From 2026, the EU Digital Product Passport (DPP) will shift from a distant regulatory concept to a concrete prerequisite for selling many goods in Europe. This new rule is both a compliance challenge and a chance to centralise product data now scattered across ERPs, spreadsheets and supplier emails.
If you manufacture, import or distribute in the EU, you will have to attach a verifiable digital identity to every product and feed it with accurate life-cycle information. The same AI-driven data backbone that already supports eco-contribution and REP reporting can power your DPP strategy.
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The DPP is a mandatory digital record that follows a physical product throughout its life. Created under the Ecodesign for Sustainable Products Regulation (ESPR) that entered into force in July 2024, it will progressively cover almost all physical goods sold in the EU, including imports.
Every item will carry a unique digital identifier—QR code, NFC tag or RFID chip—linking to a structured file in a central EU registry. When scanned, the user reaches the official digital identity of the product.
Each passport must include at minimum: Identification data (product name, model, batch, ISO/IEC-compliant ID) Materials and components (composition, origin, hazardous substances, recycled content) Environmental footprint (energy use, carbon impacts, durability, repairability indicators) Compliance documents (certificates, declarations of conformity, end-of-life instructions) Supply-chain data (who made what, where and when, with audit trails)
The DPP has a public layer for anyone (in the 24 official EU languages) and restricted layers for professionals and authorities. Sellers must update the passport whenever the product, supply chain or regulations change, treating it as a living digital twin—never a one-off label.
July 2024: ESPR becomes applicable; the EU starts drafting detailed rules for priority sectors such as textiles, batteries and electronics. Companies should already review product data and spot gaps.
End 2025: First delegated acts expected, defining exact data fields per product group.
July 2026: Central EU DPP registry goes live. First delegated acts apply with an 18-month transition window. Batteries and energy-intensive industrial equipment are first.
February 2027: Electric-vehicle and industrial batteries above a set capacity must provide highly detailed passports—often 100+ data points.
2027-2030: More product families join: textiles, electronics, furniture, construction products. Near-full market coverage is expected around 2030.
No full exemptions exist for SMEs. Importers must keep technical documentation for at least ten years and produce it on request.
Generate a unique, standards-compliant identifier per product, encode it (QR/NFC) and link every physical unit to its digital record for full life-cycle traceability.
Describe materials and components, their origin and any hazardous or recycled content. Structured, machine-readable data from suppliers is essential.
Passports often include energy consumption, life-cycle carbon footprint, repairability/upgrade scores, expected lifetime, maintenance schedules and spare-part availability. Standardise the format to match delegated acts.
Attach declarations of conformity, CE documents, safety certificates and clear end-of-life instructions (dismantling, reuse, material separation). These fields align closely with existing REP obligations.
Identify the economic operators—manufacturer or importer creating the passport and distributors placing the product on the market. All data must stay authentic, current and audit-proof.
Map where product data lives (ERP, PLM, PIM, spreadsheets, supplier portals, quality docs). Spot which DPP fields you already have and which are missing. Choose one priority product line—batteries or energy-intensive equipment are obvious early pilots—and assign clear internal roles.
Consolidate information into machine-readable formats (JSON, XML). Engage suppliers for granular breakdowns of materials and origins, updating contracts if needed. Design a data model that can also serve REP eco-contribution reporting.
Your system must generate/manage identifiers, connect securely to the EU registry, enforce tiered access and log changes for ten years. An API-first approach lets you embed compliance logic in ERP, PIM and e-commerce platforms. See Compliancr for an example.
Create passports for one product line, attach identifiers to real items and test scans with internal users, distributors and, if possible, a regulator. Fix missing data, bottlenecks and legal uncertainties before scaling.
Expand coverage to more categories and markets. Embed DPP workflows in product-development processes so new models trigger passport creation automatically. Monitor new delegated acts and update your data model as the scope widens.
French REP rules already require producers to identify channels and declare eco-contributions for packaging, textiles, EEE, furniture, batteries and more. Manual management is error-prone.
Our AI engine can identify applicable REP channels from a barcode or product sheet, calculate contributions in real time, prepare declarations and integrate via API. The same logic applies to DPP:
AI benefits: Automatically map products to DPP requirements and delegated acts; Extract attributes from technical docs and certificates; Detect inconsistencies or missing data fields before they cause non-compliance; Populate DPP templates and sync them with EU registries and national REP systems.
A unified, AI-supported compliance backbone lets you handle DPP, REP and other sustainability reporting in one place. Learn more on AlgoREP.
The main responsibility for creating and maintaining the DPP lies with manufacturers and importers; distributors must confirm a passport exists before placing goods on the market.
Penalties include fines, recalls, withdrawal of CE marking and market exclusion. Yet a solid DPP strategy also demonstrates sustainability, supports repair/reuse services, reduces waste and builds trust with retailers and regulators.
Who needs to comply? Any company manufacturing, importing or distributing covered products in the EU. No blanket SME exemption.
Does the DPP replace eco-contribution and REP duties? No. DPP focuses on product-level information; REP finances waste collection and treatment. The same data can serve both, but frameworks differ.
What if my products are made outside the EU? You or your EU-based importer must still comply and work with non-EU manufacturers to collect the required data.
Is a marketing QR code enough? No. The identifier must link to the official passport in the EU registry, not to a marketing page.
How long must I keep DPP data? At least ten years, matching other EU product-compliance rules. Automation and robust governance are essential.
Bringing DPP and REP duties together lets you build a single, AI-powered source of truth for product compliance. Start with priority categories such as batteries and industrial equipment, invest in interoperable infrastructure and turn DPP from a burden into an efficiency driver.
