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Starting in 2024, the European Union is implementing a new regulation requiring nearly all products sold in the EU to feature a Digital Product Passport (DPP). This initiative, part of the Ecodesign for Sustainable Products Regulation, aims to enhance transparency across product value chains by providing comprehensive information about each product’s origin, materials, environmental impact, and disposal recommendations.
At the center of this effort is the Digital Product Passport (DPP). The DPP is designed to close the gap between consumer demands for transparency and the current lack of reliable product data.
The Digital Product Passport will become mandatory starting in 2027 for priority product groups, with full rollout expected by 2030.
Companies that sell products in Europe - even if they are headquartered elsewhere - should already be paying attention.
This article explains what Digital Product Passports are, why the EU is introducing them, who will be affected, and what businesses should expect as implementation moves forward.
What is a Digital Product Passport?
Introduced under the Ecodesign for Sustainable Products Regulation (ESPR), the Digital Product Passport is a structured, digital record that provides life cycle data for each product in a standardized format.
It contains essential data such as material composition, carbon footprint, repairability, and end-of-life instructions, which may be accessed via a QR code or similar technology linked to the product.
The goal is not simply to improve transparency for consumers. Digital Product Passports are designed to help manufacturers, suppliers, regulators, repair providers, recyclers, and other stakeholders access reliable product information when they need it.
In practice, DPPs represent a shift from document-based compliance to data-based compliance. Rather than proving compliance through disconnected records, companies will increasingly be expected to maintain accurate, traceable, and accessible product data throughout the entire value chain.
What information can a Digital Product Passport contain?
There is no single Digital Product Passport template that applies to every product.
While the Ecodesign for Sustainable Products Regulation (ESPR) establishes the legal framework for Digital Product Passports, product-specific requirements are still being developed for most industries through future delegated acts. As a result, the information required for a battery, textile product, electronic device, or piece of furniture may differ significantly.
The timeline also varies by industry.
Batteries are currently the most advanced product category. The EU Battery Regulation (EU 2023/1542), which entered into force in August 2023, introduced the legal basis for battery passports. Requirements for electric vehicle batteries, industrial batteries with a capacity above 2 kWh, and light means of transport batteries are expected to become progressively applicable from 2027 onward, making batteries the first large-scale implementation of the Digital Product Passport concept.
Other industries are following a different path. Under the ESPR, which entered into force in July 2024, the European Commission is expected to introduce product-specific requirements through delegated acts over the coming years.
The ESPR Working Plan 2025-2030 identifies several priority sectors, including textiles, furniture, electronics, steel, aluminum, tires, and construction products. Detailed Digital Product Passport requirements for these categories are expected to emerge gradually as sector-specific legislation is adopted.
Although the final requirements are still being defined, the overall direction is already becoming clear. Based on the ESPR framework, the EU Battery Regulation, and technical guidance developed by the European Commission and the Joint Research Centre (JRC), several categories of information are expected to become common elements of many future Digital Product Passports.
| Information category | What it may include |
|---|---|
| Product Identification | Product name, model, SKU, serial number, manufacturer information |
| Material Composition | Raw materials, substances, material breakdown, composition data |
| Origin and Manufacturing | Manufacturing location, country of origin, production information |
| Sustainability Information | Environmental impact indicators, resource consumption, sustainability metrics |
| Recycled Content | Percentage and origin of recycled materials used in the product |
| Carbon Footprint | Product-level carbon footprint and related environmental indicators |
| Compliance Information | Certifications, declarations of conformity, regulatory documentation |
| Repairability and Maintenance | Repair instructions, spare parts availability, maintenance guidance |
| End-of-Life Information | Reuse, refurbishment, recycling, and disposal recommendations |
| Supply Chain Traceability | Information about suppliers, sourcing, and production stages where required |
Not every product category will be required to disclose the same information. Nevertheless, these categories reflect the direction of current EU policy and provide valuable insight into how Digital Product Passports are expected to evolve across industries.
Who is affected by Digital Product Passports?
A common misconception is that Digital Product Passports only affect manufacturers. In reality, DPP requirements are expected to impact a much broader network of organizations involved in designing, producing, importing, distributing, servicing, and recycling products.
Because a Digital Product Passport is intended to provide information throughout a product's lifecycle, the data it contains may originate from multiple participants across the value chain.
Manufacturers are likely to bear primary responsibility for creating and maintaining Digital Product Passports. This may include collecting product data, validating information received from suppliers, ensuring compliance with applicable regulations, and making passport information available through approved digital channels.
Suppliers: many of the data points expected to appear in Digital Product Passports originate far upstream in the supply chain. Material composition, sourcing information, recycled content, and environmental performance data often depend on supplier-provided information. As a result, suppliers may increasingly be asked to provide structured, verifiable product and material data to their customers.
Importers: сompanies importing products into the European Union may also face obligations related to Digital Product Passports. Importers will likely need to ensure that products placed on the EU market meet applicable passport requirements and that the required information is available and accessible.
Distributors and retailers may not be responsible for creating passports, but they will play an important role in ensuring that passport information remains available throughout the product lifecycle. They may also need to support customer access to product information through digital identifiers such as QR codes.
Repair, refurbishment, and recycling operators are expected to benefit from easier access to information about product composition, spare parts, maintenance procedures, and end-of-life handling.
Companies outside the European Union: perhaps most importantly, Digital Product Passports are not limited to companies headquartered in Europe. Any organization that manufactures, imports, or supplies products for sale on the EU market may ultimately be affected by DPP requirements. For many businesses around the world, compliance will become a prerequisite for continued access to one of the world's largest consumer markets.
The DPP is intended to apply to “any physical product that is placed on the market or put into service,” with the exception of a limited list of products (i.e. foodstuffs; animal feed; medicines; veterinary medicines; living plants, animals, or microorganisms; products of human origin; products of plants and animals directly related to their future reproduction; vehicles).
Which industries will be affected first?
Under the ESPR Working Plan 2025–2030 (adopted on April 15, 2025), the European Commission has identified several priority sectors based on their environmental impact, resource consumption, supply chain complexity, and potential contribution to the circular economy.
When will Digital Product Passports become mandatory?
Unlike many regulatory initiatives, Digital Product Passports will not be introduced through a single deadline. Implementation is expected to occur gradually through sector-specific legislation over several years.
| Date | Milestone |
|---|---|
| August 2023 | EU Battery Regulation adopted |
| July 2024 | Ecodesign for Sustainable Products Regulation (ESPR) enters into force |
| April 2025 | ESPR Working Plan 2025-2030 published |
| 2025-2030 | European Commission develops product-specific requirements through delegated acts |
| 2026+ | Product-specific delegated acts begin to emerge |
| 2027+ | First large-scale DPP requirements expected for priority sectors |
| 2030 | Significant expansion across multiple product categories expected |
The ESPR Working Plan 2025-2030 identifies the first product groups expected to receive product-specific requirements and Digital Product Passport obligations.
| Industry | Indicative timeline for delegated acts | Why it is a priority |
|---|---|---|
| Textiles and clothing | 2026 | High waste volumes, low recycling rates, and circular economy objectives |
| Iron and steel | 2026 | Significant environmental footprint and importance for industrial decarbonization |
| Tires | 2027 | Resource-intensive production and recycling challenges |
| Aluminum | 2027 | High energy consumption and importance for industrial decarbonization |
| Furniture | 2028 | Material transparency, durability, and product lifecycle considerations |
| Mattresses | 2029 | Circularity, material recovery, and waste reduction objectives |
For most companies, the key challenge is not the compliance deadline itself but the preparation required beforehand. Building reliable product data, supplier reporting processes, and system integrations often takes years rather than months.
Digital Product Passports are a product data challenge
Digital Product Passports are not primarily a regulatory challenge. They are a product data challenge. Because the information that needs to be in a digital product passport rarely exists in a single system.
Product specifications may be stored in a Product Lifecycle Management (PLM) platform, supplier information may reside in procurement systems, sustainability metrics may come from ESG reporting tools, while certifications and compliance documents are often managed separately. In many organizations, critical product information still exists in spreadsheets, emails, and disconnected databases.Creating a Digital Product Passport requires these data sources to work together.
For many manufacturers, the challenge is not generating a QR code or publishing product information. The challenge is ensuring that the underlying data is accurate, complete, traceable, and consistently maintained throughout the product lifecycle.
The companies best positioned for this transition will not necessarily be those with the most advanced compliance programs, but those with the strongest product data foundations. As Digital Product Passports become a reality across industries, product transparency will increasingly depend on an organization's ability to collect, connect, and govern data across its entire value chain.
How can businesses prepare for DPP?
While product-specific requirements are still evolving, companies do not need to wait for final regulations to start preparing. The foundations of Digital Product Passports are already clear: product data, traceability, and transparency.
Businesses can begin by focusing on five areas:
1. Identify affected products
Determine whether your products fall within priority categories identified by the EU, such as textiles, furniture, tires, mattresses, iron and steel, aluminum, or batteries.
2. Audit product data
Review what product information is currently available and where it is stored. Assess whether critical data such as material composition, supplier information, certifications, recycled content, and sustainability metrics is complete, accurate, and accessible.
3. Map your supply chain
Identify which suppliers contribute information that may ultimately be required in a Digital Product Passport. Understanding data dependencies across the value chain is essential for future compliance.
4. Assess technology readiness
Evaluate whether existing systems - including ERP, PLM, PIM, and supplier management platforms - can support product traceability, data sharing, and lifecycle information management.
5. Monitor regulatory developments
Track delegated acts and industry-specific guidance as they emerge. The exact requirements will vary by product category, making regulatory monitoring an ongoing priority.
Conclusion
Digital Product Passports are moving from concept to reality.
While many product-specific requirements are still being developed, the direction is clear: manufacturers will need to provide more transparent, traceable, and accessible product information across the entire lifecycle of their products.
For businesses, the priority is not waiting for the final rules. It is building the product data, supply chain visibility, and technology foundations needed to support them.
SmithySoft works with manufacturers to build the data, integration, and software foundations needed to support product traceability, transparency, and future Digital Product Passport requirements.
