The Ecodesign for Sustainable Products Regulation – ESPR (EU) 2024/1781 – entered into force on 18 July 2024. With it, the Digital Product Passport (DPP) became a future obligation for large parts of European industry. This article explains precisely what the ESPR requires, which product groups are affected and when, and how the path from framework regulation to enforceable compliance actually works.

What Is the Digital Product Passport under the ESPR?

The Digital Product Passport is a key EU initiative designed to make product-specific information (such as origin, carbon footprint, repairability, and recyclability) accessible to all stakeholders across the value chain. Its objective is to support the transition to a circular economy by encouraging products that are more durable, resource-efficient, and sustainable.

ESPR as a framework – how the DPP becomes enforceable

The mechanism most companies underestimate: the ESPR itself does not define product-specific mandatory data fields. It establishes the legal framework and core principles. The delegated act for each product group then determines exactly which data points a DPP must contain.

The practical implication is significant. Companies whose products fall under the ESPR must monitor not just the regulation itself, but the specific delegated act for their product category, and implement it once adopted. The transition period after a delegated act is published is at least 18 months.

Companies that start building their data infrastructure now – material composition, supply chain data, product identifiers – will be in a substantially better position than those who wait for the delegated act to land. For a clear-eyed look at common misconceptions about the DPP, including the myth that all products are already affected, see our dedicated article.

Scope: Which Products Are in Focus?

Contrary to common misconceptions, not every product is affected immediately. The ESPR Working Plan 2025–2030 prioritizes product groups with the greatest potential for environmental improvement.

The First Wave of Prioritized Products

The European Commission is currently focusing on the following product categories:

• Textiles: The primary focus is on clothing and apparel. (Note: Footwear has been deferred due to its comparatively lower environmental impact and will be reassessed in a future review starting in 2027.)

• Furniture: Including mattresses and other furnishing products.

• Metals: Iron, steel, and aluminum, classified as intermediate products.

• Tyres: With a focus on improving recyclability and increasing recycled content.

• Energy-Related Products: Existing ecodesign principles already apply to these products and are being gradually integrated into the new DPP framework. Examples include household appliances, ICT equipment, and electric motors.

Other product groups, such as chemicals, are not currently considered top priorities due to their complexity. The EU plans to begin studies in late 2025 to define the scope and requirements for these sectors.

Important: Product-Specific Regulations

In addition to the ESPR framework regulation, several product categories are governed by dedicated EU regulations that also require a digital product passport:

• Batteries: Regulated under the EU Battery Regulation (EU) 2023/1542.

• Construction Products: Regulated under the Construction Products Regulation (EU) 2024/3110.

• Toys: Regulated under the new Toy Safety Regulation (EU) 2025/2509.

Regulatory Timeline: Key Milestones

What Data Goes Into the DPP? The Attributes

The Digital Product Passport is not a static document, but rather a dynamic collection of specific attributes (data points). Because the exact mandatory attributes for most industries are still being defined by the EU and will only be finalized with the respective delegated acts, companies need a highly flexible data model.

The core attributes that the system will generally need to map include:

• Identifiers: Unique identifiers for the product, the batch, and the manufacturer.

• Materials & Origin: Material composition, the presence of substances of very high concern (SVHCs), and supply chain data.

• Sustainability: Carbon footprint, recycled material content, and circularity metrics.

• Usage & Repair: Documentation regarding installation, maintenance, repairability, and proper recycling.

The challenge for businesses lies in systematically aggregating these attributes from existing systems (such as ERP or PIM) in a flexible manner as soon as the EU publishes the exact specifications for their specific industry.

How Does the DPP Get Onto the Product? The Role of Data Carriers

The Digital Product Passport can only serve its purpose if it is reliably accessible to consumers, authorities, and recyclers in everyday scenarios. Legal requirements therefore strictly dictate that the information must be accessible via a physical data carrier attached directly to the product, its packaging, or accompanying documentation.

In practice, this will almost always be handled via a machine-readable QR code or an RFID/NFC tag. The EU stipulates that these data carriers must be based on open, non-proprietary international standards (such as the harmonized European standards EN 18219 and EN 18220).

The technological challenge for companies involves interoperability and durability: A simple, static link to a traditional website is not enough. The data carrier must remain legible throughout the product's entire lifecycle and output dynamic, standard-compliant data that can communicate directly with the central EU Product Passport Registry.

Conclusion for Businesses

The DPP requirements are mandatory. Instead of hesitating, companies should now focus on a time-saving and legally compliant implementation.

Our Recommendations

• Assess Your Product Portfolio: Determine whether your products fall within the prioritized categories outlined in the ESPR Working Plan 2025–2030.

• Build a Robust Data Foundation: Start collecting and digitizing product information early, including material composition, supply chain data, and sustainability metrics.

• Monitor Regulatory Developments: Since requirements will be introduced on a product-category basis, staying informed about upcoming delegated acts is essential.

Next Steps: How to Start Your DPP Implementation

The requirements for the Digital Product Passport are complex, but with the right preparation and technology, they are completely manageable. No matter where your company currently stands, we are ready to help you take the next step:

• Want to dive deeper into the regulations? Learn everything about the latest deadlines, affected industries, and best practices for building your data in our live webinar.

• Looking for a concrete software solution? See for yourself how data structuring, attribute management, and nameplate provisioning come together with SecIdent.