Digital Product Passports: What the EU’s ESPR Really Requires

The Ecodesign for Sustainable Products Regulation (ESPR), adopted by the European Commission in 2024, is reshaping how European industries manage product data. At the core of this regulation is the Digital Product Passport (DPP)—a digital “identity card” for products that will become mandatory across a growing number of sectors between 2025 and 2030.

The goal is clear: make sustainability data traceable, accessible, and verifiable throughout the entire product lifecycle. For businesses, this means preparing to collect, structure, and share a much wider set of product information than before.

What Must Be Included in a DPP?

Although the exact data fields will vary by product group, ESPR establishes a clear set of horizontal requirements that every Digital Product Passport must contain:

Unique Product IdentifierEvery product will need a traceable code—such as a model, batch, or serial number—linked to a machine-readable carrier (QR code, RFID, or similar).
Compliance DocumentationThe DPP must include the EU Declaration of Conformity, technical documentation, test results, and certificates to demonstrate compliance with European standards.
Material Composition and Substances of ConcernCompanies must disclose what the product is made of, including the share of recycled content, and list any hazardous substances under EU rules.
Lifecycle InstructionsInformation on repair, maintenance, durability, reuse, recycling, and safe disposal must be provided to enable circular economy practices.
Environmental and Sustainability DataIndicators such as carbon footprint, energy use, or water consumption may be required, depending on the product category.
Economic Operator InformationThe DPP must clearly identify the manufacturer, importer, and authorised representative, with up-to-date contact details.
Traceability Across the Supply ChainRecords of product origins, repair history, and end-of-life treatment must be digitally accessible.

Why This Matters for Industry

For compliance-heavy sectors, this represents both a challenge and an opportunity. Companies will no longer be able to rely on fragmented paper-based systems. Instead, they must implement digital infrastructure capable of aggregating and updating compliance, environmental, and technical data in real time.

The European Commission has already identified priority product groups—textiles, electronics, batteries, furniture, and chemicals—where DPP requirements will come into force first. For batteries, the regulation takes effect in 2027. Other industries will follow gradually, with full rollout by 2030.

From Burden to Business Value

While the regulation introduces additional reporting obligations, forward-looking firms are treating DPPs as more than a compliance exercise. Properly implemented, Digital Product Passports can:

Reduce administrative costs by automating documentation.
Build customer trust through verified sustainability claims.
Strengthen competitiveness by enabling circular business models such as repair, reuse, and recycling services.

In this sense, the ESPR’s requirements push companies to improve not just compliance, but also efficiency, transparency, and brand value.

Looking Ahead

The European Commission will publish delegated acts that specify the exact datasets for each product group. Until then, companies can already prepare by mapping their product data, investing in interoperable IT systems, and piloting traceability solutions.

Digital Product Passports are not simply a regulatory checkbox—they are the foundation of a digital, transparent, and circular economy in Europe. For businesses that move early, they can become a competitive advantage rather than a compliance headache.

References

European Commission (2024) Ecodesign for Sustainable Products Regulation (ESPR). Regulation (EU) 2024/1781. Available at: https://commission.europa.eu (Accessed: 18 August 2025).
Data.europa.eu (2024) EU’s Digital Product Passport: advancing transparency and sustainability. Available at: https://data.europa.eu (Accessed: 18 August 2025).
Compliance Gate (2024) Which products require a Digital Product Passport under the ESPR?. Available at: https://www.compliancegate.com (Accessed: 18 August 2025).
TechRadar (2024) The EU’s first ESPR working plan is out: Tech companies need to consider DPP compliance now. Available at: https://www.techradar.com (Accessed: 18 August 2025).
Impinj (2024) What is a Digital Product Passport?. Available at: https://www.impinj.com (Accessed: 18 August 2025).
Z2Data (2024) EU’s Digital Product Passport: Requirements and impacts. Available at: https://www.z2data.com (Accessed: 18 August 2025).