Digital Product Passport: A guide for manufacturers in 2026

The Digital Product Passport (DPP) is a powerful tool in the EU's push for sustainable, circular products, and it's now enshrined in law under two key pieces of legislation: 

• The Ecodesign for Sustainable Products Regulation (ESPR): Regulation (EU) 2024/1781, which sets the general framework for DPPs across the EU market. 

• The revised Construction Products Regulation (CPR): Regulation (EU) 2024/3110, which tailors sustainability and DPP requirements specifically for the construction sector.

The DPP will redefine how product data is shared, verified, and used across Europe. A DPP connects a physical product with structured, machine-readable information. Depending on the applicable rules, that information may cover product identity, technical performance, legal compliance, environmental performance, repair, and end-of-life handling.

This article covers:

• What’s a Digital Product Passport (DPP)
• Where data is stored: DPP Registry
• The role of DPP in ESPR
• DPPs for construction products
• What information needs to be included in a DPP
• Who will need to create DPPs
• How will DPPs be implemented
• How to prepare for DPPs
• How One Click LCA helps you get ready for DPPs
• FAQ - Frequently Asked Questions about DPP

What is a Digital Product Passport (DPP)?

At its core, a DPP is a structured digital record designed to store and share essential information about a product and its supply chain. It provides a unique identifier and offers a transparent window into a product’s origin, material composition, environmental performance, repairability, compliance status, and end-of-life guidance.

Under the ESPR, DPPs are required for a growing list of product groups, with construction products specifically covered by both horizontal ESPR rules and sector-specific CPR rules.

The DPP serves multiple goals:

• Bridging the gap between increasing consumer and regulatory demands (such as ESPR, CPR, CSRD) for transparency and the current lack of reliable product data.
• Enabling traceability and data interoperability across complex global supply chains.

• Supporting regulatory compliance, harmonization, and more sustainable product design and disposal.

• Enable circular economy practices like reuse, repair, and recycling.

• Inform consumers and professionals with current, machine-readable product data.

By offering a detailed digital record of a product’s life cycle, the DPP will become a powerful tool for compliance, supply-chain management, risk mitigation, and data-driven sustainability by facilitating ecodesign improvements, repair, reuse, and traceability for more circular product life cycles.

Where is DPP data stored?

The DPP Registry is the EU’s central index for Digital Product Passports. It connects each product’s unique identifier with its passport, while the detailed product data remains in decentralized storage. This allows the correct DPP to be located without the EU storing every product’s complete data. Economic operators remain responsible for the detailed product data.

DPP access is role-based. Consumers, supply-chain partners, customs authorities, and market-surveillance authorities may see different information under the applicable product rules. This protects confidential business data while giving each user access to the information needed for their role.

Detailed DPP data uses decentralized storage. The economic operator may host the primary data directly or use a DPP service provider. The ESPR also requires a backup copy through an independent DPP service provider so that the passport remains available for the required period.

DPP Registry launch

On July 20, 2026, the European Commission launched the Digital Product Passport Registry and a separate testing environment. Economic operators can access through a secure user interface or an API. 

Commission Implementing Regulation (EU) 2026/1778 launched on July 16, 2026 and with effective date on August 6, sets rules for access management, user verification, data registration, storage, and the Registry’s technical architecture.

This does not mean that DPPs are mandatory yet. A product needs a DPP when the relevant ESPR delegated act or sector law requires it.

How do DPPs affect construction products?

The revised Construction Products Regulation (CPR) introduces a separate DPP system for construction products. It will require:

• A construction-specific DPP containing key technical, safety, compliance, and environmental information.
• A European Commission delegated act to establish the system, which is intended to be compatible and interoperable.  
• Manufacturers to provide DPPs 18 months after that act enters into force, where the relevant product standards apply.
• A separate rollout timeline.
• Timeline: The European Commission’s new Digital Product Passport hub gives an indicative Q2 2027 milestone for the CPR delegated act on construction materials. 

Together, ESPR and CPR ensure that construction product DPPs meet general EU sustainability standards while addressing sector-specific needs. 

While the ESPR does not replace Environmental Product Declarations (EPDs) with DPPs, it is expected that EPD datasets will be incorporated into the Digital Passport framework, particularly those aligned with EN 15804+A2 standards. In practical terms for construction manufacturers, EPDs can likely provide the standardized environmental data required for DPPs. The final data fields will depend on the CPR delegated act and the applicable technical specification. 

What information needs to be included in the DPP?

The information stored in a DPP may cover the following dimensions, as defined in the regulation:

• Unique product identifier (product ID): DPPs should be linked to a unique operator identifier and a unique facility identifier to facilitate traceability
• Technical performance (functionality, durability, efficiency)
• Environmental performance (carbon footprint (GWP), resource use)
• Legal compliance (CE markings, chemical safety, regulatory adherence)
• User manuals and safety instructions
• End-of-life handling guidelines (repairability, recyclability, modularity)

ESPR allows the Commission to define product-specific data requirements through delegated acts. For construction products, the CPR introduces specific technical rules. The DPP of a construction product needs to include: 

• Declaration of performance and conformity (DoPC) 
• General product information, instructions for use, and safety information
• Technical documentation 
• Label 
• Other documentation applicable to the product under other Union laws 
• Data carriers of key parts for which a digital product passport is available 

The DPP will link this information to unique identifiers for the product, the economic operator, and the manufacturing facility. These identifiers must follow technical specifications adopted by the Commission or listed in harmonized standards published in the Official Journal of the EU, ensuring interoperability across platforms and systems. Manufacturers are obliged to provide a DPP within 18 months after establishment of DPP system and in accordance with the harmonized technical specifications and European assessment documents.

The DPP must be accessible and machine-readable via a scannable data carrier (e.g., QR code, watermark), ideally placed directly on the product. This ensures the data remains accessible throughout the product's life, including at the repair, resale, or recycling stage.

Who needs to create DPPs?

The DPP requirements will apply to all product categories identified by the European Commission through delegated acts. Once applicable, it will cover all relevant products placed on the EU market, including those produced within or imported from outside the EU.

Stakeholders and responsibilities:

• Manufacturers: Responsible for compiling and maintaining accurate DPP data in structured formats, and adopting digital tools for life cycle and material data management.
• Importers and distributors: Obligated to ensure DPP compliance before placing products on the EU market.
• Product designers and engineers: Introduce data traceability and circularity principles into design processes.
• Sustainability managers: Integrating DPP requirements into reporting and ESG frameworks.
• Digital service providers: DPP hosting and data management services.

Exemptions from the DPP requirements

There are no automatic exemptions for SMEs, although both the ESPR and CPR leave room for future support measures. Product groups may only be exempted from the DPP if technical specifications are not yet available or if other EU laws already provide a suitable digital system for product information sharing.  The CPR does not specify exemptions from publishing DPPs as there is an established workplan for harmonized standards development. For construction products outside the specified categories in the CPR, the provisions of the ESPR would apply. 

How will DPPs be implemented?

Technical framework

Both the ESPR and CPR mandate the development of harmonized technical requirements for DPPs. These will be adopted either through harmonized standards (published in the Official Journal of the EU) or common specifications via implementing acts by the Commission.

Key requirements include:

• Data must be transferable without vendor lock-in.
• Systems must comply with relevant data protection rules.
• DPP data must remain accessible for the period defined in the delegated acts, even in cases of insolvency or market withdrawal.
• A copy of the DPP must be hosted by an independent third-party service provider to guarantee access over time (digital service provider).

Published DPP standards

Six product-agnostic European standards have already been cited in the EU Official Journal, which means that their correct application provides presumption of conformity with the corresponding requirements of the ESPR:

• EN 18216:2026: Data exchange protocols
• EN 18219:2026: Unique identifiers
• EN 18220:2026: Data carriers
• EN 18221:2026: Data storage, archiving, and data persistence
• EN 18222:2026: APIs for product passport life cycle management and searchability
• EN 18223:2026: System interoperability

Two further drafts remain under formal vote until July 16, 2026:

• FprEN 18239: Access rights management, information-system security, and business confidentiality
• FprEN 18246: Data authentication, reliability, and integrity

How to prepare for DPPs?

Start with product families that drive EU revenue, appear frequently in tenders, or receive repeated distributor and customer data requests. This keeps the first phase tied to sales exposure and avoids a company-wide data project before the final product requirements are known.

1. Confirm which products fall under the ESPR, CPR, Battery Regulation, or another sector law.
2. Decide whether identifiers will be managed at model, batch, or item level, and map the required operator and facility identifiers.
3. Inventory existing information across ERP, PIM, and PLM. Align with Environmental Product Declarations following EN 15804+A2, which are expected to feed into DPPs.
4. Set up internal systems and train teams to gather, validate, and digitize product supply data in line with expected DPP categories.
5. Plan machine-readable exchange, API connections, decentralized storage, and the required backup process.
6. Monitor the delegated acts and technical specifications that will determine the final data fields for each product group. One Click LCA will update this guide as information becomes available.

Prioritized product categories & timeline

According to the 2025 – 2030 ESPR Working Plan, the first product-specific delegated acts were expected to roll out in late 2025, but they have not yet been released. Preparatory work is underway for iron and steel. In 2026, the Joint Research Centre published proposed DPP content for both to support future rules. Other priority products include textiles, furniture, aluminum, and energy-related products.

Ensure EU market access

The Digital Product Passport represents a paradigm shift in how product data is collected, verified, and shared across the EU economy. For construction manufacturers and sustainability professionals, DPPs offer both a compliance challenge and a competitive opportunity. Those who prepare early will be best positioned to access the competitive EU marketplace. 

To stay ahead, follow developments from the European Commission, CEN/TC 350, and sustainability platforms like One Click LCA, which already support structured digital reporting for carbon and life cycle data.