Digital Product Passport (DPP)

The Ecodesign for Sustainable Products Regulation EU 2024/1781 (ESPR) introduces the Digital Product Passport (DPP). The DPP provides comprehensive information on compliance and sustainability of products to authorities, supply chain ‘actors’ and consumers. To ensure that all stakeholders benefit from this, it is important that there is a standardised format for the information. The basis should be reliable, comparable and verifiable information. The specific details required for products under the ESPR will be outlined in delegated acts. The ESPR just sets out the framework for information requirements and the technical design of digital product passports. Depending on the product groups, there will be information requirements using digital product passports at model, batch or article level (i.e. for individual products, i.e. unit related).

The Digital Product Passport in short

„The digital product passport is a data set that summarises all components, materials, and chemical substances, but also information on repairability, spare parts or proper disposal for a product. The data comes from all phases of the product life cycle and should be able to be used to optimize design, manufacture, use, recycling, re-use and disposal.“ [BMU (2020a)]

It is therefore an important factor in making products sustainable and for the digital transformation as well as for the transformation to a Circular Economy.

Where a product comes from, what it’s made of, how it can be repaired, reused, or recycled. Companies will need to establish structured, centralised product data models, implement open interfaces in line with EN 18222 and EN 18223, and ensure compatibility with classification and identification systems such as GS1, ECLASS, UNSPSC and ETIM.

Objective

The Digital Product Passport (DPP) shall ensure that relevant product information is available digitally, interoperable and in a machine-readable format throughout the entire product life cycle, from manufacturing to recycling. The DPP is intended to ensure greater transparency, sustainability and circular economy in European supply chains.

ESPR is the foundation of the legal framework

The DPP is introduced via the ESPR Regulation, which replaces the previous Ecodesign Directive. It defines the legal framework. Articles 9 to 15 and Annex III contain general requirements related to the architecture, data requirements and registration obligations of the digital product passport. They also specify what information a DPP must or may contain, and how this data must be provided (machine-readable, interoperable, secure) and who is responsible for maintaining, updating and providing access to it. The specific data requirements will then be laid down in delegated acts for each product category.

Product groups and timeline

Through delegated acts, the DPP will gradually become mandatory for various product groups. Currently, only the battery passport has a legally defined timetable. All other timetables are based on EU work programmes and industry information and are therefore marked as estimates in the table below.

Further product groups

Besides the initial product groups, such as batteries, textiles, packaging, and construction materials, further product groups are planned for the Digital Product Passport.

Machinery and industrial equipment

The Machinery Regulation (EU) 2023/1230 does not introduce a digital product passport. However, it promotes the use of digital formats for documentation, instructions and explanations, thereby supporting the gradual digitisation of product information and traceability.

Automotive

DPPs are foreseen for components, spare parts, and remanufactured systems to ensure transparency and lifecycle traceability. The Battery and Battery Waste Regulation is also affecting the automotive industry.

Electrical and electronic equipment

For electrical and electronic equipment (EEE) several industry and standardisation bodies such as ZVEI, VDMA, DKE, DIN, VDE, Bitkom and ECLASS are already working on data models and interoperability standards to prepare the implementation of the Digital Product Passport under the ESPR, particularly in relation to repairability, recyclability, and resource efficiency.

Furniture and consumer goods

Also included in the ESPR Work Programme, these product areas will see delegated acts focused on material transparency, recyclability, and product origin information.

Overall, the DPP will be gradually introduced in more and more product areas and will become the central tool for transparent supply chains and sustainability and traceability data in the EEA.

Further information can be found in the ESPR Work Programme 2025 (COM/2025/187 final).

Structure and Technical Architecture

Generally the DPP exists of three levels:

1. The legal level determines which information must be recorded for each product group.

2. Information must be provided in a machine-readable, structured and interoperable format. Internationally recognised open standards for identification and data exchange define the semantic level for this purpose. The most important of these are GS1, which provides identification and linking structures (e.g. GTIN, GLN, Digital Link QR codes), and ECLASS, which offers a standardised semantic vocabulary for product characteristics, especially for industrial and technical goods. This allows products to be uniquely identified and consistently described.

3. The technical layer describes how systems communicate. Technical interoperability is being defined through the new CEN/CENELEC standards of the EN 1821x series, which form the technical backbone of the DPP.

Note: The listed standards are currently available as drafts (prEN) under the CEN/CENELEC Joint Technical Committee 24 Digital Product Passport.

Standardisation and development status

The eight standards of the EN 1821x series entered public enquiry mid of 2025. Final publication as EN standards is expected in 2026.In parallel, the European Commission, CEN, CENELEC, ECLASS, GS1 and projects such as CIRPASS-2 are testing implementation through pilot programmes.

The following topics were addressed during the 2025 German Market Surveillance Conference, where several industry and authority representatives discussed the upcoming secondary acts planned for mid-2026:

• A delegated act on DPP provider certification,
• implementing acts on operator credentials and the central registry,
• a delegated act on unique identifiers and data carriers.

On the conference also the risk of falsified DPP QR codes has been highlighted and the need for authentication and registry validation.

Additionally the ongoing revision of the New Legislative Framework (NLF, 2025–2027) was presented as a key reform to align CE marking, conformity assessment and market-surveillance processes with the digital product environment.

Digital Product Passport providers

Digital Product Passport providers play a key role in the creation, authentication, processing and storage of passport data. When placing a product on the market, the economic operator must make a back-up copy of the DPP available through an independent third-party service provider. This ensures long-term access to the passport, including in cases of insolvency, liquidation or cessation of activity within the Union.

DPP service providers may also be responsible for managing unique identifiers and data carriers linked to the passport. The European Commission is considering a certification scheme to ensure their reliability and data security.

The DPP itself must include a reference to the service provider hosting the back-up copy.

Manufacturer systems and interfaces

To integrate DPP requirements, manufacturers will need to adapt existing IT systems such as ERP, PLM, or PIM systems that contain much of the data required for the DPP. The main challenge is to make this data interoperable and machine-readable through standardised APIs.

The API (Application Programming Interface) structure and system interoperability will be defined via the new DPP standards EN 18222 and EN 18223. In particular, data exchange (RESTful APIs, JSON-LD), mapping of vocabularies (ECLASS, GS1, ISO, UNSPSC etc.) as well as security, access rights, and integrity.

These standards ensure that systems across Europe can “talk” to each other, regardless of the internal data formats.

EU DPP registry

Article 13 of the ESPR introduces a product passport registry. It shall be set up before 19 July 2026 and maintained by the European Commission. The registry shall at least include a list of the data carriers and unique product identifiers to enable a connection to product passports. The registry stores information included in the products passport, the actual information that needs to be uploaded will be defined in additional legislation (‘delegated acts’) per product group.

Substances of concern and chemical transparency

The Ecodesign for Sustainable Products Regulation (ESPR) explicitly requires that information on “substances of concern” be included in the Digital Product Passport. The information comprises the name, the location and the concentration of the substances of concern and instructions for the safe use and disassembly of the product.

The ESPR defines four groups of “substances of concern” (see ESPR Art. 2(27)(a–d)):

(a) substances of very high concern (SVHC) above 0.1 % w/w under REACH;
(b) substances with specific CLP hazard classes;
(c) substances regulated under the POPs Regulation (EU) 2019/1021; and
(d) substances that negatively affect reuse or recycling.

The challenge we all share

We are facing a huge transformation that will affect all of us, as companies in all roles, from raw material suppliers, chemical producers, component manufacturers, product manufacturers, second-hand users, repair companies, citizens as well as consumers.

Our behaviour and lifestyles, the way products are produced and consumed are to be massively changed in order to be able to live in a more sustainable world.

Sources

Primary EU legislation

• Regulation (EU) 2024/1781 – Ecodesign for Sustainable Products Regulation (ESPR)
• Regulation (EU) 2023/1542 – Batteries and Waste Batteries Regulation
• Regulation (EU) 2022/2399 – Single Window Environment for Customs
• Regulation (EU) 2025/40 – Packaging and Packaging Waste Regulation (PPWR)
• Regulation (EU) 2024/3110 – Construction Products Regulation (CPR)
• Regulation (EU) 2019/1021 – Persistent Organic Pollutants (POPs)
• Regulation (EC) 1272/2008 – Classification, Labelling and Packaging (CLP) of substances and mixtures
• Regulation (EC) 1907/2006 – REACH, Articles 57 and 59 (Substances of Very High Concern criteria)

Delegated acts and programmes

• European Commission Work Programme 2025 – COM/2025/187 final
• CEN/CENELEC JTC 24 – Work Programme 2025

Technical standards and drafts

• prEN 18216 – Digital product passport – Data exchange protocols
• prEN 18219 – Unique identifiers
• prEN 18220 – Data carriers
• prEN 18221 – Data storage, archiving, and data persistence
• prEN 18222 – APIs for the product passport lifecycle management and searchability
• prEN 18223 – System interoperability
• prEN 18239 – Access rights management, information system security, and business confidential
• prEN 18246 – Data authentication, reliability and integrity
• DIN DKE SPEC 99100:2025-02 – Requirements for Data Attributes of the Battery Passport (published February 2025)
• ISO/IEC 15459 – Unique Identifiers for Products and Locations (GS1/ISO Family)
• EN IEC 63278-1:2024 Asset Administration Shell for industrial applications – Part 1: Asset Administration Shell structure
• ISO 23247-1:2021 – Digital Twin Framework for Manufacturing – Overview and General Principles

Projects and expert references

• Battery Pass Consortium (2023–2025) – Content Guidance, Value Assessment and Conformity Assessment (Systemiq GmbH / BMWK)
• CIRPASS 2 Project (2025 – 2027) – Digital Europe Programme Pilot on Digital Product Passport Implementation (Grant Agreement No 101158775)
• GS1 General Specifications v23.0 (2024) – Global identification and digital link standards
• ECLASS Release 14.0 (2024) – Semantic classification and attribute model for technical products

Interpretative and explanatory sources

• White & Case (2024) – Eight Key Aspects of the ESPR – Delegated Acts Expected 2026–2028
• TÜV Rheinland (2024) – Battery Passport Implementation Guide – Mandatory Enforcement from Feb 2027
• Renoon (2024) – Fashion and Textile DPP Timeline Outlook 2028
• Circularise (2024) – EU Battery Passport and DPP Roadmap