EU Regulation
Digital Product Passport (DPP)
Background
Background
The Digital Product Passport (DPP) is a central component of the EU's Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781.
DPP aims to create a digital information carrier that follows the product throughout its entire lifecycle – from raw materials and manufacturing to use, repair, and recycling. By collecting product data in a standardised, machine-readable format, the EU seeks to enable better decisions for consumers, authorities, and actors in circular value chains.
DPP is a cornerstone of the EU's circular economy strategy and Green Deal, intended to contribute to reduced resource use, increased transparency, and improved recyclability.
Scope
Who is affected?
DPP requirements affect manufacturers, importers, and distributors when an applicable ESPR delegated act or other sector legislation requires a passport for the relevant product group. The product-specific act determines the required data, whether the passport applies at model, batch, or item level, and when the obligation starts. Battery Regulation (EU) 2023/1542 contains separate passport requirements for certain battery categories, with its own application dates. Other companies need to follow the ESPR working plan and delegated acts to determine whether and when their products are covered.
Requirements
Key requirements
Where an applicable legal act requires a digital product passport, key requirements include:
- Unique product identifier: The passport must connect to a persistent unique product identifier at the level specified by the act
- Data carrier: A carrier such as a QR code must appear on the product, packaging, or accompanying documentation as specified by the product-specific act
- Standardised data format: Information must be machine-readable, structured, and interoperable
- Content requirements: The product-specific act defines mandatory data fields and access rights
- Accessibility: Relevant actors receive access according to their defined rights
- Updates: The data must be accurate, complete, and up to date
Timeline
Timeline and milestones
- 18 July 2024: The ESPR regulation entered into force
- 2025–2026: The European Commission develops delegated acts with product-specific requirements
- 2027–2030: Phased implementation of DPP requirements for different product categories
Batteries are already covered under the Battery Regulation (2023/1542), with DPP requirements taking effect in stages – EV and industrial batteries from February 2027, LMT batteries from August 2028, and portable batteries from February 2030. Textiles and electronics are expected to be among the first ESPR categories with DPP requirements.
Compliance
Consequences of non-compliance
Where a product-specific DPP requirement applies, non-compliance may mean:
- A covered product without the required passport cannot be placed on the market or put into service
- Market surveillance authorities may require correction, withdrawal, or recall
- Member States determine penalties through national law
- Incorrect, incomplete, or outdated data may make the passport non-compliant
Action plan
What should you do now?
- Monitor delegated acts: Identify which product categories are affected and when requirements take effect
- Inventory product data: Map what data you already collect and identify gaps against expected DPP requirements
- Evaluate IT infrastructure: Assess whether your systems can handle structured, machine-readable product data linked to unique identifiers
- Engage the supply chain: DPP requires data from across the value chain – begin the dialogue with suppliers about material composition and environmental data
- Plan for data carriers: Investigate how QR codes or other data carriers can be integrated into your product labelling and packaging
- Build data quality processes: Establish routines for verifying and updating product passport data
- Connect to existing CE work: Much of the technical documentation for CE marking overlaps with DPP requirements – build on what already exists
Verca
How Verca helps
Verca's platform already collects a significant portion of the data that DPP requires through the CE workflow – material information, risk assessments, test results and standard references.
The platform is progressively expanded with DPP-specific functionality as delegated acts are published, enabling you to export structured product data in the required format.
By managing CE documentation and DPP data in the same platform, you avoid duplication of effort and ensure consistency between regulatory documentation and product passport information. Verca monitors the development of DPP standards and notifies you when requirements affecting your product categories are published.