It is an electronic collection of data assigned to a specific product, its components, or materials. It acts as a kind of digital identity card, showing the product's origin, parameters, composition, compliance with requirements, and selected environmental aspects. The basis for the DPP is the ESPR (Ecodesign for Sustainable Products Regulation), i.e., Regulation (EU) 2024/1781 of the European Parliament and of the Council establishing a framework for setting ecodesign requirements for sustainable products. The regulation entered into force on July 18, 2024.
However, this does not mean that all products will need to have a digital passport from that date. The ESPR regulation creates a legal framework, while specific requirements are and will be defined for individual product groups in relevant delegated acts or separate sectoral regulations. The European Commission currently points to iron and steel, textiles, tires, aluminum, furniture, mattresses, and ICT products as groups covered by work on subsequent requirements.
Which products does the DPP apply to?
One of the most frequently repeated simplifications is the statement that every product placed on the EU market will have to have a Digital Product Passport. In principle, the ESPR regulation covers physical goods placed on the market or put into service, including components and intermediate products, but it also provides for exemptions. These apply to, among others: food, feed, medicinal and veterinary products, live plants, animals, and microorganisms, as well as products of human origin. Furthermore, vehicles are exempt regarding aspects regulated by relevant sectoral legislation. Therefore, a company's first step should be to determine whether and under which legal act a specific product will be subject to the DPP obligation.
What information will be included in the Digital Product Passport?
The scope of data will depend on the type of product and the relevant regulations. There is no single, identical set of information applicable to all industries. Depending on the sector, the DPP may include, among others:
- product, model, series, or batch identification,
- data on the manufacturer and other entities in the value chain,
- material composition and information about components,
- share of recycled materials,
- information regarding durability, repair, and maintenance,
- environmental information,
- instructions for use,
- information regarding compliance with requirements,
- technical documentation and information needed by supervisory authorities.
Our Digital Product Passport (DPP) services
We will help you prepare for the implementation of the Digital Product Passport (DPP).
When do companies need to be ready?
There is no single date for the entry into force of the DPP obligation for all products. Deadlines depend on sectoral regulations.
- Batteries (EU) 2023/1542 (LMT batteries, industrial batteries > 2 kWh, and electric vehicle batteries) – DPP obligation from 18.02.2027
- Detergents and surfactants (EU) 2026/405 – DPP obligation from 23.09.2029
- Toys (EU) 2025/2509 – DPP obligation from 01.08.2030
- Construction products (EU) 2024/3110 – the DPP system is provided for in the regulation, with detailed requirements being developed in subsequent acts; publication planned for Q2 2027.
- Iron and steel – a delegated act is planned as part of the Commission's work for Q4 2026.
- Textiles and clothing – requirements for the DPP will be defined in a future delegated act, with publication planned for Q4 2027.
- Automotive (EU) 2026/1738 (vehicles) – DPP obligation from 01.09.2032
- CRMA (EU) 2024/1252 (critical raw materials) – requirements for the DPP will be defined in a future delegated act
These deadlines should be treated as the status of legislative work as of September 17, 2026, and should be verified on an ongoing basis as new acts are published.
What does the DPP mean for businesses?
For businesses, the biggest challenge may not be creating the Digital Product Passport itself, but rather acquiring, organizing, and maintaining the data that must be included in it. This is a serious matter, as the DPP requires answers to a number of practical questions. What data should be collected? From which systems should it be obtained? Who is responsible for its quality and updates? How can information be linked to a specific product, model, or batch? How can data be obtained from suppliers? And how can a process be prepared that can be adapted to future regulatory requirements?
Therefore, it is worth starting preparations for the DPP by analyzing obligations and data availability, then identifying gaps and determining how to fill them. Only on this basis can the target process for managing and sharing information be designed. In practice, this may mean the need to involve many areas of the organization – from procurement and production, through quality, maintenance, and compliance, to ESG and IT. Cooperation with suppliers will also take on particular importance, as some of the information needed to prepare the Digital Product Passport may be located outside the organization.
Depending on the requirements for a given product group, environmental product data, including the calculation of the product's carbon footprint, may also be a significant part of the process. Preparing this requires not only an appropriate methodology but, above all, access to high-quality data regarding materials, components, production processes, and the supply chain.
VIVERNO supports companies in translating regulatory requirements into practical action. We assist businesses at every stage, from analyzing obligations for specific product groups and identifying data gaps, to preparing data acquisition processes, aggregating data, and developing the required documentation.
It might seem that the Digital Product Passport (DPP) is primarily a technological issue. However, that is only a small part of the new passport reality. We are talking first and foremost about data and process requirements within an organization. The sooner a company determines what information it already has and what it still needs, the easier it will be to prepare for these new obligations.
