What is the Digital Product Passport and what is its objective?

The Digital Product Passport is a sort of digital identity card for a product. Its objective is to collect and make available useful information to assess sustainability, circularity and compliance throughout the product life cycle.

It is not a simple document archive. The passport will need to allow different actors, such as companies, authorities, professional customers, repairers, recyclers and supply chain operators, to access relevant information based on their role.

In practical terms, the DPP is designed to improve traceability. Through this passport, each product will be described using data connected to its composition, performance, materials, repairability, presence of relevant substances and end-of-life management.

This is particularly important for companies working with complex products, multiple suppliers or distributed production chains. In these cases, a significant part of the required information is not stored in a single company system, but across technical sheets, supplier declarations, certifications, bills of materials, quality documents and environmental analyses.

The operational value of the Digital Product Passport lies precisely here: turning fragmented data into usable information. To do this, companies need to understand which data is already available, which data is reliable, which data needs to be updated and which data is still missing.

ESPR and affected sectors: where the obligation starts

The Digital Product Passport is part of the ESPR, the Ecodesign for Sustainable Products Regulation. Regulation (EU) 2024/1781 expands the approach already present in ecodesign legislation, which was previously focused mainly on energy-related products.

With the ESPR, the European Union will be able to define specific requirements on durability, repairability, resource efficiency, recycled content, recyclability, presence of substances of concern and environmental information. The Digital Product Passport will be the tool used to make this information accessible and controllable.

The obligation will not apply to all products at the same time. The first 2025–2030 working plan identifies the priority categories on which the Commission will start working, but the concrete requirements will be defined through delegated acts specific to each category. For companies, this means that timing, required data and responsibilities will depend on the type of product placed on the market.

The first priority categories can be read in two groups.

Finished products, where the impact is more direct for manufacturers, brands, importers, distributors and operators placing the product on the European market:

• textiles, with a focus on apparel;

• furniture;

• mattresses;

• tyres.

Intermediate materials, where the impact concerns both those producing the material and downstream companies using it in their products:

• iron and steel;

• aluminium.

This distinction matters because it changes the type of preparation required. For a company selling a finished product, the Digital Product Passport will be directly connected to the product placed on the market. For a company producing or using intermediate materials, the issue may instead concern the ability to provide reliable data to industrial customers, manufacturers and supply chains that will need to build the passport for the final product.

Even a company that does not directly sell a priority category may therefore be indirectly involved. A manufacturer supplying components, materials, semi-finished goods or treatments to a customer subject to the new requirements may receive data requests to feed the Digital Product Passport of the final product.

The first step is to verify whether the company’s products fall within the priority categories or whether the company operates as a supplier within supply chains that will be affected. This analysis helps clarify when to start preparing, which information to collect and which internal functions will need to be involved.

What data will the Digital Product Passport need to contain?

The content of the Digital Product Passport will depend on the delegated acts specific to each category. There will therefore be no single model valid for all products, but a set of requirements built around the characteristics and impacts of the category concerned.

Some information will likely be recurring. This includes product composition, materials used, main components, presence of relevant substances, recycled content, technical performance, durability, repairability, recyclability and instructions for maintenance, reuse or end-of-life management.

For a company, the delicate point is connecting this data to the correct level. Some information relates to the individual product, some to the product family, and some to the material, component or supplier. If this structure is not clear, the risk is to collect data that is difficult to use or inconsistent with the required criteria.

The Digital Product Passport also requires stricter source management. A technical data point may come from a product sheet, a certificate, a supplier declaration, a laboratory test or an internal management system. Each piece of information should have a clear origin, an update date and an owner.

This aspect is essential for compliance. If a supplier updates a data point, if a material changes or if a production process is modified, the passport must be able to reflect that change. A DPP built on static information can quickly become obsolete.

The connection with the product life cycle is direct. The required information does not only concern the sales phase, but may cover design, sourcing, production, use, repair, recycling and end of life. This is why the Digital Product Passport pushes companies to look at the product more comprehensively, from material selection to post-use management.

This approach is close to the logic of LCA, because it requires companies to look at the product across several stages of its life cycle. The difference is that the Digital Product Passport does not only measure environmental impacts: it must make updated technical and environmental information accessible to different actors along the value chain.

The link between DPP, LCA and product environmental data

The Digital Product Passport is not the same as an LCA, a Product Carbon Footprint or an Environmental Product Declaration. However, these tools can become important sources for building stronger environmental data.

A product LCA analyses environmental impacts throughout the life cycle, from raw materials to production, from use to end of life. This type of analysis can help the company understand where the most relevant impacts are concentrated and which data is needed to describe the product more accurately. For companies just starting out, it may be useful to begin with a practical guide on how to conduct an LCA, to understand which information to collect and how to structure it.

The Product Carbon Footprint focuses instead on greenhouse gas emissions associated with a product. It can be useful when the passport requires information linked to climate impact or when the company needs to connect product data to emissions reduction objectives. In this case, the work can also be connected to the calculation of the Product Carbon Footprint, especially when the product has a complex supply chain or materials with significant emissions impacts.

The Environmental Product Declaration, or EPD, can also support work on the DPP. An EPD contains environmental information based on product category rules and can provide an already structured documentation base, especially in sectors where product environmental certification is already widespread.

The most operational connection concerns the life cycle inventory, often referred to as Life Cycle Inventory. This phase collects data on materials, energy, transport, processes, waste and emissions. Much of the information needed for a life cycle inventory can also be useful for the Digital Product Passport, if it is organized in a coherent and updatable way.

For this reason, companies that have already worked on LCA, carbon footprint or EPD often start from a stronger base. They have already addressed topics such as boundaries of analysis, data quality, sources, calculation assumptions and the connection between technical data and environmental data.

The DPP, however, requires an additional step. Environmental data must be connected to the product, updated over time and made available according to defined access rules. Data quality remains central, but the ability to manage it continuously becomes just as important.

How to prepare: suppliers, responsibilities and digital tools

Preparation for the Digital Product Passport should start with mapping products and product families. The objective is to understand which items may fall within future obligations, which are connected to priority sectors and which data is already available.

The second step concerns information sources. For each product or product family, the company should identify where data on materials, components, substances, suppliers, performance, maintenance, recyclability and end of life is stored. This work makes it possible to distinguish between internal data, third-party data and information that requires technical verification.

The supply chain will play a central role. Much of the information needed for the DPP depends on suppliers, subcontractors, component manufacturers or logistics partners. This is why it is useful to define clear procedures for collecting, checking and updating information, avoiding non-standardised requests or documents that are difficult to compare.

This work may overlap with other existing ESG processes. Supplier data requests, for example, can be connected to supply chain assessment or to the collection of information on Scope 3 emissions, especially when materials, transport and components have a significant impact on the product’s footprint.

Internal governance is also needed. Design, purchasing, quality, sustainability, production and controlling may have different responsibilities for the same product. Without clear role allocation, the risk is that data is collected multiple times, with different criteria or without someone responsible for validation.

A platform or ESG software can support this process when it allows companies to centralise information, connect it to sources, assign responsibilities and keep a history of updates. The same applies to tools connected to LCA, Carbon Footprint and supplier assessment when product data also needs to be connected to corporate reporting.

The Digital Product Passport will require more organised technical, environmental and supply chain data. Companies that start working now on product mapping, source quality and internal responsibilities will be able to address the obligations with greater control, avoiding the need to rebuild information once the requirements already apply.