Preparing for the ESPR’s Digital Product Passport

What is a Digital Product Passport?

The DPP is a key component of the ESPR and aims to improve the transparency and traceability of a product throughout its lifecycle. The DPP will be mandatory for several product categories, with specific requirements defined by delegated acts.   

All information included in the DPP should be product group specific and will be determined according to the delegated act procedure. Product information may include relevant information on technical performance, information on substances of concern, environmental performance, circularity performance (durability, repairability, etc.), regulatory compliance or product related information (e.g. manuals).  

In addition to the sustainability information, the passport requires four unique identifiers: product identifier, economic operator identifier, facility identifier and the registration identifier, which is not available to the public. All information should be uniquely linked to a product and easily accessible through data carriers (e.g. QR codes) included with the product. Depending on the product group, the DPP requires one of the three levels of granularity: model, batch and item, with some of the associated data being public and some restricted.   

The DPP’s main function is to improve resource management and facilitate sustainable decision-making by various stakeholders such as consumers, repairers, recyclers and waste handlers. By providing a complete view of a product's value chain, DPPs will help companies engage with suppliers, improve sourcing strategies and mitigate environmental and social risks throughout the supply chain. Want to read our first introduction to the ESPR and DPPs?

ESPR Requirements for the Digital Product Passport  

As defined by the European Commission, a product passport is a set of data specific to a product, including information accessible by electronic means through a data carrier. This data carrier is a linear barcode symbol, a two-dimensional symbol or any other automatic identification data capture medium that can be read by a device.  

The data to be included in the DPP has only been defined for batteries in the Battery Regulation. For other product categories the data is yet to be specified by the Commission, but it will be decided in close consultation with all relevant stakeholders and will be laid down in delegated acts. Article 7 in the official ESPR framework includes a detailed list of minimum information requirements that must be easily understandable and tailored to its product type and audience:  

• Performance information: Including repairability, durability, carbon footprint or environmental impact ratings.  

• User guidance: information on installation (also of third-party operating systems where applicable), use, maintenance and repair of the product, as well as collection for refurbishment or remanufacturing and the return or treatment of the product at end-of-life.  

• Instructions for treatment facilities: Instructions on how to recycle or dispose of the product.  

• Other information: Any additional information that can help consumers to choose sustainably. 

In addition, the Commission may set product performance classes, which may be based on single or combined scores. These should reflect significant improvements in performance. The information included should also allow the tracking of substances of concern throughout the life cycle of the product, including names or codes of these substances, locations and concentrations in the product, safety instructions for the use of the product and guidance on re-use, recycling and end-of-life management. 

When setting the upcoming information requirements, the Commission may: 

• Specify dates when information requirements apply, differentiating between substances. 

• Provide exemptions based on feasibility or confidentiality. 

• Ensure consistency with existing laws and reduce administrative burdens. 

Required information should be available from the product, its packaging, labels, user manuals or website.  

What are delegated acts? 

A delegated act is a legal tool which allows the European Commission to add or adjust specific rules under an existing regulation, in this case, the ESPR, without having to go through the full legislative process each time. This helps to ensure that EU legislation remains under the control of EU lawmakers, while still remaining flexible and responsive to technological advances or new sustainability needs. 

Within the framework of the ESPR, certain minimum requirements will be imposed on the products concerned in order to ensure the sustainability of those products. Consequently, the Ecodesign Regulation itself does not set out specific requirements for different product categories. Instead, the European Commission sets these requirements through the adoption of delegated acts. These delegated acts make it easier to set standards for new products or adapt to new eco-design methods, as they can be created, updated or repealed as needed. 

In the framework of the ESPR, delegated acts shall set out detailed requirements, such as: 

• Technical standards for specific product categories in terms of energy consumption, durability or recyclability. 

• Data or labelling requirements, such as data for the Digital Product Passport. 

Timing of ESPR delegated acts 

Consultation with experts, industry and stakeholders, together with a period for public input, usually determines the timing of the adoption of delegated acts. Following the Commission's proposal, the European Parliament and the Council can examine the proposal and possibly oppose it. If neither object, the act enters into force and the requirements become binding for the specified products. The Ecodesign Regulation then provides that economic operators are entitled to a transitional period of 18 months from the date of entry into force of the delegated act to implement the Ecodesign requirements contained therein. The EU has indicated that the first delegated acts under the ESPR are likely to focus on specific product groups, prioritized according to their environmental impact and their potential for improvement in terms of sustainability.  

It is expected that textiles, electronics, furniture, chemicals, iron and steel and aluminum will be among the first areas of focus for these delegated acts. These groups have been shortlisted in the ESPR and should be part of the first work plan that is due by April 2025. The Commission is carrying out consultations and studies to refine which groups should be prioritized first from the product groups mentioned above. Due to high environmental impact and the potential for significant life-cycle optimization, textiles and electronics are strong candidates. This will however only be determined after the assessments and feedback from stakeholders such as the Ecodesign Forum. Once the first working plan has been established, the specific Ecodesign requirements for these identified priority product groups will be prepared and made official through delegated acts, with the first set of requirements expected by 2026 and enforceable from 2027 or 2028. 

Key milestones and timelines for DPP implementation 

ESPR officially came into force on 18 July, but what is already clear about the timeline for requirements in the near future? As mentioned above, after the publication of the regulation, the Ecodesign Forum will be established to consult stakeholders and start drafting specific Ecodesign requirements for different product groups. It is expected that the first meeting of the Forum will take place by the end of 2024. See the figure below for a timeline for what is planned to happen after the regulation takes shape.    

ESPR Digital Product Passport System Architecture 

The Ecodesign for Sustainable Products Regulation (ESPR) introduces an innovative technical system for digital product passports, effectively creating a “digital twin” for products. This digital passport follows a product from sourcing and manufacturing through usage, reuse, and recycling, covering the entire product lifecycle to enhance traceability and sustainability for goods in the European market. While the ESPR outlines the core structure of the DPP, details on the specific data requirements throughout the lifecycle will be governed by delegated acts and regulations like the Battery Passport Regulation. 

Standardization of the DPP is currently underway, involving experts from industry and regulatory bodies in various working groups. Tributech, for instance, is contributing to JTC 24 Digital Product Passport WG4, focusing on developing the DPP Interoperability Framework. Results from these standardization efforts are expected to be published next year. 

The diagram below provides a high-level view of the ESPR DPP system architecture as interpreted by Tributech. While development is ongoing, allowing room for future adjustments, there is significant flexibility for the emerging DPP industry to design and implement tailored software solutions for the DPP ecosystem.  

DPP Registry and Web Portal 

Per ESPR requirements, the European Commission will establish a DPP Registry and a DPP Web Portal. The DPP Registry will offer an API interface, allowing economic operators and DPP service providers to register new products. Depending on regulatory requirements, the registration could be at the model, batch or individual item level. The DPP Web Portal will enable stakeholders to search and compare passport data, linking directly to data stored by the economic operator. 

DPP Data Carriers 

The ESPR mandates a data carrier that must be physically attached to the product, its packaging, or accompanying documentation. This data carrier, a unique identifier for the product, provides access to DPP information. Based on the product and delegated regulatory requirements, the data carrier may represent a model, batch, or individual item. The ESPR does not specify a particular technology, allowing flexibility to use multiple technologies, such as QR codes or NFC tags. We anticipate that the primary criteria for permitted data carriers will focus on technology accessibility for end users, meaning the Commission will likely approve only those technologies that are readily available to the public. 

DPP Data and Identifiers 

The DPP itself may be provided by the economic operator directly or by a DPP service provider that offers technical solutions tailored for general or industry-specific needs. To ensure industry-wide compatibility, the ESPR sets requirements for DPP access, identifiers and interfaces for essential operations. Economic operators or importers must ensure that DPP data is accessible to the public, regulatory agencies, and other stakeholders and, if required, verified by third parties before products can be sold within the EU market. 

The specifics of DPP data requirements will be issued through delegated acts for each industry. DPP data requirements were pioneered by the Battery Passport Regulation, which mandates over 100 data attributes, including data from sourcing, manufacturing, usage (e.g., from the battery management system) and recycling or second-life applications. Over the coming years, additional regulations are expected for industries with an initial focus on products with a high environmental impact.  

DPP Data Backups 

To safeguard DPP data, the ESPR requires that the most recent version of a product’s digital passport be backed up in case the manufacturer ceases operations. Delegated acts are expected to define additional backup requirements, including criteria for backup service providers and potential certification or qualification processes for those offering this service.  

What could your Digital Product Passport look like? 

These visual mock-ups illustrate what a Digital Product Passport could look like for industries such as battery, vehicles, or raw materials such as oil. Each interface is tailored to the unique needs of the industry, but all share the common goal to provide transparent and standardized data access for consumers and professionals. 

1. AVL's Digital Battery Passport 

Our customer AVL's Digital Battery Passport offers the only fully operational solution in a productive battery environment. The AVL Digital Battery Passport combines a secure data platform with their extensive knowledge in legislation and CO2 engineering. The platform is designed to facilitate seamless data sharing throughout the entire battery value chain, ensuring efficient integration, tracking, analysis, and reporting of relevant battery data at every stage of its lifecycle. 

The Digital Battery Passport integrates seamlessly with existing IT landscapes, including IoT/OT/IT frameworks, enabling easy data integration into business workflows. It includes automated validation and compliance checks to help organizations efficiently meet both regulatory and internal requirements. The solution also includes data notarization, which ensures the integrity of product passport data to reduce security risks and ensure accurate reporting. 

In addition to the digital solution, AVL offers consulting services for simplified regulatory compliance and seamless integration into the manufacturer / OEM ecosystem. 

2. Digital Vehicle Passport 

In the automotive industry, the Digital Vehicle Passport can offer a complete digital record of a vehicle's lifecycle. The passport allows stakeholders to access information about the vehicle's components, production processes and usage history, and provides key data on the vehicle's environmental impact, including carbon emissions, fuel efficiency and material composition. It will also allow access to other component passports of the vehicle, such as the battery passport or an inverter passport of an electric vehicle. 

A key aspect of the Digital Vehicle Passport is the End-of-Life Vehicle Directive (ELV), which is designed to ensure that vehicles are disposed of in an environmentally responsible manner once they are no longer used. The ELV Directive sets requirements for the recycling and recovery of materials from vehicles in order to reduce waste and minimize environmental impact. Through the Digital Vehicle Passport, vehicle components that need to be recycled or properly disposed of are managed accordingly to ensure compliance. 

3. Digital Oil Passport 

The Digital Oil Passport provides detailed information about the resource extraction process, including oil source, extraction methods, and environmental impacts, such as emissions and water use, to increase transparency and sustainability in the oil sector.  

As the oil moves through the supply chain, the passport traces refining processes, energy consumption and emissions, providing insight into the sustainability of the total lifecycle. The passport also aids environmental compliance by providing data on emissions and sustainability certifications, helping companies meet international standards and reduce their carbon footprint. In addition, the Digital Oil Passport ensures responsible waste management and recycling practices by tracking the disposal of any by-products in accordance with environmental laws. 

Through these DPP interfaces, we can see a complete workflow from sustainable manufacturing and compliance tracking to consumer interaction, repairability, and end-of-life recycling. Regardless of the industry, the product passport, no matter the specific design and layout, will help extend the life of the product. 

Turning Compliance into Competitive Advantage 

ESPR compliance and the implementation of Digital Product Passports is a path to real business value. By leveraging DPP data, companies can introduce value-added services - such as repair guides, recycling options, or supply chain insights - that improve the customer experience and build loyalty. 

DPPs provide an unparalleled level of transparency and trust that differentiates brands, making sustainability a unique selling point that drives competitive advantage. By empowering buyers with detailed product information, the passport will shape future purchasing decisions in both B2B and B2C markets. Companies will be able to meet the demands of sustainability-oriented customers and partners, positioning themselves as alike. 

Digital Product Passports also prepare for future audits, making it easier to demonstrate compliance and transparency. Starting early with DPP implementation ensures that companies are well prepared for regulatory audits. This helps avoid costly delays and gives companies an edge in the evolving regulatory landscape. By embracing the DPP as a core component of business strategy, companies can lead the way in sustainability while reaping the rewards in customer trust and market positioning.