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What is a digital product passport? DPP deadlines, obligations and how businesses can implement it successfully

Under the EU Ecodesign Regulation (ESPR), the Digital Product Passport (DPP) is gradually becoming mandatory for numerous product categories. Manufacturers, importers and retailers must make product-related data transparent and digitally accessible throughout the entire life cycle – from materials and carbon footprint to repairability and recycling options.

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Caspar Sunder-Plassmann

Principal

Manuel Gramlich

Principal

Satisfied customers from small and medium-sized businesses and large corporations

Executive Summary – Digital Product Passport at a Glance

Introduction to the Digital Product Passport: What is a DPP?

The Digital Product Passport is a standardised digital dataset that makes relevant information on a product’s materials, origin and production accessible throughout its entire life cycle. It is a dataset that summarises a product’s components, materials and chemical substances, supplemented by information on repairability, spare parts and proper disposal.

Structuring environmentally relevant data in a standardised, comparable format enables all stakeholders in the value and supply chains to work together towards a circular economy. The DPP also serves as an important basis for reliable consumer information and sustainable purchasing decisions in both high-street and online retail.

Depending on the product category and regulatory requirements, the following data may be stored in the DPP:

  • Materials & raw materials: origin, composition, proportion of recycled materials
  • Production & supply chain: manufacturers and suppliers involved, production sites
  • Environment & sustainability: carbon footprint, energy consumption, pollutants
  • Use & maintenance: guidance on proper care, availability of spare parts, recommended service intervals
  • Repair & recycling: reparability, disassembly instructions, disposal methods
  • Compliance & certification: proof of conformity, safety data sheets, standards

Access is gained directly via the product, usually via a QR code, RFID chip or NFC access point on the product or its packaging. Scanning this allows access to the information authorised for the user.

This is gradually creating a more uniform and highly interoperable machine-readable database for products, which can be accessed by all relevant stakeholders along the supply chain – from manufacturers and retailers, through consumers and recycling companies, to public authorities.

Legal framework and standards for the Digital Product Passport

The DPP is not a voluntary instrument. It is made mandatory by EU law. This section provides an overview of the legal basis, the products concerned and the specific deadlines.

The Ecodesign for Sustainable Products Regulation (ESPR) came into force on 18 July 2024 and replaces the previous Ecodesign Directive. It sets out a cross-product DPP system, which is supplemented by product-specific regulations and rules, including planned European registry and identification mechanisms (EU DPP Register).

The ESPR aims to improve the circularity of products. In doing so, it also places greater emphasis on reparability and durability. Products falling within the scope of the ESPR must have a Digital Product Passport in order to be sold on the EU market.

The EU is pursuing three key objectives with the Digital Product Passport:

  • Climate neutrality by 2050: Greater transparency regarding emissions and resource consumption throughout the entire supply chain.
  • Strengthening the circular economy: Repair, reuse and recycling are facilitated by improved data availability.
  • Combating greenwashing: In future, sustainability claims must be verifiable and auditable.

The requirements will be introduced gradually by product category:

Timeframe
Product Category / Requirement
From February 2025
Carbon footprint declaration mandatory for EV batteries
From December 2025
Recycling requirements for lithium-ion batteries
From January 2026
Initial labelling and documentation requirements come into force, depending on the product group
From February 2027
Full battery passport with a QR code for EV, industrial and light means of transport batteries with a capacity above 2 kWh
From 2028/2029
Extension to textiles, clothing and electronics
From 2030 onwards
Extension to construction products, furniture, chemicals and other sectors

The DPP affects all companies that manufacture, import or place products on the EU market. It does not matter whether the company is based inside or outside Europe.

The Digital Product Passport must be provided by the economic operator placing the product on the market. However, it must also incorporate relevant information supplied by previous partners in the supply chain.

Important for SMEs: Small and medium-sized enterprises are also generally affected. However, they may benefit from extended transition periods and simplified requirements. Companies that begin preparing now can secure a decisive advantage.

The technical foundations for the DPP are currently being developed by CEN/CLC JTC 24 in the form of harmonised European standards. More than 300 experts from 20 EU Member States are involved in this work.

Key technical requirements include:

  • Unique product identifiers, such as GTINs and serial numbers
  • Machine-readable data carriers, including QR codes, RFID and NFC
  • Interoperable data formats based on draft CEN and CENELEC standards
  • Registration in the central EU DPP Registry in accordance with the ESPR

Benefits of a Digital Product Passport for Businesses and Consumers

The DPP is not only a regulatory obligation. It is also a strategic instrument offering tangible commercial benefits.

Companies that implement the DPP proactively and at an early stage can unlock potential that extends far beyond compliance.

Predictive Maintenance and AI
Product data, which is generally further structured and enhanced through the DPP, can be combined with operational and service data to support AI-based maintenance strategies. This enables companies to predict failures, reduce downtime and lower maintenance costs.

New Business Models
Service-based business models – such as Repair as a Service, leasing and take-back models or data-based service contracts – can be implemented using the data foundation provided by the DPP.

Competitive Advantage Through Transparency
Demonstrable sustainability is becoming an important purchasing criterion. Customers and B2B partners increasingly reward verifiable ESG data through procurement decisions, tender evaluations and corporate communications.

Supply Chain Efficiency
Consistent, digitally available product data reduces the need for manual coordination, minimises errors and accelerates processes throughout the supply chain.

Compliance and Reporting
The standardised storage and management of material and product data allow companies to fulfil regulatory requirements more efficiently and make use of synergies between different regulations.

Future Readiness
Companies that implement the Digital Product Passport at an early stage are better prepared for regulatory change and can integrate new EU requirements flexibly without having to work under severe time pressure.

Transparent Purchasing Decisions
Consumers can understand where a product comes from, how it was manufactured and how sustainable it actually is.

Repair and Maintenance
Information about spare parts, service intervals and repair options can be accessed directly from the product.

Verifiable Sustainability
The DPP increases the traceability of sustainability-related statements and makes unsupported environmental claims and greenwashing more difficult.

Responsible Disposal
Information about recycling routes and proper disposal supports the circular economy.

The DPP is a key instrument for the circular economy.

By collecting batch-specific and item-specific data – including repair and maintenance information – companies can maintain, repair and reuse their products more efficiently. This increases both product circularity and sustainability.

Data from the use and end-of-life phases can also be fed back into the design phase. These insights help companies select materials more efficiently, design more sustainable products and increase product longevity.

Challenges in Implementing a Digital Product Passport

Introducing a DPP requires far-reaching changes within an organisation. In addition to the constantly evolving regulatory environment, companies face three principal implementation challenges.

Data Availability

Many companies find that DPP-relevant data – such as product data at batch or individual-item level – has not yet been collected completely, in a suitable format or with sufficient granularity. Information from the supply chain, including material compositions and manufacturing processes, is often particularly difficult to obtain. Companies therefore need to establish new interfaces and work closely with suppliers and business partners.

Data Quality

To use the Digital Product Passport effectively, existing data must be validated, consolidated and converted into a consistent format. This may require extensive adaptations to existing IT systems and processes, particularly when extending ERP, PLM and PIM systems to integrate internal and external data sources.

Process Realignment

Implementing the DPP often requires companies to realign their processes. Responsibilities must be clearly defined, and all relevant departments – from product development and production to IT and compliance – must work closely together. Who within the organisation is responsible for creating and populating the DPP? Who manages it after the product has been sold? Clearly defined responsibilities are essential.

Additional Challenges

  • Supply chain complexity: The DPP only works with complete data from across the entire supply chain. Integrating Tier 1, Tier 2 and Tier 3 suppliers is often complex and time-consuming.
  • Regulatory developments: Standards and delegated acts are continually evolving. Companies must remain adaptable.
  • Costs and resources: Initial investments in data infrastructure, systems and processes can represent a particular obstacle for SMEs.
  • Interoperability: Different systems and data formats must be connected in a way that enables a continuous flow of information without creating new isolated solutions.

Your Digital Product Passport Experts

Caspar Sunder-Plassmann

Principal and DPP expert

Manuel Gramlich

Principal and DPP expert

Step-by-Step Guide to Successfully Implementing a Digital Product Passport

Analyse which product data is already available, where gaps exist within the supply chain and which of your product categories will be affected by the DPP obligation first.

Map your product portfolio against the relevant regulatory requirements and deadlines.

Objective: A documented current-state assessment containing a compliance calendar, identified gaps and prioritised areas for action.

Implement a suitable software solution that centrally records and manages product data and makes it available in a standardised, machine-readable format.

Ensure that the solution can be seamlessly integrated into existing systems such as ERP, PLM, PIM and CMMS platforms.

Output: An extended IT infrastructure with centralised data storage, defined interfaces and machine-readable data formats.

The DPP can only work if complete data is available from across the entire supply chain.

Clarify at an early stage:

  • Which information your suppliers must provide
  • The format in which the data must be transferred
  • How you will assess and improve your suppliers’ readiness

Objective: A supplier matrix containing readiness assessments, defined data flows and an engagement plan for critical suppliers.

Collect all DPP-relevant data throughout the product lifecycle – from raw materials and manufacturing to use and end of life.

Validate and consolidate existing data and convert it into consistent formats.

Review whether the data complies with the applicable or emerging CEN and CENELEC requirements.

Objective: A validated and standardised DPP dataset for the prioritised product categories.

The digital access point – such as a QR code, RFID tag or NFC interface – must be applied to the product or its packaging as part of the production process.

The access point must meet the requirements for unique product identifiers.

Objective: A production-integrated access point with a functioning link to the DPP dataset.

Establish a company-wide DPP governance structure.

Key questions include:

  • Who is responsible for creating and populating the DPP?
  • Who manages the DPP after the product has been sold?
  • How will updates and changes be controlled?

Objective: A DPP governance framework with clearly defined roles, processes and decision-making procedures.

Begin with a pilot project covering a clearly defined product category.

Validate the entire process, from collecting the data to making the completed DPP accessible. Document the lessons learned and subsequently scale the solution to additional product groups and markets.

Objective: A validated DPP pilot with documented results and a scaling plan.

The DPP is not a static document.

Product data must be capable of being updated throughout the entire lifecycle, including during maintenance, repairs, resale and disposal.

Establish processes for continuous data maintenance and monitor ongoing regulatory developments.

Objective: Established processes for continuous DPP maintenance, monitoring of new regulatory requirements and iterative development.

Getting Started: Ventum Consulting’s DPP Readiness Assessment

The process begins with an honest assessment: How complete is your existing data foundation? Where do the capabilities of your current systems end? How mature is the data landscape throughout your supply chain?

Only when these questions have been answered can a DPP implementation pathway be defined that is both compliant with regulatory requirements and commercially realistic.

Ventum Consulting’s Digital Product Passport Readiness Assessment provides exactly this level of certainty: a sound analysis, clear priorities and a roadmap for your DPP transformation that aligns regulatory, technological and commercial requirements.

Two Assessment Options:

A concise readiness report containing quick wins, risks and prioritised immediate measures – providing a basis for deciding on the next stage.

A comprehensive, modular analysis covering five pillars:

  1. Compliance analysis
  2. Data and system readiness
  3. Supply chain assessment
  4. Business case and change management
  5. Strategic DPP roadmap

What Makes the Difference:

Conclusion: Why the Digital Product Passport Is Becoming Indispensable and How to Use It Effectively

The Digital Product Passport is not merely an additional administrative burden. It is an instrument of industrial transformation with far-reaching consequences for companies around the world that sell their products on the European market.

Key Takeaways:

  • Regulatory Obligation: The ESPR is making the DPP mandatory in stages. For affected product groups, the absence of a required DPP may prevent a product from being placed on the EU market.
  • Starting Early Pays Off: The requirements are being introduced gradually, but the necessary changes to data, systems, supply chains and processes require sufficient preparation time.
  • Data Quality Is Essential: Without validated, structured and machine-readable data, a DPP cannot deliver value.
  • Actively Involve the Supply Chain: The DPP only works when complete data is available across the entire value chain. Supplier management therefore becomes a critical success factor.
  • Think Beyond Compliance: Predictive maintenance, new business models, more efficient supply chains and demonstrable sustainability are among the strategic opportunities created by the DPP.
  • Establish Effective Governance: Clear responsibilities, defined processes and scalable structures prevent the DPP from becoming an isolated solution.

Companies that address the Digital Product Passport strategically today will not only fulfil regulatory obligations. They will also create the foundation for data-driven innovation, sustainable value creation and long-term competitiveness within a circular economy.

Why Choose Ventum Consulting for the Digital Product Passport?

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    FAQ – Frequently Asked Questions About the Digital Product Passport

    The Digital Product Passport is a standardised digital document that centrally provides important information about a product, including its materials, origin, production, sustainability, maintenance, repair and recycling.

    The information can be accessed directly from the product, for example via a QR code, RFID chip or NFC access point.

    The requirements are being introduced gradually by product category.

    Initial requirements already apply to batteries. The full battery passport will become mandatory from February 2027. Other product groups, including textiles, electronics and construction products, will follow in subsequent years.

    All companies that manufacture, import or place products on the EU market are affected, regardless of where they are based.

    SMEs may also be affected, although they may benefit from extended transition periods.

    Depending on the product category, the DPP may need to contain information about:

    • Materials and raw materials
    • Production locations
    • Supply chains
    • Carbon footprint
    • Energy consumption
    • Harmful substances
    • Maintenance instructions
    • Repairability
    • Recycling options
    • Compliance and certification documentation

    The Ecodesign for Sustainable Products Regulation is the EU regulation that establishes the legal framework for the Digital Product Passport.

    It entered into force on 18 July 2024 and replaced the previous Ecodesign Directive.

    Products without a mandatory Digital Product Passport may not be sold on the EU market.

    Companies may also face regulatory sanctions and competitive disadvantages.

    Strategic benefits include:

    • AI-supported maintenance strategies
    • New service-oriented business models
    • More efficient supply chains
    • Demonstrable sustainability as a competitive advantage
    • A foundation for data-driven innovation

    The most significant challenges are:

    • Data availability: Particularly data from across the supply chain
    • Data quality: Validation and standardisation of existing data
    • Process realignment: Clear responsibilities and cross-departmental collaboration

    We support companies with the gradual implementation of their DPP requirements.

    We also offer a tailored DPP Readiness Assessment in both Quick and Deep Assessment formats. Our support ranges from compliance analysis, data and system readiness and strategic roadmap development to the business case, governance framework and scaling plan.

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