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Digital Product Passport: Shaping the Future of Sustainable Products
The Digital Product Passport (DPP) under the Ecodesign Regulation will enhance product transparency and compliance, with the first implementation expected by mid-2027.
- The DPP shall be introduced for certain product groups under the Ecodesign for Sustainable Products Regulation (ESPR), for which the first delegated acts are expected by mid-2027.
- The DPP aims to provide easy access to key product information across the value chain and to facilitate authorities monitoring compliance.
Key takeaways
The European Union is taking another step toward sustainability with the Digital Product Passport (DPP), a key initiative under the Ecodesign for Sustainable Products Regulation (ESPR). This digital tool intends to make product information more accessible and transparent, covering details on a product's lifecycle from production to disposal. The DPP will play a crucial role in the EU’s broader strategy for promoting a circular economy and sustainable product design.
Overview of the Digital Product Passport (DPP)
The Digital Product Passport is a forthcoming system designed to store and share essential information about a product, helping businesses, regulators, and consumers make more informed choices. By providing transparency on materials, sustainability, and compliance, the DPP aims to support the transition to a greener economy. Product information will mainly be made available via the DPP, while European Product Registry for Energy Labelling (EPREL) will continue to apply for products covered by energy labelling regulations.
Timeline and Scope of the DPP
The first implementation of the DPP is expected by mid-2027, in line with other ecodesign requirements under the ESPR.
The DPP will apply to companies placing products on the European market, whether produced inside or outside the European Union. Initially, it will be limited to selected product groups, similar to how electric vehicle batteries already require a digital passport under the Batteries Regulation.
Not every product will require a DPP. The European Commission will decide which product groups must comply through specific delegated acts. In some cases, only certain components (e.g. parts of a product, such as the batteries) may require a DPP while the rest of the product does not. Additionally, if other EU regulations provide equivalent transparency tools, some products may be exempt.
The exact data requirements will be defined through consultation with stakeholders, ensuring that the DPP is both practical and comprehensive. The aim is to include relevant lifecycle information, such as materials used, recyclability, and compliance details. Information on material composition and any substances of concern in the product will be included, along with guidance on safe usage, recycling, and disposal.
Technical Implementation of the DPP
The DPP system is still under development, with European standardization bodies (CEN/CENELEC) working on technical guidelines. The EU Commission will set the framework for the DPP’s IT infrastructure, ensuring compatibility with various technologies while remaining neutral on which technology should be used. The Commission has initiated the standardization process to establish rules on data carriers, infrastructure, and data interoperability, which are essential for the development of the product passport system.
Compliance and Enforcement of the DPP
Manufacturers and other economic operators placing products on the market shall be responsible for ensuring the accuracy and completeness of DPP data. For that purpose, the market surveillance authorities in the Member States will monitor compliance, and impose penalties. Penalties for infringements will be determined by each EU Member State and will be designed to be effective, proportionate, and dissuasive.
Environmental Impact of the DPP
The environmental footprint of the DPP itself—including data storage and transfer—will be carefully assessed. The goal is to ensure that the benefits of increased transparency and sustainability outweigh any potential negative impacts. The DPP will ensure traceability along the value chain after the product has been placed on the market, potentially boosting the voluntary deployment of traceability solutions and promoting sustainable trade beyond EU borders.
Conclusion
The Digital Product Passport represents a major step toward making products more sustainable. By giving consumers, businesses, and regulators access to key lifecycle information, it will encourage better purchasing decisions, improve compliance, and promote innovation in sustainable design. With implementation expected to start in 2027, the DPP will mark the cornerstone of the EU’s circular economy strategy.
The Digital Product Passport is a game-changer for transparency, compliance, and sustainability, helping the EU transition to a more sustainable and circular economy.
Action Points
- Conduct a Product Inventory Assessment: Companies should begin by thoroughly reviewing their product portfolio to identify which items could fall within the scope of the DPP once implemented. This involves assessing materials used, product components, and any existing compliance documentation. Understanding the current product portfolio will help companies prepare for upcoming requirements and identify areas for improvement.
- Develop Internal Data Management Systems: Companies should start developing or enhancing their internal data management systems to ensure they can accurately collect, store, and share the necessary product information required under the DPP. This includes establishing protocols for tracking material composition, recyclability, and compliance details. By proactively setting up these systems, companies will be better positioned to meet the DPP requirements once they are finalized and implemented.
- Contact your EY Law contact person in case of questions.
