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Founder of Euverify | EU & UKCA Compliance Expert
Ajay is an eCommerce expert with 17+ years of experience as an Amazon, eBay, and Etsy seller and a Shopify specialist. He excels in EU and UK compliance, including GPSR and UKCA, helping businesses expand into European and UK markets. Ajay is the founder of Sweans, a London-based eCommerce agency, and Euverify.com, a SaaS platform streamlining compliance for non-EU sellers.
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How the EU Digital Product Passport Will Work in Practice: From QR Codes to Supply Chain Data
The Digital Product Passport (DPP) is shaping up to be one of the most significant regulatory changes for businesses selling products in the European Union. Introduced under the Ecodesign for Sustainable Products Regulation (ESPR), it’s designed to improve transparency across product lifecycles and support the EU’s goals around sustainability, circularity, and responsible resource use.
A lot of the conversation so far has focused on which products will be affected and when. But manufacturers, importers, and distributors are increasingly asking a more practical question: how will this actually work?
That’s what this article is here to answer. We’ll walk through how the DPP system is expected to function in practice, including how data gets collected, stored, and accessed across the supply chain.
What Is a Digital Product Passport?
A Digital Product Passport is a structured digital record tied to a specific product or product model. It holds key information about a product’s characteristics, composition, environmental performance, and lifecycle attributes.
The goal is to make certain product information more accessible and consistent across the EU market. That information can then be used by a wide range of people, including consumers, market surveillance authorities, repair services, recyclers, and businesses within the supply chain.
Depending on the product category, a DPP might include things like:
- Product identification details
- Manufacturer or responsible economic operator information
- Materials and substances used in the product
- Environmental performance indicators
- Repair and maintenance information
- Durability characteristics
- Recycling or end-of-life guidance
The exact content requirements will vary by product. The ESPR framework allows the European Commission to issue product-specific delegated acts, which will define what information each product group’s passport must include. Many of these delegated acts are still being developed, so the full picture is not yet finalised across all categories.
One important thing to understand: the DPP is not just a document or a static database entry. It’s part of a broader digital system designed to connect product information with the physical item on the market.
The Digital Product Passport Is Not a Single EU Database
A common misconception is that Digital Product Passports will all be stored in one central EU database. That’s not how the system is expected to work.
The DPP framework is designed around interoperable digital systems. Companies will likely be able to store passport data in their own systems or through specialist digital service providers, as long as the data can be accessed and exchanged when needed.
That said, the regulation does reference a registry component for economic operators, and discussions around the central infrastructure are still ongoing. Some form of centralised identifier registry is being considered, even if the full data won’t sit in one place. It’s worth keeping an eye on how this develops.
To make sure different systems can talk to each other, the EU has mandated the development of harmonised technical standards. Under mandate M/604, the European standardisation bodies CEN and CENELEC are working on these standards, though the work is still in progress and timelines have shifted. These standards will cover things like data structure, interoperability, data carriers, security, and APIs for data exchange.
How the Digital Product Passport Will Work
Here’s a step-by-step look at how the system is expected to function, from assigning a product identity through to someone accessing the passport in the real world.
Step 1: Giving the Product a Unique Digital Identity
Every product covered by DPP requirements will need a unique identifier. This is what connects the physical product to its digital record.
Depending on the product category and the specific regulatory requirements, that identifier might apply to a whole product model, a production batch, or in some cases an individual unit. Products with high traceability requirements, for example, are more likely to need item-level identifiers.
This identifier is the foundation of the whole system. Without it, there’s no reliable way to link a physical product to the right digital information.
Step 2: Collecting Data Across the Supply Chain
Once a product has a digital identity, the relevant data needs to be gathered. This is where supply chain collaboration becomes important, because the information required for a DPP often comes from multiple parties at different stages of production.
Some examples of who might contribute what:
Raw material suppliers might provide information on material origin, fibre types or metal content, recycled content levels, and chemical substances used during processing.
Manufacturers might contribute product composition details, manufacturing location, durability characteristics, and repair or maintenance instructions.
Importers and distributors might provide traceability information, product identification details, and supply chain documentation.
The exact data requirements will be set out in the product-specific delegated acts under the ESPR. This means that supply chain transparency and data management will become increasingly important as DPP obligations roll out across more product categories.
Step 3: Linking the Physical Product to the Digital Passport
For someone to access a Digital Product Passport, they need a way to connect the physical product in front of them to the digital record behind it. That’s done through a data carrier attached to the product.
Common options include:
- QR codes
- NFC (Near Field Communication) tags
- RFID (Radio Frequency Identification) tags
Scanning or reading the data carrier pulls up the product’s unique identifier, which then retrieves the passport information. For example, scanning a QR code on a jacket’s label could bring up material composition, repair instructions, and recycling guidance.
Which data carrier a company uses will depend on factors like the product type, durability requirements, cost, and industry-specific technical requirements. QR codes are widely expected to be a popular choice because they’re inexpensive and most people can scan them with a standard smartphone.
Step 4: Storing the Passport Data
The passport data itself won’t live on the product. It’ll be stored in digital systems, whether that’s a company’s internal database, a supply chain data platform, or a third-party data service provider.
Whatever system is used, it needs to be able to retrieve the right information when a data carrier is scanned. Because the DPP will operate across many industries and platforms, interoperability is essential.
This is where the technical standards being developed under M/604 become critical. Once finalised and referenced under the ESPR framework, companies following these standards may benefit from a presumption of conformity, meaning they’ll be considered to meet the relevant regulatory requirements without having to prove it separately.
Step 5: Managing Who Can Access What
Not all DPP data will be visible to everyone. The system is expected to include different levels of access depending on who is requesting the information.
As a rough guide:
Consumers are likely to be able to access sustainability information, material composition, repair and maintenance instructions, and recycling guidance.
Market surveillance authorities would have access to compliance documentation, detailed product specifications, and supply chain traceability data.
Businesses within the supply chain might access operational product data, logistics information, and manufacturing or repair instructions.
This tiered approach is intended to balance transparency with the protection of commercially sensitive information.
What a Digital Product Passport Might Look Like
To make this more concrete, here’s a hypothetical example using a jacket.
A DPP for the jacket could include:
Product identification: model number, brand or manufacturer details, batch or production information.
Material composition: fibre types, recycled content percentage, information about substances used in processing.
Manufacturing information: country of manufacture, supply chain traceability data.
Product performance: durability information, repair instructions, recommended maintenance practices.
End-of-life information: recyclability guidance, material separation instructions.
A consumer could access this by scanning a QR code on the garment label. A recycler might see more detailed material separation information, while a market surveillance authority could pull up the full compliance documentation.
It’s worth noting that textile DPP requirements are still being finalised, so the specific data fields required may look different once the delegated act is confirmed.
Why Companies Should Start Preparing Now
Some product categories are already well into the rulemaking process. Batteries, for example, are subject to DPP requirements under the EU Battery Regulation, with obligations applying from 2027. Textiles are also under active development as a priority category under the ESPR. For businesses in these sectors in particular, the timeline is not as distant as it might seem.
More broadly, preparation takes time, especially when it involves supply chain data collection. Practical steps companies can take now include:
Mapping your supply chain. Understanding where your materials and components come from is a prerequisite for collecting the data a DPP will require.
Assessing what data you already have. Review what product information you currently collect and where the gaps are.
Reviewing your digital infrastructure. Consider whether your existing systems can support product-level traceability and digital data management.
Talking to your suppliers. A lot of the required information will come from upstream in the supply chain. Starting those conversations early gives everyone more time to prepare.
Gradual preparation is significantly less disruptive than trying to get everything in place once a regulatory deadline is looming.
How Euverify Can Help
The Digital Product Passport introduces real operational challenges for businesses placing products on the EU market. Keeping up with evolving ESPR requirements, managing supply chain data, and getting digital infrastructure ready all take time and expertise.
Euverify supports manufacturers, importers, and ecommerce sellers with interpreting EU regulatory requirements, assessing compliance readiness, organising product documentation and traceability information, and preparing for upcoming sustainability and transparency obligations.
If you want to understand where your business stands ahead of DPP requirements, get in touch with us.
Frequently Asked Questions
Is the Digital Product Passport mandatory in the EU?
Yes. The Digital Product Passport will become mandatory for certain product categories under the Ecodesign for Sustainable Products Regulation (ESPR). Requirements will be introduced gradually through product-specific delegated acts adopted by the European Commission, though the timelines for individual product categories are still being finalised.
What is the purpose of the EU Digital Product Passport?
The Digital Product Passport is designed to improve product transparency, support circular economy goals, and help regulators, businesses, and consumers access reliable information about a product’s sustainability, materials, and lifecycle.
Which industries will be affected by the Digital Product Passport first?
The European Commission’s ESPR working plan identifies textiles and apparel, furniture, iron and steel, aluminium, tyres, detergents, paints, and lubricants among the first priority categories. Electronics is expected to follow but has not yet been confirmed as a first-wave category. Batteries are covered separately under the EU Battery Regulation (EU 2023/1542), which introduced its own passport requirements ahead of the broader ESPR framework.
Will the Digital Product Passport apply to imported products?
Yes. Products imported into the EU market must also comply with Digital Product Passport requirements once they apply to the relevant product category. Importers will need to ensure the required passport data is available.
Will small businesses need to comply with Digital Product Passport rules?
Yes. Small and medium-sized enterprises placing products on the EU market will need to comply when their product category becomes subject to DPP requirements. Support measures for smaller businesses have been discussed at a policy level, though no formal SME support framework has been confirmed under ESPR to date.
What are the risks of non-compliance with Digital Product Passport rules?
Failure to comply with DPP requirements could lead to regulatory enforcement actions such as product withdrawals, sales restrictions, fines, or market access limitations within the EU.
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