Digital Product Passports are coming. Is your data ready?
Digital Product Passports (DPPs) are no longer a future concept. For manufacturers, their introduction could represent a fundamental shift in how product information is created, managed and shared.
- DPPs are becoming mandatory across several EU regulations, led by the Ecodesign for Sustainable products Regulation (ESPR), with more product groups coming into scope over the next few years.
- Compliance is not just about an RFID tag or QR code it depends on updated high quality product data across the lifecycle.
- Early preparation creates an advantage, reducing compliance risk and evidencing valuable use cases over generic ones.
What are Digital Product Passports?
Digital Product Passports (DPPs) are a new way of attaching essential information to physical products in a digital form that can be accessed throughout their lifecycle. At their simplest, a DPP is a structured set of data, accessed via a QR code or similar carrier, that describes what a product is made of, how it performs, where it comes from, and how it can be repaired, reused or recycled. Under the EU’s sustainability legislation, DPPs are intended to make product information more transparent and usable for everyone from manufacturers and suppliers to regulators, repairers and recyclers. As DPP requirements roll out across multiple sectors, manufacturers face a simple question: is your product data ready?
Digital Product Passports in regulation
The EU’s Ecodesign for Sustainable Products Regulation (ESPR) explicitly establishes the Digital Product Passport as the standard way product information must be made available to market actors, authorities and consumers. ESPR has been in force since July 2024, and the first working plan 2025-2030 was adopted in April 2025. But the EU’s clear intention of using DPPs goes beyond ESPR:
- The new Construction Products Regulation, Regulation (2024/3110) has provisions for a construction DPP which should be aligned with the ESPR DPP framework.
- The EU Batteries Regulation (2023/1542) already regulates battery passports with defined data carrier (QR Code) applying from 2027.
- Other initiatives, such as the New Regulatory Framework and the Market Surveillance Regulation have hinted to DPPs as a tool for digitising product information.
It’s clear then that manufacturers will have to adopt DPPs in the near future, and they need to decide if they will treat them as a regulatory burden or as a strategic digital operating layer.
DPPs use visibility and comparability of data as drivers for more sustainable products
The EU is using DPPs to make information on product sustainability, circularity and compliance more usable across the single market; for consumers, manufacturers, authorities, customs, repairers and recyclers. The official direction is clear: product information will increasingly sit in a digital layer tied to the physical product across its lifecycle, covering areas such as technical performance, materials, repair activity, recycling capability and safe end-of-life handling. This makes DPPs more than a static reporting format. They sit at the intersection of regulation, supply chain transparency, repairability, circular business models and industrial competitiveness.
The DPP is also seen as a future proofing tool to facilitate data sharing of product information. This is evidenced in the 2025 European Parliament resolution, which signals that the DPP should play a larger role, not only making product information available, but establishing conformity (potentially replacing current declarations). These trends suggest that the DPP will be eventually become applicable to more product categories, apart from those explicitly included in the current regulations.
Why Digital Product Passports are not just about QR codes
So, the DPP seems like an irreversible development, but in terms of standards and implementation, it is still being operationalised. The regulatory direction is firm, but the implementation architecture is still being defined. The Commission has stated DPP data access should work on a need-to-know basis and rely on open, non-proprietary international standards. CEN/CENELEC Joint Technical Committee 24 are developing a set of standards to be proposed for operationalising the DPP, ranging on subjects like the data carriers, unique identifiers, interoperability requirements, and access rights.
These standards are still in the works and yet to be adopted. For companies, that creates a dangerous temptation: to wait for perfect clarity.
The risk is obvious.
By the time the last details settle in the relevant regulations, the internal data groundwork may still be missing, and implementation timelines will be increasingly challenging.
That internal groundwork is where the real challenge, and a lot of the value, resides.
Manufacturers will need to connect multiple types of information and data points, such as product master data, compliance records, material information, sustainability metrics, repair instructions, service updates and end-of-life guidance across systems that were rarely designed to speak to each other. Some of that information will be public. Some will be tightly role-based and in some cases it will have to be third-party verified.
The value of nuance in data granularity
One of the key design choices and strategies stemming from the DPP is data granularity. The emerging DPP thinking (explicitly in the ESPR legal text) distinguishes between Model, Batch and Item data.
Taking pencils as an example:
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 |
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| Model level | Batch level | Item level |
| A type of pencil of the reference ABC produced by company XYZ | A group of pencils of the reference ABC produced by company XYZ in Factory 123 on a specific date | A pencil of the reference ABC with the specific serial number ABC123456 |
Different levels of granularity entail different types of efforts to source and verify the required data, and may unlock different benefits from a circularity standpoint.
That distinction matters because circularity goals are not all the same. If the objective is product communication, declarations, repair instructions or recyclability guidance, model-level data may be enough.
If the objective is provenance, lot control or process events, batch-level data becomes relevant.
If the objective is repair history, refurbishment, warranty status, targeted recalls, authentication or trusted resale, item-level data starts to matter a great deal.
- Model: Typical information includes recycler instructions, bill of materials and composition. This type of data is expected to remain the same for the same model regardless of other levels of granularity.
- Batch: Relevant for environmental footprint details that vary by facility or date of manufacture.
- Item: Captures lifecycle events like repairs, component replacement, upgrades or remanufacturing. This type of information is of particular importance to high value products or assets.
This shows how data points could vary significantly depending on the product category. The pencil example would likely benefit little from any item-level traceability, while a remanufactured 30 kVA power generator can improve its financial return if item level data is recorded with high quality and accuracy. The effort and time required to implement the DPP and its usefulness for different actors will depend on these decisions.
Is Digital Product Passport compliance enough?
DPP implementation should be greater than mitigating non-compliance risks. Done well, DPP implementation forces a company to clean up product data, clarify internal ownership, and connect engineering, sustainability, IT and aftersales around a shared digital thread.
It can reduce friction in market access and audits, strengthen sustainability claims, support repair and service models, and create the foundations for reuse, refurbishment and other circular revenue streams.
DPPs are meant to help consumers choose better, prolong product lifetimes, improve enforcement and support circular business practices that generate economic value. The companies that see only regulatory cost are likely to miss the much larger operational prize, the DPP is a new communication channel to customers and value chain partners.
Who is impacted by Digital Product Passports?
The first wave of ESPR and CPR delegated acts between 2025 and 2030 is expected to cover a wide range of sectors, based on the confirmed European Commission Working Plan and supporting regulations:
- Textiles and apparel, priority product group, legislation expected 2027
- Furniture, adoption expected 2028
- Tyres, expected 2027
- Mattresses, expected 2029
- Steel and aluminium, adoption expected 2026–2027
- Electronics and ICT, identified as high impact sectors, with delegated acts expected 2027–2028
- Construction products, full DPP implementation from 2026 onwards
- Batteries, first mandatory DPP deadline February 2027
- Toys, first mandatory DPP deadline, 2030
- For some sectors, implementation timelines may be only two to three years from delegated act adoption, leaving limited time for defining data governance and restructuring.
What smart manufacturers should do now to prepare for DPPs
Preparation is key, however, companies that move early should not start with a massive transformation programme based on the implementation of a new platform. They should start mapping the potential use cases for DPPs in their sector and the data needs stemming from these. The European Commission’s Joint Research Centre has published a methodology detailing how to approach this, including considerations like:
- Who are the main actors and stakeholders in the value chain of the product?
- Which specific actors collect, process or rely on product data?
- What information is available to each actor in the value chain?
- How comprehensive, reliable, suitable and accessible are these existing sources of data?
- What concrete use cases can be enabled for the product through the DPP?
- What decisions does each use case support?
- What data is required for this use case?
- What level of detail or aggregation is needed?
From there, the path becomes clearer:
- assign ownership,
- decide what belongs at model, batch and item level,
- map where the data lives today, and
- define the processes and governance needed to manage that data in line with DPP.
Most importantly, identify what business benefits can be captured from it.
Digital Product Passports are moving from concept to reality. The organisations that start getting their product data in order now will be in a much stronger position.
Ricardo can help companies navigate these questions, understand impacts and develop strategies. Now is the time to prepare, so when the regulation kicks in, you can exploit the benefits of the DPP instead of being restricted by a compliance-only approach.
