Digital Product Passport (DPP): Enabling Circularity Through Transparency
As industries move toward greater transparency and sustainability, the Digital Product Passport (DPP) is set to redefine how businesses track and share product information. Whether you’re in retail, manufacturing, or distribution, adapting to these changes will be key to maintaining compliance and staying competitive. But what exactly does DPP mean for your business, and how can you prepare?
This whitepaper dives deep into the essentials—breaking down regulatory requirements, practical implementation strategies, and the role of PIM in streamlining data management.
With 4,000 words of expert insights, industry analysis, and actionable steps, it’s a must-read for businesses looking to stay ahead of the curve.
Enjoy the read and get ready for the future of product data!
The Digital Product Passport “DPP” is a tool proposed by the EU’s commission as an initiative for enhancing circular economy and sustainability within different industries. The initiative, as part of the Ecodesign for Sustainable Products Regulation “ESPR” aims to enhance transparency across product value chains by providing comprehensive information about each product’s origin, materials, environmental impact and disposal recommendations and instructions [3]. The DPP is designed to close the gap between consumer demands for transparency and the current lack of reliable product information/data. All the data collected and stored in the DPP is shared among stakeholders to ensure full transparency of the product.
Although, the DPP concept has been recently proposed by ESPR in 2021, however, the concept will evolve over time but in its current stage, the DPP is scoped around product sustainability, recyclability, durability and environmental initiatives all of which fall under the “Circular economy” umbrella.
1.2 DPP purpose and objective
The digital product passport purpose is to improve circularity by providing more reliable information which enables a more environmentally conscious decision-making across the value chain and enables tracing of environmental impact and accurate measurements. This can lead to drive economic value, by creating corporate value through collaboration between stakeholders across the value chain.
ESPR aims to significantly improve the sustainability of products placed on the EU market by improving their circularity, energy performance, recyclability and durability. The ESPR replaces the Ecodesign Directive 2009/125/EC and establishes a framework for setting eco-design requirements on specific product groups [1].
1.3 Prioritized industries to implement the Digital Product Passport
While the ESPR will apply the proposal only on energy-related products, the ESPR will extend the scope to all physical products. Only a few products are not in the scope such as; food products and medical products “medical drugs”.
The ESPR highlighted and prioritized the following industries, however the ESPR in collaboration with JRC “Joined research centre” are conducting a study on more industries that will be added to the current list [4]:
Batteries & vehicles
Textiles
Electronics & ICT
Plastics
Furniture
Construction and buildings products/materials
Chemicals
The following industries are excluded from the regulation:
Food and feed
Medicinal products and veterinary medical products
Living plants
Animals and micro-organisms
Products of human origin
Products of plants and animals relating directly to their future reproduction
2 Timeline
2.1 Digital Product Passport Timeline
Under the EGD “European Green Deal” which aims for a long-term goal of enabling Europe to reach net zero emissions by 2050, there is CEAP “Circular Economy Action Plan” which came to force in 11 March 2022 and is directly related to the topic of DPP.
The CEAP strategy and framework for DPP focuses on product sustainability, producing less waste, increase recycling and making more informed decisions related to products.
As per the CEAP guidelines, the prioritized industry is chosen based on their currently high emissions and wastage attributes. All the industries mentioned above are expected to be fully utilising the DPP by 2030 as presented in figure 1” DPP timeline”.
Figure 1 DPP timeline
2.2 Important key dates related to the ESPR
Figure 2 “ESPR key dates” provides important key dates of the ESPR and the European green deal.
Figure 2 ESPR Key dates
3 DPP data collection, requirements and compliance criteria and regulations set by ESPR
In this section, the report covers the type of data collected and stored in the DPP, both mandatory data and voluntary data that companies can include and the ESPR regulation for compliance of product’s DPP.
Ecodesign requirements
The European Commission on 30/3/2022 has proposed the following in “stablishing a framework for setting eco-design requirements for sustainable products and repealing Directive 2009/125/EC”. The commission shall, as appropriate on the relevant product groups and with due consideration for all stages of their life cycle, establish eco-design requirements to improve the following products aspects as mentioned in article 5 (1)
Durability
Reliability
Reusability
Upgradability
Reparability
Possibility of maintenance and refurbishment
Presence of substances of concern
Energy use of energy efficiency
Resources use or resource efficiency
Recycled content
Possibility of remanufacturing and recycling
Possibility of recovery of materials
Environmental impacts, including carbon environmental footprint
Expected generation of waste materials
The Ecodesign requirements as stated in article 5 (5) from (A to F) shall meet the following criteria:
There shall be no significant negative impact on the functionality of the product, from the perspective of the user
There shall be no adverse effect on the health and safety of persons;
There shall be no significant negative impact on consumers in terms of affordability of relevant products, also taking into account access to second-hand products, durability and life cycle cost of products
There shall be no disproportionate negative impact on the competitiveness of economic sectors at least of SMEs
There shall be no proprietary technology imposed on manufacturers or other economic operators
There shall be no disproportionate administrative burden on manufacturers or other economic actors
The commission also highlights the following information to be presented related to substances of concern throughout the product’s life cycle such as:
Name of substance of concern present in the product
The concentration, concentration percentage, or concentration range of substance of concern
Safe instructions for using the product
Information related to disassembly of the product
Instructions on recycling the product or product disposal (end of life cycle)
Information requirements
For a DPP to comply with the regulations set by ESPR the following requirements are essential:
DPP should be uniquely linked to a product
Backup copy of DPP should be available
DPP should be available through the lifespan of the product and not the economical operator
Access through a unique product identifier embedded in the data carrier (QR code, Bar code, etc…)
In case of distance sale “online” access to the DPP should be available
Differentiated access to data is required (e.g., public and restricted data)
DPP should be linked to the EU registry
A copy of the digital product passport must be sent to the EU registry, either by the economical operator “EO” responsible of the product or by an authorised third party per agreement between the EO and the third party as mentioned by Regulation no 2024/1781 [5]. The figure 3 “DPP Compliance Structure” presented below shows the 6 main points for a DPP to be sent to EU registry
Figure 3 DPP Compliance structure
4 DPP data requirements:
While details of specific product groups will be defined in specific delegated acts, the general information requirements are described for the DPP [1] in Article 7 and ANNEX III and Article 9 (A to F) and in accordance to requirements set in Article 10, which specify that this information shall or may include:
Unique product identifier at the level of indicated in the applicable delegated act
Global trade number as provided for in standard ISO/IEC 15459-6 or equivalent of products or their parts
Relevant commodity codes such as TARIC code
Compliance documentation, such as the declaration of conformity, technical documentation or conformity certificates.
Requirements related to substances of concern
User manuals, instructions, warning or safety information/instructions
Information related to the manufacturer
Unique operator identifiers other than of the manufacturer, in particular responsible for product certification tasks
the data carrier and the unique product identifier shall comply with standard (‘ISO/IEC’) 15459:2015
Unique facility identifiers
Information related to importer
Voluntary EU Ecolabels
Information on the performance of the product in relation to the product parameters
Information for users on how to install, use, repair and maintain (care) the product in order to minimise its impacts on the environment and instructions on how to return or dispose of the product at end of life
Other information that may influence the way the product is handled by different stakeholders other than manufacturer
4.1 DPP data sample attributes:
In this section, the report presents a sample of the data that is be found in the digital product passport, (check Figure 4 “DPP sample data” below), within different product categories as described in [1] Article 1 (1), Article 5(1), Article 7(2)(5):
Product General Data:
Product Name
Product Serial Number or ID
Product Size
Product Colour
Product Dimensions: (volume, length, etc…)
Product Listed Price
Batch ID
Batch Date of Production
Manufactured By
Manufactured Location
Packaging Date
Product Sourcing Data:
Material Name
Material Colour (e.g., DIY colour used)
Material Description
Material Type
Material’s Supplier Name
Components Used
Percentage or Concentration of Components Used
Recycled Material’s Name
Recycled Material’s Percentage or Concentration Used
Sustainability Performance and Carbon Footprint Data
Co2 EQV for overall product
Co2 EQV for Production of Product
Co2 EQV for shipping of Product
Co2 EQV for Packaging of Product (can be added to shipping of product and marked as one)
The overall carbon dioxide emissions are the sum of Co2 produced from production, shipping and packaging.
Expected Waste Generation
Providing energy utilization details of product across its life cycle
Emissions to water or air that were emitted within the manufacturing process and what raw materials or components of the product are made from recyclable materials
Certifications
Evidence that shows sustainable practices such as (e.g. use of non-harmful materials and components, safe labour working environment, sustainable raw materials, etc…) were implemented during product life cycle
Evidence of product authenticity to help prevent selling of fraudulent products
Instructions
Instructions on recycling
Instructions on product disposal
Instructions on how to repair, upgrading and dissemble
Instructions of using/maintain product (in case of fashion the instructions can clarify how to wash the product and at what temperature it should be washed at, no use of dry cleaning)
Supply Chain Data
Raw Materials Supplier Name
Raw Materials Supplier Location
Manufacturer Name
Manufacturer Location
Full supply chain Cycle with dates of production and shipping
Figure 4 DPP Sample data
5 Current ongoing work on the DPP prioritized industries by the European commission and authorized organisations/bodies:
The European Commission in collaboration with JRC released a study on 13th of November 2024 one the new product priorities [4]. This report represents the JRC’s final analysis of new product priorities for the ESPR. As a result of the analysis, eleven final products (Textiles and footwear, Furniture, Tyres, Bed mattresses, Detergents, Paints and varnishes, Lubricants, Cosmetics, Toys, Fishing gears, Absorbent hygiene products), seven intermediate products (Iron and steel, Commodity chemicals, Non-ferrous, non-aluminium metal products, Aluminium, Plastic and polymers, Pulp and paper, Glass) and three horizontal requirements (Durability, Recyclability, Recycled content) are identified as potential priorities for the next steps of preparation of the first ESPR Working Plan.
However, the results illustrated are not final decisions: they do not bind the Commission and are without prejudice to what may ultimately be prioritised for first action under ESPR, included in the first ESPR Working Plan, or undertaken under other EU policy frameworks. The link for the report “[4]”.
Adding to this, the methodology applied by the JRC for its analysis supporting the ESPR working plan was based on the criteria for product prioritisation in the Commission’s proposal for the ESPR, and considered environmental, market and economic aspects as well as the extent to which selected product groups are already covered by existing environmental EU policy. The prioritisation criteria considered ten environmental aspects (water effects, air effects, soil effects, biodiversity effects, waste generation and management, climate change, lifecycle energy consumption, human toxicity, material efficiency, and lifetime extension) in terms of global environmental impacts and the potential for improvement in the EU, especially considering what could be achieved via ecodesign requirements under the framework of the ESPR.
6 Current ongoing work on the DPP technical infrastructure:
As the European Commission mentioned, Work is already ongoing. DPP IT architecture will rely on harmonised standards being developed by the European Standardisation Organisations CEN/CENELEC8 (to be delivered before the end of 2025). The European Commission will issue in the coming years up to five delegated and implementing acts under ESPR, relying on those standards and, if necessary, common technical specifications, to define different elements of the DPP IT architecture. Adding to this, the European Commission’s intention is to remain technology neutral while providing relevant criteria to develop necessary standards.
There is no defined template for the DPP or tool available or foreseen. Such a template would depend to a great extent on the requirements established in individual delegated acts for product groups (or horizontally). However, there will be minimum requirements on the content of DPPs for specific product groups. The European Commission expects that Digital Product Passport service providers will include such templates in their services or part of their services provided.
7 Recommendations and future work for Pimberly to follow on the DPP:
As mentioned above, the European Commission is working on setting technical standards for the DPP and studying each product group and communicating with relevant stakeholders and conducting public consultation for defining required information to be found in the DPP for the selected product groups. The EC will publish new delegated acts in 2025/2026 under the ESPR related to:
Information requirements specific for each Product group
Potential compliance certificates and DPP service providers certification scheme
The recommendation is for Pimberly to stay updated with ESPR publications and news, adding to that, since Pimberly joined CIRPASS2 project as a partner, it is recommended for Pimberly to engage with CIRPASS expert group as a leading PIM/DAM software to identify/collaborate on potential work for the DPP. And to stay updated with CIRPASS2 project news and events hosted frequently in Europe.
8 Reference material used for the report:
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC Document No 52022PC0142 30/3/2022. Link:https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A0142%3AFIN
(1)‘product’ means any physical good that is placed on the market or put into service;
(2)‘component’ means a product intended to be incorporated into another product;
(3)‘intermediate product’ means a product that requires further manufacturing or transformation such as mixing, coating or assembling to make it suitable for end-users;
(4)‘energy-related product’ means any product that has an impact on energy consumption during use;
(5)‘product group’ means a set of products that serve similar purposes and are similar in terms of use, or have similar functional properties, and are similar in terms of consumer perception;
(6)‘ecodesign’ means the integration of environmental sustainability considerations into the characteristics of a product and the processes taking place throughout the product’s value chain;
(7)‘ecodesign requirement’ means a performance requirement or an information requirement aimed at making a product more environmentally sustainable;
(8)‘performance requirement’ means a quantitative or non-quantitative requirement for or in relation to a product to achieve a certain performance level in relation to a product parameter referred to in Annex I;
(9)‘information requirement’ means an obligation for a product to be accompanied by information as specified in Article 7(2);
(10)‘supply chain’ means all upstream activities and processes of the value chain of the product, up to the point where the product reaches the end-user;
(11)‘value chain’ means all activities and processes that are part of the life cycle of a product, as well as its possible remanufacturing;
(12)‘life cycle’ means the consecutive and interlinked stages of a product’s life, consisting of raw material acquisition or generation from natural resources, pre-processing, manufacturing, storage, distribution, installation, use, maintenance, repair, upgrading, refurbishment and re-use, and end-of-life;
(13)‘end-of-life’ means the life cycle stage that begins when a product is discarded and ends when the product is returned to nature as a waste product or enters another product’s life cycle;
(14)‘environmental impact’ means any change to the environment, whether adverse or beneficial, wholly or partially resulting from a product during its life cycle;
(15)‘class of performance’ means a range of performance levels in relation to one or more product parameters referred to in Annex I, ordered into successive steps to allow for product differentiation;
(16)‘remanufacturing’ means an industrial process in which a product is produced from objects that are waste, products or components and in which at least one change is made to the product that affects the safety, performance, purpose or type of the product typically placed on the market with a commercial guarantee;
(17)‘upgrading’ means enhancing the functionality, performance, capacity or aesthetics of a product;
(18)‘refurbishment’ means preparing or modifying an object that is waste or a product to restore its performance or functionality within the intended use, range of performance and maintenance originally conceived at the design stage, or to meet applicable technical standards or regulatory requirements, with the result of making a fully functional product;
(19)‘maintenance’ means an action carried out to keep a product in a condition where it is able to function as required;
(20)‘repair’ means returning a defective product or waste to a condition where it fulfils its intended use;
(21)‘durability’ means the ability of a product to function as required, under specified conditions of use, maintenance and repair, until a limiting event prevents its functioning;
(22)‘reliability’ means the probability that a product functions as required under given conditions for a given duration without a limiting event;
(23)‘environmental footprint’ means a quantification of a product’s environmental impacts, whether in relation to a single environmental impact category or an aggregated set of impact categories based on the Product Environmental Footprint method;
(24)‘Product Environmental Footprint method’ means the life cycle assessment method to quantify the environmental impacts of products established by Recommendation (EU) 2021/2279;
(25)‘carbon footprint’ means the sum of greenhouse gas (GHG) emissions and GHG removals in a product system, expressed as CO2 equivalents and based on a life cycle assessment using the single impact category of climate change;
(26)‘public contracts’ means public contracts as defined in Article 2(5) of Directive 2014/24/EU;
(27)‘substance’ means a substance as defined in Article 3, point (1), of Regulation (EC) No 1907/2006;
(28)‘substance of concern’ means a substance that:
(a)meets the criteria laid down in Article 57 and is identified in accordance with Article 59(1) of Regulation (EC) No 1907/2006; or
(b)is classified in Part 3 of Annex VI to Regulation (EC) No 1272/2008 in one of the following hazard classes or hazard categories:
–carcinogenicity categories 1 and 2,
–germ cell mutagenicity categories 1 and 2,
–reproductive toxicity categories 1 and 2, [to be added in the course of the legislative procedure once Regulation (EC) No 1272/2008 contains these hazard classes: Persistent, Bioacumulative, Toxic (PBTs), very Persistent very Bioaccumulative (vPvBs); Persistent, Mobile and Toxic (PMT), very Persistent very Mobile (vPvM); Endocrine disruption],
–respiratory sensitisation category 1,
–skin sensitisation category 1,
–chronic hazard to the aquatic environment categories 1 to 4,
–hazardous to the ozone layer,
–specific target organ toxicity – repeated exposure categories 1 and 2,
–specific target organ toxicity – single exposure categories 1 and 2; or
(c)negatively affects the re-use and recycling of materials in the product in which it is present;
(29)‘product passport’ means a set of data specific to a product that includes the information specified in the applicable delegated act adopted pursuant to Article 4 and that is accessible via electronic means through a data carrier in accordance with Chapter III;
(30)‘data carrier’ means a linear bar code symbol, a two-dimensional symbol or other automatic identification data capture medium that can be read by a device;
(31)‘unique product identifier’ means a unique string of characters for the identification of products that also enables a web link to the product passport;
(32)‘unique operator identifier’ means a unique string of characters for the identification of actors involved in the value chain of products;
(33)‘unique facility identifier’ means a unique string of characters for the identification of locations or buildings involved in the value chain of a product or used by actors involved in the value chain of a product;
(34)‘processing’ means processing as defined in Article 3, point (2), of Regulation (EU) 2018/1807;
(35)‘destruction’ means the intentional damaging or discarding of a product as waste with the exception of discarding for the only purpose of delivering a product for preparing for re-use or remanufacturing operations;
(36)‘consumer product’ means any product, excluding components and intermediate products, primarily intended for consumers as defined in Article 2, point (2), of Directive (EU) 2019/771;
(37)‘unsold consumer product’ means any consumer product that has not been sold or that has been returned by a consumer in view of their right of withdrawal in accordance with Article 9 of Directive (EU) 2011/83/EU;
(38)‘self-regulation measure’ means a voluntary agreement or codes of conduct, concluded by industry sectors on their own initiative, which they are responsible for enforcing;
(39)‘making available on the market’ means any supply of a product for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge;
(40)‘placing on the market’ means the first making available of a product on the Union market;
(41)‘putting into service’ means the first use, for its intended purpose, in the Union, of a product;
(42)‘manufacturer’ means any natural or legal person who manufactures a product or who has such a product designed or manufactured, and markets that product under its name or trademark or, in the absence of such person or an importer, any natural or legal person who places on the market or puts into service a product;;
(43)‘authorised representative’ means any natural or legal person established in the Union who has received a written mandate from the manufacturer to act on its behalf in relation to specified tasks with regard to the manufacturer’s obligations under this Regulation;
(44)‘importer’ means any natural or legal person established in the Union who places a product from a third country on the Union market;
(45)‘distributor’ means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a product available on the market;
(46)‘economic operator’ means the manufacturer, the authorised representative, the importer, the distributor, the dealer and the fulfilment service provider;
(47)‘technical specification’ means a document that prescribes technical requirements to be fulfilled by a product, process or service;
(48)‘harmonised standard’ means a standard as defined in Article 2(1), point (c), of Regulation (EU) No 1025/2012;
(49)‘CE marking’ means a marking by which the manufacturer indicates that the relevant product is in conformity with the applicable requirements set out in Union harmonisation legislation providing for its affixing;
(50)‘accreditation’ means accreditation as defined in Article 2(10) of Regulation (EC) No 765/2008;
(51)‘national accreditation body’ means a national accreditation body as defined in Article 2(11) of Regulation (EC) No 765/2008;
(52)‘conformity assessment’ means the process demonstrating whether the requirements set out in the relevant delegated acts adopted pursuant to Article 4 have been fulfilled;
(53)‘conformity assessment body’ means a body that performs conformity assessment activities including calibration, testing, certification and inspection;
(54)‘notified body’ means a conformity assessment body notified in accordance with Chapter IX of this Regulation;
(55)‘online marketplace’ means a provider of an intermediary service using software, including a website, part of a website or an application, that allows customers to conclude distance contracts with economic operators for the sale of products covered by delegated acts adopted pursuant to Article 4;
(56)‘dealer’ means a retailer or any other natural or legal person who offers products for sale, hire or hire purchase, or displays products to customers in the course of a commercial activity, whether or not in return for payment;
(57)‘distance selling’ means the offer for sale, hire or hire purchase of products, online or through other means of distance sales, whereby the potential customer cannot physically access the product displayed;
(58)‘product presenting a risk’ means a product that, by not complying with a requirement set out in or pursuant to this Regulation other than those listed in Article 65(1), may adversely affect the environment or other public interests protected by that requirement;
(59)‘product presenting a serious risk’ means a product presenting a risk for which, based on an assessment, the degree of the relevant non-compliance or the associated harm is considered to require rapid intervention by the market surveillance authorities, including cases where the effects of the non-compliance are not immediate.
