrics of a product that help show the functionality and efficiency (e.g., energy efficiency, durability and material use)
- Sustainability – reducing environmental impact (e.g., carbon footprint, chemical safety and resource efficiency)
- Circularity – reuse, repair and recycling (e.g., repairability, recyclability and end of life management). This is also a key contributor to the Circular Economy Action Plan (CEAP).
The Digital Product Passport will need to contain essential product information, such as:
- Product identification (e.g., serial number, batch number)
- Economic Operator Identifier
- Facility Identifier
- Registration Identifier (not public)
- Product characteristics (e.g., materials, dimensions, weight)
- Safety and performance information
- Environmental and social impact data
- Supply chain information (e.g., country of origin, manufacturing process)
With respect to data, the following key points should be kept in mind:
- Data quality and accuracy: Manufacturers must ensure the accuracy, completeness, and timeliness of the data provided in the DPP.
- Data accessibility: The DPP must be easily accessible to stakeholders throughout the product lifecycle, including consumers, authorities, and other businesses.
- Interoperability: The DPP must be compatible with existing systems and formats, allowing for seamless data exchange between stakeholders.
Each product group/industry will have its own data requirements. You’ll need to collect that data from your supply chain partners. You’ll need a solid product database to help store and work on all this information across your product catalog.
Timelines
- December 2019: Adoption of the European Green Deal, which set the stage for the DPP initiative with the goal of making the EU climate neutral by 2050.
- March 2020: The EU Circular Economy Action Plan was adopted, further supporting sustainable production and consumption, which led to the creation of the DPP.
- March 2022: A proposal for the Ecodesign for Sustainable Products Regulation, which includes DPP information requirements, was introduced.
- December 2023: A provisional agreement on the ESPR and DPP legislation was reached between the European Parliament and European Council.
- April 2025: The European Commission is scheduled to publish its first working plan outlining the initial product groups prioritized for ecodesign regulations, including those subject to DPP requirements.
- Nothing will officially be enforcedbeforeJuly 19, 2025.
- July 19, 2025: The destruction of unsold consumer products will be prohibited
- No later than December 2025: The European Commission will have a definition of the harmonized standards.
- January 2026: expected publication of the delegated acts for textiles
- April 2026: expected publication of the delegated acts for iron and steel
- By 2026: digital battery passports will be mandatory for specific types of batteries
- July 2026: Deadline for the European Commission to establish the DPP registry, which will house unique identifiers connected to products.
- February 2027: Batteries will be the first product group for which the use of a DPP becomes a legal requirement under the recently adopted Battery Regulation.
- July 2027: compliance deadline for textiles
- October 2027: compliance deadline for iron and steel
- By 2030digital product passports will be fully implemented for every product sold in the EU.
- On July 19, 2030, the European Commission will evaluate the effectiveness of the DPP (and will do so every 6 years).
Impacted companies should start taking steps now to ensure they have the right technology strategies in place to prepare for the DPP.
For more information on how ONESOURCE Global Trade solutions can assist you in managing your global trade compliance obligations, please contact your Account Manager or Client Services Manager.