The Digital Product Passport (DPP) is coming to almost every product sold in the European Union. A scan of a QR code on the product will show where it comes from, what it is made of, how to repair it and how to recycle it. For manufacturers, the question is no longer whether the EU digital product passport arrives, but how to produce the data behind it without drowning in manual work. This article covers the regulatory requirements, the timeline and the practical implementation of the DPP.
- Legal basis: Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, in force since July 2024
- Who must provide it: the economic operator placing a product on the EU market, including importers of products made outside the EU
- Access: through a data carrier such as a QR code, linked to a unique product identifier
- First products: batteries (battery passport from February 2027), followed by product groups from the ESPR working plan such as textiles, steel, aluminium, furniture and tyres
- Technical approach tested by OI4: DPP generated automatically from Asset Administration Shells
What is a digital product passport?
A DPP is a structured set of product information that is accessible electronically through a data carrier on the product, its packaging or its documentation. It covers the entire product lifecycle: raw material, production, use, repair and end of life, with detailed information about the materials used and the emissions caused along the way. Its purpose is transparency. Consumers can compare products by sustainability, repair shops get the information they need, recyclers know which materials they handle, and market surveillance authorities can check compliance.
The DPP is part of the European Green Deal and the Circular Economy Action Plan. The European Commission sees product information as the missing link for a circular economy: without reliable data about materials and repairability, products cannot be kept in use longer or recycled properly. The digital passport closes this gap, improves product traceability and makes the environmental impact of each sustainable product visible.
The legal framework: ESPR and other regulations
The Ecodesign for Sustainable Products Regulation came into force in July 2024 and replaced the old Ecodesign Directive, which only covered energy-related products. The ESPR applies to almost all physical goods on the EU market, with exceptions such as food, feed and medicinal products. It does not set requirements directly. Instead, the European Commission adopts delegated acts for product categories that define each requirement and the content of the passport for that group.
Other EU regulations introduce passports in parallel. The Battery Regulation requires a battery passport for electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh from 18 February 2027. The revised Construction Products Regulation also provides for a digital product passport for construction products. All of these build on the same idea: product data that is machine-readable, interoperable and linked to a unique identifier.
When will the digital product passport become mandatory?
There is no single date on which the passport will be mandatory for everyone. The DPP applies product group by product group, once the delegated act for that group enters into force and its transition period has passed. The timeline so far:
| Date | Milestone |
|---|---|
| July 2024 | ESPR enters into force |
| April 2025 | First ESPR working plan sets priorities, including textiles, steel, aluminium, furniture, tyres and mattresses |
| July 2026 | Deadline for the European Commission to set up the central DPP registry |
| February 2027 | Battery passport becomes mandatory under the Battery Regulation |
| From 2027 onward | First ESPR product groups follow as their delegated acts apply, typically with a transition period after adoption |
Companies should not wait for the act covering their own products. Suppliers will be asked for component data long before the end product needs a passport, and the data structures take time to build.
Which products need a digital product passport?
In the long run, most physical products sold in the EU will need DPPs. The first wave focuses on products with a high environmental impact and a large potential for circularity. The textile industry is among the first product groups, together with intermediate products such as steel and aluminium, furniture, tyres and mattresses. Electronics and energy-related products follow. Industrial components matter even if they are not covered directly: a drive or a sensor becomes part of a machine, and the machine builder needs the component’s data for the passport of the end product.
What information does a digital product passport contain?
The exact content is defined per product group, so the requirements outlined in each delegated act matter. Typical information includes:
- a unique product identifier and the identity of the manufacturer or importer
- materials and their origin, including recycled content and substances of concern
- the carbon footprint and other indicators of environmental impact
- information on repair, spare parts, disassembly and recyclability
- user manuals, safety information and compliance documents
Not everyone sees everything. The regulation allows different access rights, so that consumers see public information while authorities or recyclers get detailed data. Confidential business information stays protected.
Who is responsible for creating a digital product passport?
The economic operator who places the product on the EU market is responsible for its DPP. That is usually the manufacturer, or the importer for products made outside the EU. The rules therefore also apply to companies in the US, Asia and elsewhere that sell into the EU. There is no comparable US federal requirement, but exporters to Europe must comply. In practice, the passport depends on data from the entire supply chain, so suppliers have to deliver structured information to their customers.
How the digital product passport works technically
The ESPR sets principles rather than one technology. The data must be machine-readable, structured and based on open, interoperable standards. Each product gets a unique identifier. A data carrier, usually a QR code, links to the passport. The data is stored decentrally by the economic operator or a service provider, while the Commission’s registry holds the identifiers. European standardization bodies are developing the detailed standards for identifiers, data carriers, interfaces and access rights.
This is where the Asset Administration Shell comes in for the implementation of the DPP. The AAS already provides a standardized digital twin for industrial products, with submodels for the digital nameplate, technical data, documentation and carbon footprint. A DPP built on the AAS reuses data that exists anyway instead of creating a separate system, and keeps traceability across the product life cycle.
How OI4 members implement the digital product passport
OI4 members have tested the AAS-based approach in practice. In a proof of concept, a user configures a bicycle in a demonstrator. The configuration creates a type AAS of the bicycle from the AAS of its handlebar, saddle and wheel. During assembly, instance shells are generated and real process data such as torque values is written back. At delivery, the DPP is created automatically from the synchronized data, including a product carbon footprint calculated from the component footprints. The shells use the submodels Nameplate, Carbon Footprint, Technical Data and Handover Documentation.
A second project, From Regulation to Value, used the OI4 Next Bike to define a practical DPP framework, address lifecycle questions such as change management and design infrastructure concepts that keep data ownership and sovereignty with the companies. Members of the Component Supplier workgroup also offer the DPP as a service on Twinsphere, an AAS platform aligned with IDTA metamodels and ECLASS.
The lesson from both projects: the passport is easiest to produce when product data is structured from the start. Companies that already provide digital twins of their components have most of the DPP requirements covered.
Benefits beyond compliance
The DPP creates work, but also value. Structured product information reduces manual effort in sales and service, improves traceability in the supply chain and supports new business models such as repair, refurbishment and take-back. Supply chain transparency also helps with other regulations, for example carbon reporting. Companies that treat the DPP as part of their product data strategy, rather than as a separate compliance project, get the most out of it.
What are the concerns about digital product passports?
The main concerns are the effort for small and medium-sized companies, the protection of confidential data, the quality of supplier data and the risk of incompatible solutions. Interoperability addresses the last point: if every platform uses its own format, suppliers have to deliver the same data in many versions. Open standards such as the AAS and the work of the European standardization bodies aim to prevent this.
Frequently asked questions
When will the DPP be mandatory?
It depends on the product group. The battery passport applies from February 2027. Other product groups follow as the European Commission adopts delegated acts under the ESPR, with the first groups from the 2025 working plan expected from 2027 onward.
Does the US have a digital product passport?
There is no federal US requirement comparable to the EU DPP. US companies that sell products in the EU must still provide a DPP for product groups covered by EU rules.
What is the difference between the DPP and the ESPR?
The ESPR is the EU regulation that sets ecodesign requirements for sustainable products. The digital product passport is one of its instruments: the digital record through which the required product information is made available.
What does a QR code on a product have to do with the DPP?
The QR code is the most common data carrier. Scanning it opens the passport via the unique product identifier, so the information is available without a separate app or database search.
How does the Asset Administration Shell help with the DPP?
The AAS provides a standardized digital twin with submodels for nameplate, technical data, documentation and carbon footprint. A DPP can be generated from these shells automatically, as the OI4 bicycle demonstrator shows.
