The EU Digital

Product Passport:
What your business
needs to know

• Essential information for the DPP

• Key dates for implementation
• Next steps you need to take
 EU Digital Product Passport: What your business needs to know | 1.

Table of contents Introduction

It’s a stark forecast that in terms of consumption, we will need the
About our contributors ................................................................................2 equivalent of three Earths to fulfil the demand of resources by the year
2050. This shows the urgency to adopt sustainable practices and rethink
Chapter 1: What is the EU Digital Product Passport?.............................................. 3 – even revolutionize – the way we create and use products in every part
of society. Finite resources cannot, by definition, last and so the EU is
Chapter 2: What information is included in the DPP? ........................................... 5 changing the traditional resource-draining, ‘take-make-dispose’ model,
in favor of promoting the longevity of manufactured goods. The EU is
Chapter 3: Digital Product Passport formats ........................................................... 8 ushering in a new era of sustainability and transparency, spearheaded
with the introduction of the Digital Product Passport (DPP).
Chapter 4: Key sectors requiring DPPs ...................................................................... 9
The EU’s Ecodesign for Sustainable Products Regulations (ESPR) serves as a framework
law that enables the EU to develop detailed requirements for specific product groups or
Chapter 5: How has industry addressed DPPs so far?........................................... 13 categories with shared characteristics. This process began with a prioritization exercise
to identify which products should be regulated first. In April 2025, the Commission
Chapter 6: Timeline of key dates................................................................................ 14 adopted the first ESPR and Energy Labelling Working Plan, which outlines the initial
set of product groups to be addressed under the new rules – including Digital Product
Chapter 7: Importance of the DPP............................................................................. 16 Passport (DPP) obligations – through a process involving stakeholder engagement,
impact assessments, and consultations within the Ecodesign Forum.

Chapter 8: Implications of non-compliance ........................................................... 18 The key requirements for the DPP are laid out in the ESPR, which encompasses
performance and information requirements, both of which are integral to the DPP.
Chapter 9: Step-by-step guide to prepare your business for compliance....... 19 Together with the Energy Labelling Framework Regulation (ELFR) it facilitates consumer
choice and encourages the take-up of more sustainable and energy-efficient products.
Chapter 10: Ensure DPP compliance with Enhesa’s targeted solutions........... 21
The DPP provides a way to make sure a product’s component parts are identified so
they can be reused while the transparency drives product manufacturers to promote
Links to useful references ......................................................................... 23 sustainable materials.

Compliance professionals for a range of manufacturers need to

understand that the DPP is an important requirement in the EU. In this
informative eBook by Enhesa Product Intelligence, you’ll learn everything
you need to know about the DPP, including which sectors it affects first,
its significance, key dates, the implications of non-compliance and more.
2. | EU Digital Product Passport: What your business needs to know

What is the EU Digital

About our expert contributors
Kimberley de Miguel | Managing Analyst, Europe,
1. Product Passport?
Middle East and Africa, Enhesa Product Intelligence
The EU Digital Product Passport is a record containing a unique product
Kimberley De Miguel joined Enhesa Product in June 2023 as identifier, compliance documentation and information on substances of
the Managing Analyst for the Europe, Middle East and Africa concern within the product, providing safety instructions and guidance on
(EMEA) regions. Kimberley holds a BEng in Materials Science product disposal. DPPs are key to improving supply chain management
and Engineering and an MSc in Sustainability and Environmental and to ensure regulatory compliance, so companies can mitigate risks
Management, and specializes in regulatory and product compliance related to authenticity and environmental impact. It enables stakeholders
and value chain transparency. across the supply chain including manufacturers, consumers and recyclers
to make informed decisions while promoting sustainable practices.
The crucial part of Kimberley’s role is to extract the most critical aspects of upcoming
regulations and utilize her understanding of the industry’s day-to-day challenges to find
the best solutions. The working plan is the first step in applying the broader scope of the ESPR to specific
product groups, including those subject to DPP requirements. It seeks to balance
environmental ambition with practical implementation, ensuring the regulation delivers
meaningful impact without creating excessive administrative burdens – especially for SMEs.
Stacey Bowers | Global Product Compliance Manager, In line with this, the DPP will be accessible in digital form, such as via a quick response (QR)
code, to streamline information sharing and support efficient compliance and decision-
Enhesa Product Intelligence
making across the supply chain.
Stacey Bowers, MILS, is a Global Product Compliance Manager
within Enhesa Product Intelligence’s Expert Services Team. Stacey The DPP is pivotal in enhancing product traceability, sustainability, and efficiency across
has expertise in a wide range of specialist subjects including various industries.
product compliance requirements, products in scope, chemicals,
waste, packaging, electrical and electronic equipment (EEE),
cosmetics, medical devices and textiles. Stacey has been part of Enhesa
since November 2023, but within the wider global product compliance industry for
over 20 years, at companies such as Compliance & Risks and Bureau Veritas. DPPs are key to improving supply chain
A librarian by training, she has a Master’s Degree in Information and Library Science and management and to ensure regulatory
considerable experience delivering bespoke research and analysis to the world’s biggest compliance, so companies can
companies. Stacey has been at the helm when launching our compliance products geared
towards a wide range of sectors, such as the Global Battery Compliance Tool which breaks mitigate risks related to authenticity
down regulatory requirements for batteries, covering design, restricted substances, and environmental impact.
labeling, extended producer responsibility (EPR), and more. Our range of comparison tools
help companies find synergies and inform their strategies.
4. | EU Digital Product Passport: What your business needs to know

The content of a DPP varies depending on the product category and regulatory
requirements. Ecodesign requirements are central to the ESPR and are established through
European Commission delegated acts for specific product groups, unless horizontal rules
apply across multiple categories. These requirements aim to improve product durability,
2.  What information is
included in the DPP?
reliability and circularity, while reducing environmental impacts across the lifecycle.
Requirements may include both performance (eg recycled content thresholds or substance Generally, the DPP may include the following key information:
restrictions) and information obligations, such as those relating to the DPP and substances
of concern. Social aspects may be considered in future but are currently addressed under
the Corporate Sustainability Due Diligence Directive (EU) 2024/1760.

1. Product identification: 2. Material composition:

• unique identifiers, such as serial • details on raw materials and

numbers or QR codes; components;

• hazardous substances and compliance

• product name, model and brand; and with chemical regulations like REACH;
and

• recyclable and non-recyclable

• manufacturing date and location.
components.
6. | EU Digital Product Passport: What your business needs to know EU Digital Product Passport: What your business needs to know | 7.

Definitions information Definitions information

Under the ESPR, substances of concern (SoCs) are broadly defined While the ESPR does not provide a formal definition of environmental sustainability, it
in Article 2(27) and fall into four categories: frames the concept through 16 product aspects listed in Article 5 (1), which collectively
define the scope of sustainability requirements. These aspects cover the entire lifecycle
• REACH-based (SVHCs on the Candidate List); of a product, including durability, reparability, energy and resource efficiency, presence
• CLP-based (substances with certain hazard classifications); of SoCs, recyclability, and the expected generation of waste – effectively addressing “all
• POPs regulated under Regulation (EU) 2019/1021; and aspects of circularity,” as highlighted in Recital 119.
• substances that hinder reuse or recycling (circularity-based), identified case-by-
case by the Commission.

While SoCs form a core part of information requirements, exemptions are possible, and 4. Supply chain transparency:
restrictions for circularity can also apply to substances outside this definition – meaning
substance regulation under ESPR will be tailored to specific product groups. • sources of raw materials and supply chain partners; and
• ethical considerations, including labor practices and conflict-free sourcing.

3. Environmental impact: 5. Maintenance and repair information:

• carbon footprint and energy consumption during production; • instructions for repair and maintenance;
• information on the product’s durability and lifecycle; and • availability of spare parts and tools; and
• repairability and recyclability scores. • warranty details.

6. End of life Information:

• guidelines for recycling and disposal; and
• information on take-back schemes or reverse logistics.

7. Regulatory compliance:
• c onformance with EU directives and standards, such as the Ecodesign Directive or
Waste Electrical and Electronic Equipment (WEEE) Directive; and
• certifications and labels, such as CE marking or energy
efficiency ratings.

The aim is to provide comprehensive, standardized information that is

easily accessible and interpretable by all stakeholders in the product’s
value chain.
3.  Digital Product
Passport formats 4.  Key sectors
requiring DPPs
The format of a Product Passport is typically digital and can be implemented through
various technologies to ensure accessibility and interoperability.

QR codes or barcodes
A scannable code printed on the product or packaging
that links to a digital platform containing the product’s
information.

Blockchain technology
A decentralized ledger to securely store and track
information about the product’s lifecycle, ensuring data
integrity and transparency.
The initiative aims at many sectors and will roll out across a range of
Cloud-based platforms industries, starting with batteries.
Centralized or decentralized platforms accessible via the
internet, where manufacturers, retailers and consumers
Requirements for batteries
can upload or retrieve product data.
The EU’s 2023 Batteries Regulation repealed its 2006 Batteries Directive and established
new requirements on sustainability, safety, labeling, marking and information to allow
Embedded chips or tags batteries to be placed on the market or put into service within the EU.
RFID or NFC tags embedded in the product, enabling near-
field communication for data access. Importantly, the regulation established a requirement for batteries, such that they must be
marked with a QR code which provides access to information including:

• eneral information on the manufacturer’s identity and the

g
battery’s category and identification, place of manufacture, date of
Regardless of the specific format, the DPP must be designed to ensure data security, user- manufacture, weight, capacity and chemistry;
friendliness and compatibility across different systems and devices. This interoperability is • the symbol for separate collection of batteries, also known as the
crucial for achieving the EU’s vision of a seamless digital ecosystem. crossed-out wheeled bin symbol;
10. | EU Digital Product Passport: What your business needs to know EU Digital Product Passport: What your business needs to know | 11.

• the chemical symbols for cadmium and lead, if those heavy metals are present The Ecodesign for Sustainable Products Regulation
above 0.002% cadmium or 0.004% lead;
• the EU declaration of conformity (DoC); and The Ecodesign for Sustainable Products Regulation (ESPR), which entered into force on 18 July
• evidence of compliance with an EU-recognized due diligence scheme. 2024, is intended to improve the circularity, energy performance, recyclability and durability
of products in the EU, with a focus on products with a significant environmental impact.

The Commission’s working plan 2025-30 for the ESPR and Energy Labelling listed the
following four final “priority products” and indicative timelines for adoption:
For starting, lighting and ignition (SLI) batteries, the passport
must detail the amount of the following recovered from waste
EUR 78 billion (out of High potential to improve product lifetime 2027
and present in active materials in the battery: EUR 142 billion of all extension, material efficiency and to reduce
textiles and footwear in impacts on water, waste generation, climate
• cobalt; market size, 2019) change and energy consumption. Information
• lead; requirements under the ESPR will work in
Textiles/
synergy with the Textile Labelling Regulation
• lithium; and Apparel
currently under review.
• nickel.

For light means of transport (LMT) batteries, industrial batteries with a capacity greater EUR 140 billion (2021) High potential to improve aspects of resource 2028
than 2kWh, and electric vehicles batteries, the passport must include: use, with impacts of production and supply
of materials often being the main contributor
• the material composition of the battery and critical raw materials present; across different environmental impact
Furniture categories (e.g. climate change, acidification,
• information on responsible sourcing;
eutrophication), and waste generation. Positive
• recycled content information; impact on other categories such as air, soil and
• the share of renewable content; biodiversity.
• minimal, nominal and maximum voltage; and
• expected battery lifetime expressed in cycles. EUR 45 billion (2021) Though already regulated by other pieces of 2027
EU legislation (including the Tyre Labelling
Regulation (EU) 2020/740), potential to
improve recyclability and recycled content and
to mitigate risks related to waste management
The QR code must be printed or engraved visibly, legibly and indelibly on the battery. Tyres of end-of-life tyres.
Where this is not possible or not warranted due to the nature and size of the battery, the
QR code may be affixed to the packaging and to the documents accompanying the battery.
EUR 10 billion (2022) High potential to improve waste generation, 2029
These marking requirements will take effect on 18 February 2027. lifetime extension and material efficiency.

Mattresses
12. | EU Digital Product Passport: What your business needs to know

5.  How has industry

In addition, energy-related products, including those already regulated under the 2009
Ecodesign Directive, will be regulated under the ESPR in the future.

To this end, the working plan covers 35 products, setting a transition period until 31
addressed DPPs so far?
December 2026, under which the measures continue to be covered by the Ecodesign
Directive, while carrying forward and including 16 EEE products under the ESPR, including:
Several initiatives are actively developing DPP frameworks tailored to their
• household dishwashers – 2026; respective sectors.
• household washing machines and washer-dryers – 2026;
• low-temperature emitters – 2026; CIRPASS (Circular Product Passport) is a collaborative project involving
• displays – 2027; multiple stakeholders aiming to establish cross-sectoral DPP prototypes. It focuses
• EV chargers – 2028; on creating standardized frameworks for product information exchange to support
• electric motors and variable-speed drives – 2028; a circular economy. The project has developed roadmaps for DPP implementation
• refrigerating appliances (including household fridges and freezers) – 2028; across sectors such as batteries, electronics and textiles, promoting transparency
• light sources (only for Ecodesign) and separate control gears – 2029; and sustainability throughout product lifecycles.
• mobile phones and tablets – end 2030;
• tumble dryers – end 2030; and Battery Pass was launched by an industry-led consortium, seeking to advance the
• standby and off mode consumption – end 2030. implementation of the EU Battery Passport. This project aims to provide detailed
information on battery composition, manufacturing processes and end of life
The Commission, in consultation with stakeholders, has initiated the standardization management, thereby enhancing sustainability and regulatory compliance within
process to set rules on data carriers, infrastructure and data interoperability, which are the battery industry.
needed to enable the product passport system to develop.
Catena-X is a German consortium comprising automotive companies, suppliers
and technology providers, developing a DPP framework specifically for the
automotive industry. With over 60 partners, Catena-X facilitates secure and
reliable data sharing across the automotive value chain, encompassing vehicle
components’ lifecycle from production to end of life.

Manufacturing-X initiative aims to establish an open data ecosystem across

various industries. It focuses on creating data spaces that enhance transparency,
efficiency and sustainability in manufacturing processes, supporting data
sovereignty and interoperability among stakeholders.

Chem-X is an initiative within the Manufacturing-X framework,

concentrating on the chemical industry. It aims to develop data
ecosystems that improve transparency and efficiency in chemical
manufacturing processes, aligning with the overarching goals of
Manufacturing-X.
 EU Digital Product Passport: What your business needs to know | 15.

6.  Timeline of key dates

Virtually all products sold in the EU will
require a DPP. Products exempt from
2020 requiring DPPs include food, medicines,
plants, animals and vehicles.
The European Commission adopted the CEAP, proposing the
introduction of a DPP. The plan fed into the European Green
Deal for sustainable development with aims to alleviate
pressure on the natural environment and its resources, tying
into the EU’s 2050 climate neutrality target.

The Sustainable Products Initiative (SPI) was unveiled to focus on toxic-free

products and chemical safety. Within the initiative was a regulation for Ecodesign
2022 which outlined minimum requirements for products intended for trade in Europe.
The details of requirements for the digital passport were laid out. Its purpose, to
enhance traceability of substances of concern in products.

The Commission added an update on the ESPR, the legislation outlining

requirements for companies to produce DPPs. Virtually all products sold in the
EU will require a DPP. Products exempt from requiring DPPs include food,
medicines, plants, animals and vehicles (e-bikes and e-scooters are not exempt).
2024

2025
The European Commission adopted the 2025-30 working plan on the ESPR and Energy Labelling Regulation,
providing a list of products that should be prioritized to introduce ecodesign requirements and energy
labeling over the next five years. The selection of products included in the present working plan is based on
2026 an inclusive process and reflects both the input from stakeholders and member states. It is based on a
thorough technical analysis and criteria notably related to the EU’s climate, environment and energy
efficiency objectives, as well as an extensive consultation process, including through the Ecodesign Forum.

2027
-28
Anticipated implementation Expansion of the product passport to
of the passport for batteries other product categories such as textiles
under the new EU Battery and electronics, depending on the
Regulation. progress of sector-specific legislation.
 EU Digital Product Passport: What your business needs to know | 17.

7.  Importance of the DPP

Promotes transparency
The passport provides detailed product information, empowering consumers and
businesses to make environmentally responsible choices. This passport can be a tool for
decision makers as information is easily shared to interested parties.

Supports circularity
It was realized that less than 10% of materials used around the world were fed back into the
materials cycle. By offering insights into repairability and recyclability, the passport fosters
reuse, remanufacturing and recycling, reducing the overall environmental footprint. The
DPP becomes a driver for cutting back on pollution, waste and environmental destruction,
and will mean products become more durable and easier to reuse, recycle and repair.

Enhances compliance
The passport ensures alignment with EU environmental goals and regulatory requirements,
helping businesses avoid penalties. As a tool, the DPP makes it clear what’s required for
product standards.

Boosts market competitiveness

It was realized that less than 10% of
materials used around the world were fed
Companies adopting sustainable practices early can gain a competitive edge by appealing
to eco-conscious consumers and securing access to the EU market. The act of greenwashing
back into the materials cycle. By offering
(where false claims of sustainability are made) will be harder, which in turn makes those insights into repairability and recyclability,
with DPPs able to prove the legitimacy of their ‘green’ product claims.
the passport fosters reuse, remanufacturing
Creates trackable supply chain and recycling, reducing the overall
Offers a means to share product data across the whole supply chain, becoming the digital
environmental footprint.
twin of a physical product. Important information such as materials sourced, manufacturing
process and recyclability will be easy to check.
8.  Implications of
non-compliance 9.  Step-by-step guide to
prepare your business
for compliance
Non-compliance with the EU Digital Product Passport requirements can Responsibility for the DPP is with whomever puts the product on the market.
have significant consequences for businesses. Manufacturers and EU importers of regulated products will have to ensure
that a product passport in accordance with the applicable delegated act
is available. The ESPR doesn’t limit the definition of manufacturer to EU-
based entities, and the Commission’s impact assessment confirms that its
Market access restrictions requirements apply equally to both EU and non-EU companies. This means
that non-EU manufacturers are expected to meet the same compliance
Products without a compliant passport may be barred from the EU market. The EU is
obligations as their EU counterparts. A manufacturer may appoint an
serious about ensuring only compliant products circulate within its jurisdiction. Non-
authorized representative established in the EU to act on their behalf for
compliance could result in outright bans, leading to loss of access to one of the world’s
largest consumer markets.
specific ESPR-related responsibilities.

Reputational damage
Failure to meet sustainability standards could harm brand reputation and consumer trust.
Today’s consumers are increasingly eco-conscious and prefer brands that align with their
values. Non-compliance could lead to negative publicity, damaging a company’s image and
impacting customer loyalty.

Financial penalties
Companies may face fines and legal actions for non-compliance. The EU has a history of
imposing substantial penalties on businesses that violate regulations, which can strain
financial resources and erode profitability.

Supply chain disruption

Incomplete or inaccurate product data could impact collaborations with suppliers and
partners required to adhere to EU standards. Non-compliance can disrupt relationships
across the supply chain, leading to delays, increased costs and potential loss of business
partnerships.
20. |EU Digital Product Passport: What your business needs to know

Ensure DPP
compliance with
Steps for implementing the DPP
10. Enhesa’s targeted
solutions
Stay ahead of regulatory requirements and make safer, more sustainable
Invest in digital choices with Enhesa’s comprehensive solutions. As DPPs rely on up-
to-date regulatory standards and sustainability best practices, Enhesa
infrastructure provides the intelligence you need to remain compliant. Whether you’re
Implement systems to collect,
store and share product data navigating complex compliance obligations or aiming to future-proof
securely and efficiently. your product strategy, Enhesa equips you with the insight to meet DPP
requirements with confidence.

Product Intelligence | Enhesa

Our mix of data tools and expert advice gives you a clear view of the regulatory and business
environment as well as forewarnings about planned changes.
Seek expert Assess product
guidance lifecycle The powerful suite of solutions includes:
Engage with legal
and sustainability Conduct a thorough review of
consultants to your products’ design, materials Engage
navigate the and supply chain to identify areas
requiring adjustment to meet
stakeholders  hemical Watch News & Insight – reports on the latest chemical
C
complexities of Collaborate
passport requirements. regulatory information around the world;
the regulations. with suppliers,
distributors and
other partners
to ensure
consistent  egulatory Database – reliable, always up-to-date regulatory
R
data across intelligence;
the value
Monitor regulatory updates chain.
Stay informed about the EU’s
evolving guidelines and timelines
to ensure timely compliance.
 xpert Services – a team of experts guiding
E
clients through their specific regulatory needs;
22. |EU Digital Product Passport: What your business needs to know EU Digital Product Passport: What your business needs to know | 23.

 anaged Services – highly tailored, bespoke support with list

M
Act now
building and regulatory monitoring services; The EU Digital Product Passport represents a significant step toward a sustainable and
transparent economy. While the requirements may seem challenging, they also present an
opportunity for businesses to innovate, differentiate and align with the EU’s sustainability
goals. By acting now, companies can ensure compliance, minimize risks and position
themselves as leaders in the transition to a greener future.
 rofessional Development – learn regulations specific to your
P
products, train your teams and attend key events; and
We have many solutions that can help and experts on hand who can guide you through
aspects of eLabeling and explain digital carriers in and outside the EU. If you have any
questions, please get in touch with us at Enhesa Product Intelligence.

F ocused Compliance Solution – combination of database tools

and expert support in key themed areas for chemical and product
compliance. Links to useful references
EU’s Digital Product Passport: Advancing transparency and sustainability
Sustainable consumption and production
Consider complementing our solutions with Enhesa Sustainable Chemistry, which How the EU wants to achieve a circular economy by 2050 | Topics | European Parliament
empowers you to choose and source safer chemicals for use, manufacture and design. The Digital Product Passport: The ticket to achieving a climate neutral circular economy?
state-of-the-art, configurable solutions save you time, getting the information you need
Circular economy action plan – European Commission
more efficiently. Services include:
Latest updates on Digital Product Passport in May 2024
EU Digital Product Passport: Requirements, benefits and implementation
Chemical Assess – on-demand hazard and list screening in one Digital Product Passports are just around the corner | Deloitte UK
simple-to-search, intuitive tool; The EU Regulation on Batteries and Battery Waste
The Ecodesign for Sustainable Products Regulation (ESPR)
 upply Chain Connect – identify hidden hazards in your supply
S ESPR and Energy Labelling Working Plan 2025-30
chain by sourcing ingredient information from suppliers in one JRC Publications Repository – Ecodesign for Sustainable Products Regulation: Study on
consistent format; new product priorities
Register of Commission expert groups and other similar entities
EU Parliament, Council of Ministers provisionally agree on Ecodesign Regulation
Chemical Research – search thousands of databases at once; and
Ecodesign for Sustainable Products Regulation
REACH: The Ecodesign for Sustainable Products Regulation
Battery recycling worldwide – statistics and facts
Certification Services – designed to help meet customer
80+ Sustainability Statistics for 2025: Ultimate List
expectations.
Packaging and Packaging Waste Regulation | Enhesa
Act today and prepare for
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sustainable future with 360°
intelligence for your operations,
products, and chemicals
management across the globe.

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risk, and drive sustainability.
you can benefit your organization’s product
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