The saying goes, "you can’t manage what you can’t measure". And soon, you won’t be able to sell it either.
Upcoming regulatory frameworks require businesses to be more transparent about the environmental impact of their products. One of the most significant developments in this space is the Digital Product Passport (DPP), a central element of the EU’s strategy to foster a circular economy.
If your company is in the manufacturing, procurement, supply chain, or ESG sectors, Digital Product Passports are likely to be relevant to your work. While not yet in full effect, DPP requirements are moving quickly from policy to practice, and they’ll introduce new expectations around product data, traceability, and environmental reporting. This guide explains what’s coming, what to watch for, and how to prepare to stay ahead of the curve.
A Digital Product Passport is a digital record attached to a product containing comprehensive data about its materials, sustainability profile, manufacturing history, and more. Under the EU Ecodesign for Sustainable Products Regulation (ESPR), DPPs will be mandatory for many products bought or sold in the EU.
The DPP will be attached to each product in the form of an NFC chip, QR code, or RFID tag, and linked to a cloud-hosted passport that complies with ISO/IEC 15459 for global traceability. Early implementations have already emerged in sectors like electronics, batteries, and textiles, where material provenance and repairability are key.
Unlike standard product specs, a DPP goes beyond production to include resale, repair, and end-of-life, creating new data sharing and governance challenges for product owners. But DPPs aren’t just a regulatory checkbox. For forward-looking businesses, they offer a possibility for a long-term competitive advantage.
While you may still have time before the regulation comes into force for your industry, companies that are early adopters will:
The Ecodesign for Sustainable Products Regulation (ESPR) came into force on July 18th 2024. It outlines the EU’s approach to creating more environmentally sustainable and circular products. The ESPR is part of a number of measures designed to help achieve the 2020 Circular Economy Action Plan (CEAP), which will contribute to helping the EU reach its environmental goals to double its rate of material reuse and achieve its energy efficiency targets by 2030.
Digital Product Passports are included in the ESPR requirements, with the goal to “support products’ sustainability, promote their circularity, and strengthen legal compliance”—key pillars of the European Green Deal.
The EU’s goal with DPPs is clear: to enable a more sustainable, circular economy by improving product transparency. DPPs allow stakeholders to:
Currently, the ESPR has provided preliminary requirements for the DPP relating mostly to its format and implementation. Further guidance on the required content of the DPP is expected to be released in April 2025.
It’s important to note that DPPs differ from traditional systems like product information management systems (PIMs), which focus on marketing and commercial data, and lifecycle assessment tools (LCAs), which provide environmental modeling at a point in time. They combine product ID, sustainability metrics such as product carbon footprint (PCF), and circularity data in a regulated, permissioned format. This introduces challenges around version control, cross-border data access, and reconciling supplier input across complex BOM structures.
Further information on the content of the DPP is due to be released in April 2025. The ESPR includes a list of ecodesign requirements that are likely to be covered by DPPs:
In April, the European Commission will publish a timeline for the adoption of DPPs across predefined product categories. The “working plan” will include product components and groups to be prioritized for ecodesign requirements, as well as regulations prohibiting the destruction of unsold products. The criteria will differ by product type based on materials, processes, and data protection requirements.
On April 9th, 2025, the EU Commission launched a consultation on DPP regulation. The objective is to collect input on how data for DPPs should be stored and managed. Interested stakeholders are invited to give their feedback until July 1st, 2025.
In the future, manufacturers, importers, distributors, and retailers must make DPPs accessible for products sold in the EU. This means that all regulated products in the EU market will have to carry a DPP, whether the manufacturer is registered in the EU or elsewhere.
From 18th February 2027, all industrial and electric vehicle batteries must include a Battery Passport. This will be the first category affected by DPP requirements and will act as an example for the other categories set out below.
For batteries, the data requirements are:
Detailed specifications are available via the Battery Pass initiative.
While finalized requirements are still pending, the ESPR has listed initial product categories to target based on the priorities of CEAP: climate impact, high levels of waste, and potential to enhance circularity. They are:
The European Commission is set to update this list as time progresses. The details will become clearer after April 19th 2025, but the expectation is that DPPs will be phased in over the next five years.
Update: The European Commission has now published the first working plan for the ESPR for 2025-2030. The following groups will require a Digital Product Passport:
The DPP requirements for each group will be set in individual acts.
For now, electronics, energy-related products, and tyres will not require a DPP as they are already covered by energy labeling requirements. A study will be launched by the end of 2025 to determine a more detailed plan for chemicals, as it was deemed a very complex product group. Detergents, paints, and lubricants have been deprioritized.
Getting ready for DPPs means more than collecting data. It requires aligning ESG, IT, and supply chain teams, systems, and processes to generate machine-readable, auditable, product-level sustainability records. Some steps to help you prepare:
To streamline these processes, consider using automation solutions to efficiently gather sustainability data, such as product carbon footprint tools.
As demand for DPP-related data increases, ERP and supply chain solution providers have a valuable opportunity to support their customers by providing access to the necessary data, helping them stay compliant with the requirements and remain competitive in the market.
DPPs will require extensive data collection. Most sustainability, material, and supplier data is fragmented across ERP, Product Lifecycle Management (PLM), and third-party systems. Aligning these into a DPP-ready format will likely require middleware or APIs to translate and validate data in real time. Platforms that can integrate sustainability data and make it accessible alongside existing product metrics will offer a key advantage, providing essential input for DPPs.
For ESG platforms, DPPs introduce new expectations. Customers may expect access to product-level sustainability data (like PCFs) in DPP-ready formats, especially for high impact categories. Platforms might also need to provide additional integration or interface with systems like Product Information Management tools (PIMs) and supplier databases to provide end-to-end support.
Although there is still some time to go before the regulation is implemented, those who invest early in DPP readiness will be ready to capitalize on rising demand and regulatory changes once enforcement begins.
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