Digital Product Passport: When Does It Become Mandatory?
Timeline, affected products, and preparation strategies
The Digital Product Passport (DPP) is coming - but when exactly? This question concerns thousands of companies across Europe. The answer depends on your product category, but one thing is certain: preparation should start now, not when regulations take effect.
The Legal Framework: ESPR
The Ecodesign for Sustainable Products Regulation (ESPR) is the foundation for DPP requirements. Adopted in 2024, it replaces the previous Ecodesign Directive and significantly expands its scope. Under ESPR, the European Commission will adopt delegated acts specifying DPP requirements for different product categories.
DPP Timeline by Product Category
Full Battery Passport requirements including carbon footprint, recycled content, and supply chain due diligence. Carbon footprint declarations already required from February 2025.
Expected DPP requirements including carbon footprint data and recycled content declarations.
Material composition, durability information, and recyclability data required for textile products.
Repairability scores, spare parts availability, and recyclability information for electronic devices.
Environmental performance data and lifecycle information for building materials.
Important: Battery Passport Already in Force
The Battery Regulation is separate from ESPR and has earlier deadlines. Carbon footprint declarations are required from February 2025. Companies in the battery value chain should already be implementing solutions.
What Must the DPP Contain?
While specific requirements vary by product category, common elements include: unique product identifier, manufacturer information, material composition, sustainability data (carbon footprint, recyclability), repair and maintenance instructions, and end-of-life handling. Data must be accessible via standardized data carriers (QR code, NFC, RFID).
Core DPP Data Requirements
- Unique product identifier linked to data carrier
- Manufacturer and supply chain information
- Material composition and substances of concern
- Carbon footprint data (where applicable)
- Durability and repairability information
- Recycling and disposal instructions
- Compliance declarations and certifications
Who Is Affected?
Any company placing products on the EU market in affected categories must comply - regardless of where products are manufactured. This includes manufacturers, importers, and in some cases distributors. The entire supply chain needs to contribute data.
Frequently Asked Questions
Do I need a DPP for products already on the market?
Generally no - DPP requirements apply to products newly placed on the market after the respective deadline.
What happens if I don't comply?
Non-compliance can result in products being prohibited from the EU market, significant fines, and reputational damage.
Can I use my existing ERP/PLM data?
Existing data is a starting point, but it typically needs to be standardized, validated, and supplemented for DPP requirements.
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