Explanation of the Digital Product Passport

The Digital Product Passport (DPP) is becoming a central element of European product regulation. With the Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781) and the Battery Passport under the EU Battery Regulation (EU) 2023/1542, the DPP is no longer a theoretical concept – it is turning into a concrete requirement for many companies.

At the same time, the topic causes a great deal of uncertainty. Many organisations are unsure what the Digital Product Passport actually entails, how complex implementation will be, and what is truly required to remain compliant. In practice, much of this uncertainty stems from persistent myths and misconceptions surrounding the DPP.

This article addresses the most common misunderstandings and provides a clear, pragmatic perspective on what the Digital Product Passport really requires – and how companies can approach it in a realistic and manageable way.

Myth 1: Everyone sees the same information in the Digital Product Passport

One of the most common concerns about the Digital Product Passport is the fear of full transparency. Many companies assume that all product information will be visible to everyone, including sensitive data such as supplier details, material compositions or internal quality information.

This assumption is incorrect. The Digital Product Passport is not designed as a single, uniform view of product data. Instead, the ESPR explicitly foresees role-based access rights. Different stakeholders along the product lifecycle are entitled to different types of information, depending on their role and legitimate need.

Market surveillance authorities require different data than repair services or recyclers. End consumers, where applicable, only receive a limited and clearly defined subset of information. Confidential or commercially sensitive data does not have to be publicly accessible.

The DPP therefore does not aim for transparency at all costs, but for targeted transparency where it is regulatorily required.

Myth 2: The DPP is just a website or a PDF for download

Especially in e‑commerce or marketing contexts, the Digital Product Passport is often mistaken for a product webpage or a downloadable PDF. A common question is whether an existing online shop page or product document could simply be linked and used as a DPP.

For a proper understanding of the DPP, this distinction is crucial:
The Digital Product Passport is neither a website nor a static document. It is a structured, machine-readable dataset that must meet clearly defined regulatory requirements.

A key element is the registration of the DPP in the EU-wide registry (EC Registry). Digital Product Passports must be registered and uniquely referenceable within this system. Traditional websites or PDFs generally cannot meet these formal and technical requirements. They lack standardised data structures, interoperability, and the ability to support role-based information access.

While a website may be used to visualise or complement information, it is not sufficient to ensure compliance. Reducing the DPP to a web page fundamentally misunderstands its regulatory purpose.

Myth 3: The DPP only affects large corporations or specific industries

Another widespread misconception is that the Digital Product Passport only applies to large enterprises or a small number of industries. While it is true that the DPP is being introduced gradually by product groups, starting with the Battery Passport, this does not limit its relevance to a narrow audience.

The ESPR applies in principle to all products placed on the EU market, regardless of company size. Small and medium-sized enterprises are therefore just as much within scope as large corporations.

This is particularly important for companies that operate as part of a supply chain. Even if they are not required to publish a Digital Product Passport themselves, they may still be obliged to provide structured product data to downstream economic operators who must comply with DPP requirements.

The Digital Product Passport is therefore not a niche topic, but an emerging cross-industry standard.

Myth 4: Implementing the DPP requires a large IT project

The Digital Product Passport is often associated with major IT initiatives, long implementation timelines and high costs. While this concern is understandable, it does not reflect the full picture.

In practice, the main challenge of the DPP lies not in technology, but in data availability and quality. Much of the required information already exists within organisations – spread across different systems, departments or external partners.

The regulation defines what information must be provided, but not how complex the technical implementation has to be. Especially at the beginning, it is entirely possible to adopt step-by-step and pragmatic approaches without embarking on a full-scale IT transformation.

What matters most is gaining early clarity about existing data, identifying gaps and setting realistic priorities.

Myth 5: This is just an EU issue

The Digital Product Passport is often perceived as a purely European compliance topic. While it is indeed driven by EU regulation, its implications extend far beyond Europe.

Any company – including those based outside the EU – that places products on the European market must comply with DPP requirements. As a result, the Digital Product Passport effectively becomes a globally relevant obligation for international supply chains.

Moreover, the DPP is part of a broader global movement towards greater product transparency, traceability and sustainability. Viewing it as a purely regional requirement underestimates its long-term strategic importance.

Conclusion: Replacing assumptions with clarity

There is no doubt that the Digital Product Passport introduces new obligations. However, many of the perceived challenges are based on misunderstandings rather than on the actual regulatory requirements.

In summary:

• Not everyone sees the same information

• A DPP is more than a website or a PDF

• It does not only affect large corporations

• It requires structure, not a massive IT project

• And it is far from being a purely local EU issue

Companies that engage with the real requirements early gain one key advantage: certainty. Understanding what is actually expected makes it possible to implement the Digital Product Passport pragmatically and in line with regulatory expectations.

Next step

If you are currently assessing what the Digital Product Passport means for your organisation, which data is relevant, or how to approach implementation in a structured way, an early and realistic evaluation is essential.

Feel free to contact us to discuss your situation and gain clarity on requirements, data readiness and next steps.