Digital Product Passport advisory for every product

A Digital Product Passport is a structured digital record that carries product information — materials, origin, environmental impact, repair instructions, and end-of-life options — throughout its lifecycle. Rather than a physical label, a DPP is typically accessed via a QR code or data carrier on the product, linking to a rich set of verified data.

Several EU regulations mandate DPPs for products sold in the EU. The Ecodesign for Sustainable Products Regulation (ESPR) provides the overarching framework, while product-specific regulations — including the EU Battery Regulation, the Toy Safety Regulation, the Detergents Regulation, and the Construction Products Regulation — each introduce their own DPP requirements. The goal is to enable transparency, support circular business models, and empower consumers, recyclers, and regulators with trustworthy product data.

Responsible Economic Operators (REOs) — typically product brands and importers placing products on the EU market — bear the primary compliance obligation. They must ensure a DPP is created and made accessible for each product unit or batch.

However, DPP compliance is not a solo effort. Supply chain partners (raw material suppliers, component manufacturers, logistics providers) must contribute the underlying data. Technology providers build the systems that host and exchange passport data. And industry associations often coordinate sector-wide approaches to data models and standards.

Over 30 product groups will eventually need a Digital Product Passport, each at a different stage. Three have confirmed DPP dates: Batteries from February 2027 (Battery Regulation 2023/1542), Packaging from August 2028 (PPWR 2025/40), and Toys from August 2030 (Toy Safety Regulation 2025/2509).

Delegated acts are in preparation for several product groups — including textiles, iron & steel, construction products, washing machines, dishwashers, aluminium, tyres, electronic displays, and detergents. These delegated acts are expected to include DPP requirements, with obligations likely applying around 2028–2029, but this will only be confirmed upon adoption.

The ESPR working plan identifies further products for future delegated acts — including furniture, electric motors, EV chargers, fridges, cooling equipment, mattresses, light sources, tumble dryers, mobile phones & tablets, and welding equipment. No delegated acts have been started for these products, so DPP timelines (indicatively ~2030–2032) remain tentative.

An additional 19 product groups — including computers, air conditioners, vacuum cleaners, and solar panels — are transitioning from the Ecodesign Directive to the ESPR under Article 79. Existing measures remain in effect until 31 December 2026, after which new ESPR delegated acts with DPP requirements are expected — but none have been initiated yet.

See our full product group overview or read our analysis of the expected textile delegated act.

The specific data requirements depend on the product category and its delegated act, but common elements include: product identification, manufacturer details, materials and substances of concern, carbon footprint, recycled content percentages, durability and reparability scores, disassembly instructions, and end-of-life handling guidance.

Beyond regulatory minimums, DPPs can carry voluntary data that supports circular business models — such as proof of ethical sourcing, certifications, or dynamic usage data. The regenerative potential of DPPs lies in going beyond compliance to tell a product's full story.

We are an independent advisory firm — we don't sell DPP software, build platforms, or take commissions from technology providers. This independence means our advice is always in your interest, not shaped by a product we need to sell.

We help you understand what you actually need before you buy anything: readiness assessments, compliance roadmaps, data architecture strategy, vendor-neutral technology selection, and organisational change management. Whether you're a brand, government, supply chain partner, or industry association, we tailor our approach to your role in the ecosystem.

The ESPR applies to all products placed on the EU market, regardless of where they are manufactured. This means exporters to the EU — including manufacturers in Brazil, China, Turkey, Bangladesh, and other major production countries — must comply with DPP requirements for their EU-bound products.

We have particular expertise in bridging EU requirements with production realities in Brazil and Latin America, helping local manufacturers and exporters prepare their data infrastructure and processes for EU compliance. Other regions, including the UK and parts of Asia, are also developing their own product passport frameworks.