Digital Product Passport

The DPP is a digital data set that documents the entire life cycle of a product, including all components—from raw material extraction, production, and use, to repair and recycling.

The DPP is being introduced by the European Commission as the core element of the ESPR (Ecodesign for Sustainable Products Regulation). The goal is to promote the circular economy and increase transparency across supply chains. Digital, standardized information will be made available to consumers, processors, repair businesses, and recyclers.

The introduction of the DPP will begin gradually, depending on the respective product regulation.

The first product groups for which the DPP will become mandatory are:

• Batteries: From February 2027 (in accordance with the EU Battery Regulation).

• Textiles and Tires: From 2028/2029 (expected, as part of the first ESPR implementation measures).

• Electronics (specifically smartphones, tablets): Also in the first waves from 2028/2029.

In the long term, the DPP will be extended to almost all physical products placed on the EU market.

The obligation to comply depends on the respective Delegated Acts. The ESPR has entered into force, but the mandate to introduce the DPP only takes effect once the Commission has adopted a specific Delegated Act for a certain product group. This Act will specify a concrete date or a concrete timeframe from which the DPP is compulsorily required for that product group.

The required data varies depending on the product group and is specified in so-called Delegated Acts of the EU. However, data from four main areas must generally be recorded:

• Product Identity: Unique identifier, manufacturer, model.

• Sustainability & Ecodesign: Durability, reparability (instructions, spare parts), recyclability, CO2 footprint (LCA data).

• Materials & Origin: Composition, hazardous substances, proof of origin.

• Compliance: Declarations of conformity, certificates.

These data must be retrievable via a physical data carrier (QR code, NFC, or RFID chip) attached to the product and stored interoperably.

Interoperable means:

• Technical: The data must be available in a standardized, machine-readable format. This is ensured through the use of global standards such as JSON or XML.

• Semantic: All actors understand the data in the same way through an unambiguous definition of terms.

• Organizational: It must be possible to access and exchange this DPP data across company and geographical boundaries.

The biggest hurdle is not regulatory compliance itself, but the operational and technical implementation:

• Data Management: The huge amount of DPP-relevant data is often scattered (across ERP, PIM, and PLM systems) or missing (e.g., CO2 values or data from suppliers). This data must be harmonized, and its accuracy must be guaranteed.

• Interoperability: A technical bridge must be created between the manufacturer's internal systems and the future central DPP system.

• Supply Chain: Integration and data exchange with suppliers are complex, as the information often originates from the entire value chain.

Non-compliance with the DPP obligations poses a high business risk:

• Sales Ban: Products without a legally compliant DPP may no longer be sold or placed on the EU internal market.

• Fines: Companies face significant financial penalties, which can reach substantial amounts in some Member States.

• Competitive Disadvantage: Companies that fail to deliver lose the trust of customers and business partners.

The DPP is far more than just a compliance obligation; it is an enabler for the circular economy and directly creates new business models and strategic competitive advantages:

• "Product-as-a-Service" (PaaS): Through transparent life cycle data, the business model of renting or leasing products becomes more attractive. The manufacturer retains ownership and uses the DPP data for things like planned maintenance.

• Repair and Spare Parts (Aftermarket Revenue): The DPP provides the necessary information (instructions, spare parts, availability) directly to customers and repair services. This increases the repair rate and allows manufacturers to establish a controlled, profitable market for certified spare parts and their own repair services.

• Take-back and Value Creation from Waste: Thanks to precise material information in the DPP, recyclers can sort products more efficiently and recover higher-quality raw materials. Companies that support this system can buy back recycled materials more easily and cheaply (Closed-Loop Systems).

• "Green Premium" Pricing: The sustainability data made transparent in the DPP (e.g., low CO2 footprint, high reparability) can be used to justify a higher price to environmentally conscious customers. The DPP provides the indispensable proof for these "green" statements.

• Product Development Optimization: By accurately tracing defects, repairs, and the end-of-life process, the DPP data provides valuable feedback for the ecodesign of new product generations.

The basis for the DPP is the Regulation on the Ecodesign for Sustainable Products (Ecodesign for Sustainable Products Regulation, ESPR). The ESPR is a framework regulation that enables the European Commission to define the exact requirements and content of the respective DPP for specific product groups (e.g., textiles, detergents, steel) through Delegated Acts.

The specific data requirements (which information must be included in the DPP) and the detailed access rights for various economic operators are not regulated directly in the ESPR, but in the Delegated Acts issued by the Commission for the respective product group. These product-specific legal acts concretize the framework provisions of the ESPR.

Technical standardization, particularly interoperability (the ability of different DPP systems to communicate with each other), is a core element of the ESPR. The Commission has tasked standardization organizations such as CEN and CENELEC with developing the necessary technical standards to ensure that the DPP data can be easily retrieved, read, and exchanged across various IT systems.

The DPP is expected to draw on existing and future international norms and standards. Particularly relevant are standards for product identification (e.g., GS1 standards like GTIN/EAN), data transfer and structure, as well as the work of ISO and UNECE (especially concerning the circular economy and sustainability data).

The responsibility for the accuracy and up-to-dateness of the information contained in the Digital Product Passport lies primarily with the manufacturer or the party placing the product on the EU market. They must ensure that the stored data is correct at all times and complies with the requirements of the respective Delegated Acts.