EU’s digital product passport: New era for transparency and sustainability

The Digital Product Passport (DPP) is a new regulatory tool introduced by the European Union as part of its Green Deal and Circular Economy Action Plan. Its aim is to collect and provide access to essential data about products throughout their lifecycle—covering materials, origin, carbon footprint, repairability, recyclability, and more. This passport will be mandatory for a broad range of sectors and product categories, particularly those with significant environmental impacts.

 

What sets the DPP apart is its digital-first approach. The information will be accessible via a scannable QR code or similar identifier on the product, leading to an interoperable, standardized database. It’s designed to create transparency across value chains and enable smarter decision-making by consumers, manufacturers, recyclers, and regulators alike.

The DPP also represents a paradigm shift in product governance. Instead of treating sustainability and compliance as an afterthought, it brings them to the design and procurement phase. It empowers a more circular, accountable, and traceable economy.

 

Why the EU Is Leading This Initiative

The EU has long positioned itself as a global regulatory powerhouse, particularly in the areas of environmental and consumer protection. The DPP aligns closely with Brussels’ vision of climate-neutral industry, smart manufacturing, and digital transformation. It builds on the success of existing regulatory frameworks like REACH, RoHS, and Ecodesign directives.

Through the DPP, the EU aims to address pressing issues such as resource scarcity, waste generation, and carbon emissions. Many products today become waste prematurely due to poor information on repair or reuse. The DPP ensures that each product carries with it the metadata needed to extend its life or recycle it effectively.

This leadership is also geo-economic. As supply chains become more scrutinized globally, the DPP strengthens the EU’s influence over international product standards. Exporters to the EU will likely have to comply with DPP requirements, which may set de facto global norms.

How the DPP Works in Practice

Each digital product passport will be sector-specific, with core and optional data elements defined by the EU for each product category. The European Commission, in collaboration with industry stakeholders, will define technical specifications, likely by 2026. Categories such as textiles, electronics, batteries, and construction materials are among the first to be targeted.

For example, a smartphone’s DPP may include data about the source of raw materials, the presence of hazardous substances, energy consumption, software updates, dismantling instructions, and carbon footprint. This data will be digitally linked to the product, typically through a secure QR code or RFID tag.

Data must be verifiable, up-to-date, and accessible to a range of actors—manufacturers, consumers, repair technicians, and recyclers. While the architecture is still under development, blockchain and cloud-based infrastructures are being considered to ensure data integrity and scalability.

 

Industries Most Affected

Industries that rely on complex, global supply chains and that produce material-intensive goods will feel the most immediate impact. The DPP is initially expected to apply to sectors like consumer electronics, batteries, construction products, and textiles—all known for their environmental footprint and lack of transparency.

For the electronics industry, the DPP could significantly change design and compliance processes. Manufacturers will need to rethink how they track components, manage software updates, and provide repair data. Similarly, the textile sector will be pushed to disclose material sources, labor standards, and chemical usage.

While the DPP will create additional compliance burdens, it also opens up new competitive opportunities. Companies that are early adopters and invest in traceability tools and circular design will gain a market advantage as consumers and regulators demand accountability.

 

Benefits for Consumers and End-Users

One of the major goals of the DPP is to empower consumers with knowledge. At the point of sale, a buyer could scan a product and instantly understand its environmental and social footprint—how it was made, where it came from, and how it can be repaired or recycled. This democratizes sustainability.

The DPP also enhances product lifespan and reparability. End-users, including businesses and individuals, will have easier access to spare parts, manuals, and upgrade pathways. This may contribute significantly to the EU’s goal of creating a “Right to Repair” economy.

Moreover, it strengthens consumer trust. In a marketplace saturated with vague “eco-friendly” claims, the DPP adds a layer of verified, standardized data that makes it harder to greenwash. This builds confidence and encourages informed purchasing decisions.

Challenges to Implementation

Despite its potential, the DPP comes with considerable implementation hurdles. Gathering, standardizing, and updating granular product data across complex supply chains will require major investments in digital infrastructure and data governance frameworks.

Small and medium-sized enterprises (SMEs), in particular, may face difficulties integrating with the DPP system. They often lack the resources or technical expertise to build traceability systems or adapt to new digital compliance platforms. The EU has promised to provide support tools, but the readiness gap remains.

Interoperability is another issue. The DPP must integrate with existing ERP, PLM, and supply chain management tools. Ensuring cybersecurity, data integrity, and regulatory enforcement across borders adds further complexity, especially as non-EU companies attempt to enter the DPP ecosystem.

 

Technology Enablers and Infrastructure

The DPP’s success hinges on the technologies underpinning it. These include cloud databases, Internet of Things (IoT), RFID, blockchain, and data-sharing APIs. Companies will need to adopt flexible, secure, and scalable tech stacks to manage their product information efficiently.

Blockchain may play a central role in providing immutable product histories and supply chain transparency, especially for high-risk goods like batteries or textiles. Combined with IoT sensors, it could enable real-time tracking of environmental conditions, usage, and maintenance.

However, a one-size-fits-all tech solution is unlikely. The system will require open standards, sector-specific schemas, and modular architectures to accommodate diverse product categories. Collaboration between tech providers, regulators, and manufacturers is essential to develop agile frameworks.

 

Legal and Compliance Landscape

The DPP is legally backed by the Ecodesign for Sustainable Products Regulation (ESPR), which expands the scope of ecodesign beyond energy-related products. It provides the legal mandate for the European Commission to enforce DPP requirements and ensure industry compliance.

Sanctions for non-compliance could include market access restrictions, fines, and recall obligations. EU Member States will be responsible for enforcement, while the European Commission will provide the central governance architecture. The legal framework is designed to be future-proof and scalable to new sectors.

For legal teams and compliance officers, the DPP means ongoing regulatory monitoring, internal audits, and cross-departmental coordination. It is no longer sufficient to track products post-production; companies must embed compliance from the design phase onward.

Long-Term Impact on Business Models

The DPP is not just a compliance tool—it’s a catalyst for business transformation. By embedding product lifecycle data into supply chains, companies can unlock new revenue streams such as product-as-a-service, extended warranties, and subscription-based maintenance.

It encourages companies to shift from linear “make-use-dispose” models toward circular business models. Manufacturers may increasingly design products for modularity, reuse, or refurbishment, while service providers may develop platforms for second-life markets and repair networks.

In the long term, the DPP could redefine value creation in product-driven industries. Data becomes a key asset, enabling smarter design, better customer engagement, and enhanced ESG reporting. Companies that integrate DPP principles into core strategy may gain a significant competitive edge.

 

Next Steps and Global Outlook

The EU plans to finalize technical DPP standards between 2024 and 2026, with pilot programs already underway in selected sectors. Stakeholders are encouraged to participate in consultations and prepare for phased implementation by assessing digital readiness and engaging in partnerships.

While currently an EU initiative, the DPP may have global ramifications. Much like GDPR influenced global data practices, the DPP could become a benchmark for digital product transparency worldwide. Countries and companies trading with Europe may eventually adopt similar models to remain competitive.

The road ahead is complex but promising. The DPP represents a rare alignment of technology, regulation, and sustainability, offering a framework that could redefine how products are made, used, and valued—within the EU and beyond.