EU’s Digital Product Passport: 6 Keys to Keep Your Products Compliant

The EU Digital Product Passport Is Coming

The European Union is introducing a Digital Product Passport (DPP) system to advance product transparency and sustainability across nearly all industries. As part of the new Ecodesign for Sustainable Products Regulation (ESPR), most products sold in the EU will soon be required to carry a digital passport with information about their origin, composition, environmental impact, and end-of-life handling​.

In essence, a DPP is a digital record of a product’s lifecycle, containing key details such as

• a unique product identifier,
• compliance and certification documents,
• materials and substances used (including any hazardous substances),
• carbon footprint data,
• repairability and maintenance information,
• user manuals,
• and recycling/disposal instructions​

By making this data accessible (for example via a QR code or other data carrier on the product), the EU aims to empower consumers and businesses with reliable product information and support the transition to a circular economy.

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Why Should Manufacturers Care?

The DPP isn't just another regulatory checkbox. It’s a digital profile containing everything from product materials and environmental impact data to maintenance records and recyclability. Failing to comply means products risk market bans, fines, or delays.

But here's the good news: compliance can also mean opportunity. Manufacturers can leverage DPPs for transparency, enhancing customer trust and gaining competitive advantage through verifiable sustainability claims.

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Quick Facts on the DPP:

• Who’s affected first: Batteries, furniture, textiles, electronics, chemicals, paints, lubricants and materials like steel and aluminum.
• What’s required: Unique product identifiers, detailed material composition, environmental metrics, and lifecycle documentation.
• Deadlines: Compliance kicks off from 2027, with registration processes starting as early as 2026.

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OEM Obligations Under the DPP Framework

Manufacturers must prepare for several critical obligations under the EU's DPP legislation:

• Provide Digital Product Passports: Each regulated product requires a structured, digital passport containing comprehensive information such as unique identifiers, material composition, environmental performance, compliance certificates, and user manuals.
• Use Standardized Formats: Digital passports must adhere to standardized data formats and identifiers, like QR codes or RFID tags, compatible with platforms such as the Asset Administration Shell (AAS) and GS1 standards.
• Ensure Lifecycle Traceability: Product passports must capture ongoing data about repairs, maintenance, upgrades, and other lifecycle events. OEMs need to establish data exchange mechanisms with suppliers, service providers, and end-users to ensure the passport remains current and accurate.
• Follow Timelines Closely: The implementation timeline is crucial. Compliance requirements begin to phase in from 2027, with specific sectors like batteries mandated even earlier. Preparation must start immediately to meet these deadlines.

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Getting Started: How to Implement

You probably already have much of the required data—now it’s about structuring and integrating it. Here’s a quick look at the changes needed:

• Product Compliance Teams must establish clear data collection and maintenance processes.
• Supply Chain Teams must enhance traceability of materials and components.
• Digitalization Teams will need to adopt interoperable digital twin standards like Asset Administration Shell (AAS).
• After-Sales Teams should begin systematic collection of product maintenance and repair data.

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Need a Proven Operating Model?

Compliance can be straightforward if approached strategically. We've developed a practical operating model outlining clear roles, responsibilities, and process adjustments for seamless implementation.

Ready to future-proof your products?

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