Digital Product Passport (DPP): a guide to EU requirements and compliance

What is a Digital Product Passport (DPP)?

A Digital Product Passport (DPP) is a digital identity associated with a product that provides access to relevant information throughout its entire lifecycle, from manufacturing and distribution to use, maintenance, repair, reuse, and recycling.

The DPP creates a standardized framework for making product information available in a structured and verifiable way. Depending on the applicable legislation and product category, a Digital Product Passport may include information related to product composition, materials, environmental performance, sustainability characteristics, regulatory compliance, and traceability.

The objective is to improve transparency across value chains while supporting product sustainability, resource efficiency, circular economy initiatives, and informed purchasing decisions.

Why is the EU introducing the Digital Product Passport?

The European Union is introducing the Digital Product Passport as part of its broader sustainability and circular economy strategy. The DPP is expected to play a central role in implementing the Ecodesign for Sustainable Products Regulation (ESPR), which establishes a framework for improving product sustainability and information transparency across the European market.

By increasing the availability and accessibility of product information, the DPP is expected to:

• Improve product traceability across supply chains.
• Facilitate repair, reuse, refurbishment, and recycling activities.
• Support sustainability, circularity, and resource efficiency objectives.
• Increase transparency for economic operators, authorities, and consumers.
• Improve access to reliable product compliance and environmental information.

As DPP requirements continue to evolve through delegated acts, organizations that prepare early will be better positioned to adapt efficiently and transform regulatory obligations into strategic advantages.

What information does a Digital Product Passport contain?

The information included in a Digital Product Passport will vary according to the applicable legislation and product category. However, future DPPs may contain information such as:

• Product identification, including product type, model, and manufacturer details.
• Materials and product composition information.
• Sustainability and environmental performance data.
• Technical documentation and declarations. Instructions for use, maintenance, repair, and end-of-life management.
• Certifications and evidence of regulatory compliance.
• Material origin and supply chain traceability information.
• Product safety information.
• Additional information required by applicable European legislation.

Specific data requirements will be determined through delegated acts that define the obligations applicable to each product category.

How does a Digital Product Passport work?

The Digital Product Passport will typically be accessed through a QR code or another digital identifier attached to the product. By scanning the code, users can access the information associated with that product throughout its lifecycle.

To support interoperability across the European market, the European Commission has developed the DPP Registry, an infrastructure that enables the registration of Digital Product Passport identifiers and the verification of economic operators. Access to this system is managed through EU Login.

Importantly, the DPP Registry does not store the complete passport content. Instead, it stores the information necessary to identify and locate the passport. Technical, sustainability, traceability, and compliance information remains managed by manufacturers or authorized Digital Product Passport service providers.

This decentralized approach facilitates interoperability while allowing organizations to maintain control over their product data.

Which products require a Digital Product Passport?

Not all products will be subject to the same Digital Product Passport requirements, nor will implementation occur simultaneously across sectors. Future delegated acts will define:

• Which product categories are covered.
• Which information must be disclosed.
• Product traceability requirements.
• Digital identification mechanisms.
• Data access conditions.
• Maintenance and update obligations.

Different sectors will have specific requirements tailored to their technical, sustainability, and regulatory characteristics. Batteries are expected to be among the first categories subject to mandatory Digital Product Passport obligations, while additional sectors will progressively be incorporated through sector-specific delegated acts.

The Construction Products Regulation (CPR) also establishes the foundation for DPP-related requirements within the construction products sector.

Expected DPP Implementation Timeline

The rollout of the Digital Product Passport is expected to take place progressively across different industries and product categories. Current estimates indicate the following timeline:

These timelines may evolve as additional delegated acts and implementation measures are adopted by the European Commission.

How can Applus+ Laboratories support Digital Product Passport readiness and implementation?

At Applus+ Laboratories, we partner with manufacturers, brands, and industrial organizations to assess Digital Product Passport readiness, review product information, identify compliance gaps, and implement practical DPP solutions aligned with evolving European requirements.

Why choose Applus+ Laboratories?

Applus+ Laboratories combines expertise in European product legislation with extensive technical knowledge in testing, inspection, certification, and product assessment to to help organizations navigate evolving Digital Product Passport requirements.

Through our collaboration with OKTICS, we complement regulatory and technical capabilities with practical digital implementation solutions, helping organizations manage DPP information efficiently and adapt to future requirements.

Our experience across multiple industrial sectors and participation in Digital Product Passport projects enables us to provide an integrated approach that brings together regulatory, technical, digital, and operational perspectives to support effective DPP readiness and implementation.

Frequently asked questions about the Digital Product Passport

Will the Digital Product Passport be mandatory for all products?

No. DPP requirements will be introduced progressively through delegated acts and will vary depending on the product category.

Will the Digital Product Passport be mandatory for all products?

No. Each sector will have specific requirements related to its technical characteristics, sustainability objectives, and traceability needs.

Who will be responsible for the Digital Product Passport?

Responsibility will primarily lie with economic operators placing regulated products on the European market, particularly manufacturers and importers. However, the implementation and use of Digital Product Passports (DPPs) will involve multiple stakeholders across the product lifecycle:

• Manufacturers will provide detailed information on product composition, origin of materials, and sustainability-related data.
• Retailers and distributors will facilitate access to DPP information for customers and other relevant stakeholders.
• Consumers will use DPPs to make informed decisions about purchasing, use, repair, and disposal.
• Repair and maintenance providers will rely on DPP data to support product repairs and identify suitable spare parts.
• Waste management and recycling operators will use the information to determine the most appropriate recycling and end-of-life treatment options.
• Regulators and market surveillance authorities will use DPPs to verify compliance with sustainability and circular economy requirements.

What role will the supply chain play?

DPP implementation will require information from suppliers, manufacturers, distributors, and other stakeholders to support traceability and information availability.

What are the benefits beyond regulatory compliance?

In addition to supporting regulatory requirements, DPPs can improve traceability, centralize technical documentation, enhance supply chain transparency, optimize product information management, and strengthen communication with customers and stakeholders.

Why should companies start preparing now?

Early preparation allows organizations to identify information gaps, adapt processes progressively, reduce future implementation risks, and build internal capabilities before obligations become mandatory.

What is the first step?

The first step is conducting an initial assessment to determine how Digital Product Passport requirements may affect your products and to develop an implementation roadmap aligned with your business objectives.