What is a Digital Product Passport?

What information does a DPP contain?

A Digital Product Passport contains a comprehensive set of product data designed to support transparency, circularity, and regulatory compliance. The exact data fields are defined per product category through delegated acts, but common elements span identification, environmental performance, and end-of-life handling.

Core data categories include:

• Product identification — unique product and batch identifiers, manufacturer details, facility of production, and the product's Global Trade Item Number (GTIN) or equivalent
• Material composition — a full bill of materials including substances of concern above reporting thresholds defined by REACH and the ESPR
• Environmental footprint — carbon footprint per product unit or functional unit, calculated using Product Environmental Footprint (PEF) methodology where specified
• Recycled content — pre-consumer and post-consumer recycled content percentages by weight, verified through mass balance or chain-of-custody approaches
• Durability and reparability — expected product lifespan, reparability scores, availability of spare parts, and warranty information
• Disassembly and repair instructions — step-by-step guidance for repair, refurbishment, or disassembly, supporting right-to-repair objectives
• End-of-life handling — instructions for recycling, safe disposal, and material recovery, enabling waste operators to maximise circular value

Beyond regulatory minimums, DPPs can carry voluntary data supporting circular business models — such as proof of ethical sourcing, certifications, dynamic usage data, or links to regenerative economy initiatives.

Which EU regulations require Digital Product Passports?

Multiple EU regulations now mandate or will mandate Digital Product Passports. The ESPR (Regulation (EU) 2024/1781) provides the overarching framework, establishing DPP requirements for nearly all physical products placed on the EU market through product-specific delegated acts.

In addition to the ESPR, several product-specific regulations introduce their own DPP requirements:

• EU Battery Regulation (Regulation (EU) 2023/1542) — requires battery passports from February 2027, covering industrial, electric vehicle, and light means of transport batteries above 2 kWh
• Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) — requires DPPs for packaging from August 2028
• Toy Safety Regulation (Regulation (EU) 2025/2509) — mandates digital product information for toys from August 2030
• Construction Products Regulation (CPR, Regulation (EU) 2024/3110) — introduces digital declarations of performance and digital product information requirements for construction products
• Detergents Regulation (Regulation (EU) 2024/2847) — introduces digital labelling that may align with DPP infrastructure
• ELV Regulation — proposal includes circularity passports for vehicles, building on DPP architecture

The ESPR delegated acts currently in preparation — for textiles, iron & steel, and other product groups — are expected to add DPP requirements for those sectors. Read our analysis of the expected ESPR textile delegated act or our deep-dive into the Construction Products Regulation and DPPs.

Who needs to comply with DPP requirements?

REOs (Responsible Economic Operators) — typically 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 before the product is placed on the market.

However, DPP compliance is not a solo effort. Four groups of organisations carry responsibilities:

• Brands and importers (REOs) — must create, publish, and maintain the DPP for each product
• Supply chain partners — raw material suppliers, component manufacturers, and logistics providers must contribute the underlying data on materials, processes, and provenance
• Technology providers — build the systems that host, exchange, and verify passport data, including integration with the EU DPP registry
• Industry associations — coordinate sector-wide data models, interoperability standards, and common implementation approaches

The obligations apply regardless of where the product is manufactured. Any company exporting to the EU must comply with DPP requirements for their EU-bound products. This includes manufacturers in China, Turkey, Bangladesh, Brazil, and other major production countries. We have particular expertise in bridging EU requirements with production realities in Brazil and Latin America.

Which products need a Digital Product Passport?

Over 30 product groups will eventually need a Digital Product Passport, each at a different stage of regulatory development. Three product groups have confirmed DPP dates:

• Batteries — from February 2027 (Battery Regulation 2023/1542)
• Packaging — from August 2028 (PPWR 2025/40)
• Toys — from August 2030 (Toy Safety Regulation 2025/2509)

Delegated acts are in preparation for several further 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 applying around 2028–2029, but dates will only be confirmed upon adoption.

The ESPR working plan (COM/2025/187) 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 yet.

An additional 19 product groups are transitioning from the old Ecodesign Directive (2009/125/EC) to the ESPR under Article 79. Existing measures remain in effect until 31 December 2026, with new ESPR delegated acts including DPP requirements expected afterwards. See our full Digital Product Passport advisory page for a complete product group overview.

When do DPP requirements take effect?

DPP requirements are being phased in over several years, starting with batteries in February 2027. Here is the current confirmed and expected timeline:

• February 2027 — Battery passports required for industrial, EV, and LMT batteries above 2 kWh
• August 2028 — Packaging DPPs required under the PPWR
• 2028–2029 (expected) — DPP requirements for textiles, iron & steel, and other product groups under ESPR delegated acts (dates pending adoption)
• August 2030 — Toy digital product information required
• 2030–2032 (indicative) — Further product groups under ESPR working plan delegated acts

Early preparation is critical. Building DPP-ready data infrastructure, aligning supply chain data flows, and selecting technology partners takes 12–24 months for most organisations. Companies in product groups with confirmed dates should already be in active implementation. Those in product groups with delegated acts in preparation should be conducting readiness assessments now.

How does a Digital Product Passport work technically?

A DPP is accessed via a data carrier — typically a QR code, RFID tag, or digital watermark — physically attached to the product or its packaging. Scanning the data carrier provides a link to the structured digital record hosted on a DPP platform.

Key technical characteristics of the DPP architecture include:

• Unique identifiers — each product unit or batch receives a unique identifier, with the ESPR specifying the use of GS1 or ISO/IEC 15459 standards
• Interoperable data formats — DPP data is structured using open standards to enable machine-readable exchange across platforms, supply chains, and regulatory systems
• Tiered access control — different data is visible to different actors: consumers see product information and environmental data, market surveillance authorities can access full compliance documentation, and supply chain partners access what they need for their role
• EU DPP Registry — the ESPR requires all DPPs to be registered in a centralised EU registry, enabling regulatory oversight and cross-border market surveillance
• Persistence — DPPs must remain accessible for at least 10 years after the last unit of a product model is placed on the market
• Decentralised storage — while the registry is centralised, actual DPP data can be hosted by the economic operator or their chosen platform, linked via standardised APIs

The technical specifications are still being finalised through implementing acts and standardisation work at CEN/CENELEC. Organisations should design flexible data architectures that can adapt as standards mature.

How can Regen Studio help with DPP compliance?

Regen Studio is an independent advisory firm — we do not sell DPP software, build platforms, or take commissions from technology providers. This independence means our advice is shaped by your needs, not by a product we need to sell.

Our DPP advisory services include:

• DPP readiness assessments — evaluate your current data maturity, identify gaps, and map the path to compliance
• ESPR compliance roadmaps — regulation-specific guidance covering timelines, data requirements, and organisational responsibilities
• Data architecture strategy — design data models and governance structures that serve both regulatory compliance and business value
• Vendor-neutral technology selection — evaluate DPP platforms and tools without conflicts of interest
• Supply chain traceability design — map data flows from raw materials through production and distribution
• Circular business model integration — go beyond compliance to leverage DPP data for repair, resale, and recycling services

We work with brands, governments, supply chain partners, system providers, sector associations, and research institutes. Whether you are just starting to explore DPP requirements or are deep in implementation, we tailor our approach to your stage and role in the ecosystem.