Product Transparency with Digital Product Passports (DPP)
With growing global awareness around sustainability and ethical sourcing, consumers and regulators are demanding greater transparency in how products are made, used, and disposed of. This shift is reshaping industries, pushing brands to offer accurate, accessible information about their products’ environmental and social impact.
Enacted on 18 July 2024 under Regulation (EU) 2024/1781, ESPR lays the groundwork for a circular economy in which products are designed to be reused, repaired, resold, and recycled, minimizing waste and maximizing value.
A key enabler of this transformation is Digital Product Passport (DPP), a digital tool designed to improve traceability, support regulatory compliance, and drive sustainable innovation. It provides essential data on materials, environmental footprint, and recyclability.
At the forefront of this movement is the European Union, which is driving systemic change through its Ecodesign for Sustainable Products Regulation (ESPR).
This blog explores the benefits of using DPP, information stored, challenges in its adoption, and the role of GS1 standards in ensuring product identification.
Table of Contents
What Is a DPP?
A Digital Product Passport is a standardized digital record that stores and shares detailed information about a product’s lifecycle from raw material sourcing and manufacturing to usage, repair, resale, and end-of-life disposal.
It includes data on origin, composition, environmental impact, and recyclability, making it a powerful tool for improving transparency, traceability, and sustainability across industries.
To ensure accessibility and interoperability, a DPP must be machine-readable and linked to the physical product via a scannable data carrier such as a QR code, NFC chip, or RFID tag, ideally affixed directly to the item.
These carriers embed a unique product identifier, which directs users to the comprehensive digital record. This enables smooth access for regulators, consumers, and supply chain partners.
A DPP presents this information in two ways:
- A human-readable view, such as a simple product webpage with clear text, images, and links.
- A machine-readable format, such as structured data that software systems can process automatically.
The DPP is more than just a webpage you open with a QR code. It is a standard system connecting to checked and trusted technical information, ensuring the details are accurate, reliable, and easy to use anywhere.
This means that data stays at the manufacturer or the economic operator and can be outsourced to a service provider that hosts the data set. The EU will set up a central registry where every economic operator will need to register any product passport for any product that has to be provided with DPP.
The registry will have a very limited set of fields. These fields are:
- Product identifier - Enables linking the relevant dataset
- Economical operator identifier - helps identify who puts the product on the market
- Facility identifier(optional) - indicates the last production place where the item is changed or touched before it’s launched into the market
- Commodity code- checks whether a product is DPP-regulated based on the commodity code or not. If yes, it then identifies which DPP applies, since every category will have a different setup of DPP
- DPP reference/link - links the data set to the central registry, providing all the DPP data points for a maximum of 16 DPP aspects
- DPP backup reference/link - a backup DPP that helps when the primary service provider is no longer there.
While the overarching legal framework for DPPs is already in place, the specific rules and technical requirements are still being finalized and will roll out gradually over the next few years.
Companies are encouraged to begin preparing now, as DPP compliance will become mandatory for an increasing number of products.
DPP prioritized product categories
The ESPR broadens the scope of previous ecodesign directives to cover nearly all physical goods, excluding only food, feed, and pharmaceuticals. The categories included are:
- Textiles (Garments & Footwear)
- Iron and Steel
- Aluminum
- Furniture (including mattresses)
- Tyres
- Detergents
- Paints
- Lubricants
- Chemicals
- Information and Communication Technology Products and other Electronics:
Energy-related products
New ecodesign requirements
Review of current provisions under Directive 2009/125/EC
DPP objectives
- To enhance sustainability and circularity by sharing information, making information available for all economic actors throughout a product lifecycle.
- To create new business opportunities by enabling repair centers and remanufacturing companies. To create new ways to recycle stuff by providing more data on products, so that they can use that data to run these new business opportunities
- To ensure compliance with new norms or new threshold levels for certain indicators. With these passports, the government and customers can check whether products from China coming to Europe, do they have the right DPP information provided and do they comply with the current standards.
- To make better decisions about buying products so they can be in the procurement phase. For retailers putting more sustainable products on the shelf, the DPP can help to provide that information. To help consumers sort the most sustainable versions of products.
DPP Mandate: Current Status
Here’s a simple breakdown of the current progress in creating the standards for DPP service providers.
Call for evidence
Feedback period: 12 November 2024 – 10 December 2024
This first stage sets the foundation for new rules. The regulator outlines the problem that needs to be addressed and presents possible ways to solve it. Early concepts, guiding principles, or draft ideas may be shared.
Stakeholders (industry associations, manufacturers, importers, exporters, technology providers, researchers, NGOs, and public authorities) are invited to respond. Their role is to share data, technical insights, and practical suggestions.
This feedback helps test whether the regulator’s initial thinking is realistic and identify gaps before formal drafting begins.
Public consultation
Consultation period: 08 April 2025 – 01 July 2025
The regulator opens a public consultation. This allows a broader group of stakeholders to participate, including businesses in affected sectors, consumer groups, industry bodies, environmental organisations, trade unions, local authorities, and sometimes individual citizens.
Here, the focus is on reviewing proposed directions or draft rules and giving feedback on practical application, possible risks, and sector-specific impacts.
Upcoming stages
Draft Act stage: The European Commission finalizes the legal text of the Digital Product Passport (DPP) rules, incorporating feedback from prior consultations. This draft specifies requirements for service providers, compliance timelines, and enforcement measures.
Commission Adoption (planned for Q4 2025): The College of Commissioners formally approves the proposal. Once adopted, the draft act is submitted to the European Parliament and EU Council for further negotiation and final approval, moving it closer to becoming binding EU law. This phase ensures the proposal meets legal and policy standards before advancing.
The ESPR broadens the scope of previous ecodesign directives to cover nearly all physical goods, excluding only food, feed, and pharmaceuticals.
16 aspects relevant for the DPP
The aspects of a DPP show how sustainable a product is and how it performs throughout its life. The aspects that will matter most depends on the industry, type of product, and rules that apply. Not every aspect fits every case. They’re flexible tools that help shape a DPP to match different industry needs and product lifecycles.
- Durability
- Reliability
- Reusability
- Upgradability
- Repairability
- The possibility of maintenance and refurbishment
- The presence of the substance of concern
- Energy use and energy efficiency
- Water use and water efficiency
- Resource use and resource efficiency
- Recycled content
- The possibility of remanufacturing
- Recyclability
- The possibility of the recovery of materials
- Environmental impacts, including carbon footprint and environmental footprint
- Expected generation of waste
What Information Does a DPP Contain?
The DPP database will operate as hybrid architecture means that it will be decentralized in structure to allow distributed data ownership, yet linked through a central DPP registry, scheduled to launch by July 2026. This registry will serve as a unified access point, ensuring consistency, traceability, and regulatory governance across industries.
The type of information included varies by industry, depending on regulatory requirements, product complexity, and sustainability goals.
Product identification & compliance: DPP includes core identifiers such as the product name, serial number, and manufacturer details. These ensure traceability and legal compliance globally. Certifications like CE, RoHS, or FSC may also be listed to validate adherence to environmental and safety standards.
Manufacturing process: DPPs document how and where a product was made, including energy and water usage. This is especially applicable in industries like textiles and construction, where production methods significantly impact environmental outcomes.
Material composition: Details about raw materials, their origin, and whether they are hazardous or recycled are included. For electronics and batteries, this helps identify toxic components or rare earth metals, guiding safe disposal and reuse strategies.
Ethical sourcing: Information on fair trade certifications, labor conditions, and sustainable sourcing practices is included. This is particularly essential in the fashion and furniture industries, where ethical transparency affects consumer trust.
Lifecycle & sustainability data: DPPs track a product’s carbon footprint, expected lifespan, and circularity potential. This data supports EU circular economy goals and helps consumers make informed choices. Industries like chemical and packaging benefit from this transparency to decrease waste and improve recyclability.
Technical specifications: Depending on the sector, DPPs may contain dimensions, weight, performance metrics, and software versions. For example, in electronics, this ensures compatibility and supports maintenance and upgrades.
Repairability & maintenance: Installation guides, repairability scores, and spare part availability are often included. This fosters product longevity and supports right-to-repair initiatives, especially in electronics and appliances.
End-of-life instructions: DPPs provide disposal recommendations and recycling instructions. In sectors like construction and automotive, this ensures responsible material handling post-use, supporting the EU’s circular economy goals.
Note that not all data fields apply universally. For example, software versioning is crucial in electronics but irrelevant in textiles. Similarly, ethical sourcing may be emphasized in fashion but is less relevant in packaging. DPPs are customized as per industry to reflect sector-specific priorities and regulations.
DPP data carriers
To connect physical products with their digital records, DPPs rely on data carriers that store or link to lifecycle information. These carriers ensure that product data is accessible, traceable, and secure throughout its journey.
2D barcodes
2D barcodes like GS1 Digital Link QR code plays a key role in DPP by embedding a product’s unique GTIN into a scannable format that connects directly to cloud-based DPP data.
This enables access to product origin, composition, and sustainability details, supporting transparency and circular economy goals when scanned through a GS1 QR code.
RFID/NFC
Radio Frequency Identification (RFID) and Near Field Communication (NFC) technologies allow products to be identified and tracked wirelessly. RFID tags can be embedded into items and read by specialized scanners, enabling real-time inventory management and supply chain transparency.
NFC, commonly found in smartphones, lets consumers access DPP data with a simple tap—making it ideal for retail, automotive, and electronics sectors. These technologies support scalable, interoperable data sharing across the value chain.
Watermarks
Digital watermarks are invisible codes embedded into packaging or product surfaces. They can be scanned using dedicated apps or devices to retrieve DPP data. Watermarks are particularly useful for products where visible tags may interfere with design or functionality, such as in luxury goods or printed materials.
Their discreet nature adds a layer of security and authenticity verification.
GS1 standards and DPP
GS1 is a global standards organization best known for creating the barcode system used in retail worldwide. GS1 Sunrise 2027 initiative also coincides with and helps facilitate the adoption of the DPP.
Sunrise 2027 is a non-mandatory global initiative led by GS1. Its primary goal is to make 2D barcodes fully compatible with retail point of sale (POS) systems by the end of 2027.
The move positions 2D barcodes, such as QR codes and DataMatrix, as an upgraded alternative to the traditional 1D formats (UPC/EAN).
Both 1D and 2D barcodes will often appear on the same product packaging during the transition period. This dual labeling ensures scanning works universally while retailers and manufacturers adapt their systems.
Over time, once adoption is widespread, only one will be needed, either 1D or 2D, depending on the company’s choice.
The use of GS1 standards in DPPs is not mandatory by default but they are strongly recommended and, in some cases, required depending on the industry, region, and regulatory framework.
GS1 standards offer globally recognized methods for product identification, data sharing, and traceability, making them ideal for building interoperable and scalable DPP systems.
GS1 standards ensure that product data is structured, consistent, and accessible across supply chains. They support key DPP functions like serialization, authentication, and lifecycle tracking.
By using GS1 identifiers (like Global Trade Item Number (GTIN)), businesses can connect physical products to digital records in a standardized way, reducing fragmentation and improving regulatory compliance. This also strengthens consumer trust by enabling instant access to verified product information through a single scan.
Most GS1 Member Organizations (GS1 US, GS1 UK) do not provide direct 2D barcode generation services. Their main responsibility is to publish the standards and technical guidelines companies must follow. They provide the framework, but not the actual tools.
Adoption typically follows two routes:
In-house systems – Larger companies with budget and technical resources may build their own barcode generation platforms, but this requires considerable investment.
Solution providers—Most businesses work with GS1 solution partners such as QR Tiger and their GS1 QR code generator for quick implementation, simple scaling, and ensure compliance.
Real-World Use Cases
Fashion and textile industry: In the fashion and textile industry, brands like Nobody’s Child and ASKET are piloting DPPs to track fiber origins, dyeing processes, and recyclability.
As an early adopter, Nobody’s Child is redefining fashion transparency through DPP with RFID threads sewn into garments. These washable identifiers allow each item to be digitally tracked across the supply chain, improving stock accuracy, reducing waste, and optimizing in-store operations.
Customers can scan the QR code on the wash label to access sustainability credentials, register their garments, and get personalized recommendations or loyalty rewards.
Nobody's Child has partnered with Coinbase to use Web3 technology, allowing customers to receive an NFT as a "digital receipt" in a Coinbase wallet. This can be used to prove authenticity for returns or resale.
Automotive industry: Audi and Tesla are leveraging DPPs to enhance transparency in their electric vehicle (EV) battery supply chains. By digitally documenting each battery’s material origin, carbon footprint, and recyclability, they ensure traceability from raw sourcing to end-of-life.
This practical approach builds consumer trust in sustainable mobility and also aligns with the EU’s new battery passport regulation, which will make DPPs mandatory for all EV batteries sold in Europe by 2027. As the regulation phases in, such initiatives position these brands ahead of compliance while reinforcing their commitment to environmental responsibility.
Construction & Real Estate industry: The Edenica office building project in London integrates Material Passports, a type of DPP purpose-built for the construction industry, to track components throughout their lifecycle from sourcing to reuse. The DPP documents details like the type of material, origin, exact location in the building, the installation method, expected lifespan, and whether it can be reused or recycled.
By using DPP, the project realized a reduction in operational energy by 50%, paved the way for circular construction in the UK, and provided a clear plan for reuse, renovation, or disassembly.
Challenges in Adopting DPPs
The implementation of DPPs presents several challenges as outlined below.
1. Lifecycle data complexity: Collecting accurate lifecycle data from diverse suppliers is complex. Ongoing data updates are essential for compliance and efficiency.
2. System compatibility and integration challenges: DPPs need secure systems that work with existing ERP (Enterprise Resource Planning), PLM (Product Lifecycle Management), and CRM (Customer Relationship Management) tools. Integration can be costly and time-consuming for global firms.
3. Protecting sensitive data while ensuring transparency: Sensitive product data must be protected while meeting data privacy regulations (for example, GDPR). Clear access controls are vital to safeguard intellectual property.
4. High setup costs: Initial setup involves digitizing data, staff training, and scalable tech. High upfront costs may deter adoption.
5. Navigating global market: EU-led standards may clash with regional regulations. Global firms must assess supplier readiness and replace non-compliant partners.
The next step in product sustainability
Digital Product Passport (DPP), driven by the EU’s ESRP, is set to become mandatory for key sectors like textiles, electronics, batteries and more moving forward. These passports store essential product data such as materials, origin, repairability, and recyclability, accessible through GS1 Digital URI and 2D barcodes.
The specific rules and official technical requirements are still being finalized. Companies can begin planning for implementation now as DPP compliance will be mandatory for more product categories.
They help businesses improve supply chain visibility, meet sustainability goals, and empower consumers with trustworthy information. Its early adoption ensures regulatory readiness and also builds brand trust and long-term value in a sustainability-driven market.
FAQs
What sectors are exempted under ESPR?
The regulation exempts a few sectors such as food, feed, and medicinal products.
Why are DPPs required in the European Union?
As part of its Circular Economy Action Plan, the European Commission is introducing Digital Product Passports (DPPs) to improve traceability and support sustainable product design, reuse, and recycling.
While greater transparency may also help consumers access reliable product details, the primary goal is to give manufacturers, regulators, and supply chains better data for compliance and circular economy practices.
Is having a QR code on packaging enough to meet DPP regulations?
No, adding a QR code is not sufficient. The QR code acts as a gateway, but the real requirement is the structured, reliable, and complete product data behind it. The data must be structured, machine-readable, and standardized according to EU interoperability standards.
How do DPPs support circular economy goals?
DPPs facilitate:
- Transparent tracking of materials and environmental impact
- Informed decision-making for consumers and regulators to support the EU’s sustainability and circularity objectives.
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