What is the digital product passport, and which companies are affected?

The Digital Product Passport (DPP) is a digital ID linked to a product, accessible via a QR code or a microchip. It centralizes the product’s sustainability data: composition, origin, carbon footprint, percentage of recycled materials, repairability, availability of replacement parts, and end-of-life guidelines.

It is established by the European Regulation on the Ecodesign of Sustainable Products (ESPR, Regulation (EU) 2024/1781), which entered into force in July 2024. It will become mandatory on a phased basis, product group by product group, starting in 2026–2027. This applies to all companies that manufacture, import, or distribute products placed on the European Union market in the priority categories: textiles, iron and steel, aluminum, furniture, mattresses, tires, and batteries.

Key Takeaways

• The DPP is a digital sustainability ID card that can be accessed via a QR code.
• It was established by the ESPR Regulation (EU) 2024/1781, which has been in effect since July 2024.
• The European Central DPP Registry must be operational by July 19, 2026.
• First mandatory passport: the battery passport, effective February 18, 2027 (EU Regulation 2023/1542).
• This applies to manufacturers, importers, and distributors who sell products on the EU market, including those outside Europe.
• The product's carbon footprint (PCF, ISO 14067 standard) is among the key data points that must be reported.

What is a digital product passport?

A digital product passport is a structured, machine-readable record of data that is physically linked to the product via a data carrier (QR code, barcode, or RFID chip). By scanning this carrier, each stakeholder in the supply chain (consumer, retailer, repairer, recycler, regulatory authority) can access the information that pertains to them.

How does it actually work?

A unique identifier links the physical product to its digital record hosted online. A consumer who scans a clothing tag can see itsexact composition, country of manufacture, and recycling instructions. A recycler can access technical information useful for disassembly. The data is hosted by the company, but its identifier is recorded in a central European registry.

What data does it contain?

The exact content varies by product group and will be determined by sector-specific delegated acts. The main categories of information are common to all:

• unique identifier for the product and the manufacturer;
• composition, materials, and substances of concern;
• carbon footprint and percentage of recycled materials;
• durability, repairability, and availability of replacement parts;
• instructions for disassembly, reuse, and recycling;
• regulatory compliance and technical documentation.

What is the regulatory framework?

The digital passport stems fromthe ESPR Regulation (EU 2024/1781), which replaces the 2009 Ecodesign Directive and significantly broadens its scope. Whereas the previous regulation applied only to energy-related products, the ESPR can cover nearly all physical products placed on the European market.

The regulation establishes a framework, and the Commission then adopts delegated acts on a sector-by-sector basis. The ESPR 2025–2030 work plan, adopted on April 16, 2025, identifies six priority sectors: textiles, furniture, mattresses, tires, iron and steel, and aluminum. Once a sector-specific delegated act is adopted, companies generally have 18 months before it takes effect.

Batteries are subject to a separate timeline: they fall under the Batteries Regulation (EU 2023/1542), which requires a battery passport starting February 18, 2027, for industrial batteries with a capacity of more than 2 kWh, electric vehicle batteries, and batteries for light mobility vehicles.

Which companies are affected?

The DPP does not apply only to large manufacturers. As long as a product falls within a covered category and is placed on the market in the European Union, the requirement applies, regardless of the manufacturer’s country of origin. An Asian company that exports textiles to Europe is subject to the same requirements as a European manufacturer.

Manufacturers, importers, and distributors

The responsibility for creating and maintaining the passport rests primarily with the operator that places the product on the market:

• the manufacturer based in the EU, who is primarily responsible for the passport;
• the importer, who assumes responsibility when the manufacturer is outside the EU;
• the agent or distributor, who must ensure that the passport exists and remains accessible.

The sectors highlighted as priorities are textiles and apparel, furniture, steel and aluminum, tires, electronics, and batteries. Small and medium-sized enterprises (SMEs) in these sectors are included, sometimes with flexible deadlines.

The schedule by product group

The dates below are approximate: they depend on the actual adoption of each delegated act.

Two other milestones will shape 2026: the central European DPP registry must be operational by July 19, 2026, and the ban on the destruction of unsold textiles and shoes will take effect on that date for large companies (July 19, 2030, for SMEs).

Why the Carbon Footprint Is at the Heart of the Product Passport

Among all the required data, the product’s carbon footprintplays a central role. The battery passport already requires the carbon footprint of each battery to be reported over its entire life cycle, and this requirement will apply to most of the groups covered by the ESPR.

However, this figure cannot be made up on the spot. A credible product carbon footprint must be calculated in accordance withthe international standard ISO 14 067, based on actual supply chain data, not generic default values. This is what distinguishes a verifiable figure from an unverifiable internal estimate.

A concrete example: A manufacturer of aluminum components imported from outside the EU will be required, for each product SKU, to provide a carbon footprint that is traceable and can be recalculated exactly. If the manufacturer does not have data from its suppliers, it will have to use default values, which are often unfavorable. Building a product data foundation in advance therefore becomes an asset, not just an obligation.

This is Decarbo’Solution®’s area of expertise: the My-PCF® module generates product carbon footprints that comply with ISO 14067, are auditable, and can be directly reused in a digital passport. Upon request, we are happy to provide you with our methodological framework document on product carbon footprint calculation.

How can you start preparing now?

Even if the deadline for your sector has not yet been set, there are four initiatives that can be launched immediately:

1. Identify the relevant products and assign each part number to the correct ESPR group.
2. Map available data and data gaps, particularly regarding composition and carbon footprint.
3. Organize the data collection process from suppliers, which takes the longest to set up.
4. Choose an interoperable computing and storage solution capable of powering a digital passport.

Companies that get started now will have several years of historical data and proven methods at their disposal. The others will have to build their systems in a rush, just when supplier data will be most in demand.

FAQ

Is the digital product passport already mandatory?

Not yet across the board. The first mandatory passport is the battery passport, effective February 18, 2027. The other sectors (textiles, steel, aluminum, tires, furniture) will follow in accordance with delegated acts, between 2027 and 2030.

Are small and medium-sized businesses affected?

Yes, provided they manufacture, import, or distribute a product from a covered group. However, certain related requirements—such as the ban on destroying unsold textiles—provide for longer transition periods for small and medium-sized enterprises (July 19, 2030).

Is a company outside the EU subject to the DPP?

Yes. The requirement depends on the destination market, not the country of origin. Any product in a covered group placed on the European market must have a passport, and the responsibility for this lies with the importer.

What is the connection between the DPP and the company's carbon footprint?

The DPP focuses on a product’s carbon footprint (PCF, ISO 14067), while the carbon assessment covers the entire organization (BEGES). Both rely on the same supplier data: establishing a single foundation prevents duplication of effort.

Which standard should be used for the passport's carbon footprint?

The international standard is ISO 14067, which provides a framework for calculating a product’s carbon footprint over its life cycle. It ensures an auditable and comparable result, as required by authorities and clients.