Digital Product Passport: What's a DPP

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 economy

• The Construction Products Regulation (CPR): Regulation (EU) 2024/1305, which tailors sustainability and DPP requirements specifically for the construction sector

The DPP is set to redefine how product data is shared, verified, and used across Europe. As part of the broader Circular Economy Action Plan under the European Green Deal, the DPP aims to enhance product sustainability by embedding transparency into the heart of product value chains.

This article covers:

• What’s a Digital Product Passport (DPP)
• The role of DPP in ESPR and CPR
• 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

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 real-time, accurate product data.

By offering a detailed digital record of a product’s lifecycle, 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 lifecycles.

The role of DPP in ESPR and CPR

The ESPR sets overarching rules for DPPs:

The DPP is an important component of the Ecodesign for Sustainable Products Regulation (ESPR), which seeks to improve product sustainability across all stages of the value chain by imposing stricter sustainability requirements for products being marketed in the EU. Unlike the previous Ecodesign Directive, which focused primarily on energy-related products, ESPR expands its scope to cover a broader range of product groups, including construction materials, textiles, electronics, and intermediate products like steel and aluminium.

In this expanded framework, the DPP enables open data sharing, supporting broader industry collaboration and accountability for all actors. By establishing common guidelines for the information covered by the passport, the DPP also paves the way for a much needed harmonization across the EU countries. To ensure accessibility, a copy of the DPP must be hosted by an independent third-party service provider. Finally, having a digital record of all environmental, compliance, material composition, and disposal information allows consumers and decision-makers to make informed choices and assess the environmental impact of their projects at an early stage.

The revised Construction Products Regulation (CPR) also integrates the DPP concept into its sectoral legislation, requiring: 

• A construction-specific DPP aligned with ESPR principles but tailored to product performance, safety, and lifecycle characteristics in the built environment. 

• Integration with the EU Construction Products Database 

• Mandatory DPPs for many regulated construction products by 2030, with a phased implementation starting from 2025 

Together, ESPR and CPR ensure that construction product DPPs meet general EU sustainability standards while addressing sector-specific needs. The European Commission is expected to adopt delegated acts that will support the establishment of a construction digital product passport system in addition to the framework of the ESPR. Both systems are intended to be compatible and interoperable.  

In practical terms, the DPP will need to integrate with tools like environmental product declarations (EPDs), especially for construction products. While the ESPR does not replace EPDs with DPPs, it is expected that EPD datasets will be incorporated into the DPP framework, particularly those aligned with EN 15804+A2 standards.

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)

• 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 harmonised 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 will need 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 lifecycle 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 requirement

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

To ensure a coordinated rollout, the ESPR mandates 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)
  
  

A dedicated Digital Product Passport service provider ecosystem is expected to emerge, and rules governing these actors will be defined in a delegated act anticipated at the end of 2025.

How to prepare for DPPs

Although final delegated acts are still under development, here’s how manufacturers can get ready:

1. Align EPDs with EN 15804+A2 standards. These are expected to feed into DPPs, especially for construction products.
2. Set up internal systems to gather, validate, and digitize product supply data in line with expected DPP categories.
3. Train internal teams to ensure the responsible departments understand the requirements of DPPs and obligations for data compliance.  
   
4. Ensure traceability by linking products with operator and facility identifiers.
5. Engage with service providers to ensure DPP-compliant data storage and access solutions.
6. Monitor the Commission’s updates on technical specifications and product group inclusion.

Prioritised product categories & timeline

According to the 2025 – 2030 ESPR Working Plan, the first DPP-related delegated acts will begin to roll out in Q4 2025, focusing initially on priority product groups like textiles, furniture, iron, steel, aluminium, and energy-related products. A mid-term review in 2028 will assess the progress and potentially expand DPP requirements to new sectors, including chemicals and footwear.

The CPR is quite specific with product categories that will be covered and have established a priority list for developing harmonized standards. The first harmonized standards are expected to drop by the end of 2025. 

Securing your product’s access in the EU market

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.