Companies operating in the EU are getting ready for the new Digital Product Passport (DPP) requirements. The sentiment is mixed: while some meet the innovation with anxiety, some view it as an opportunity for a competitive edge in the market reshuffle that is to come. Here, we look at the main factors to consider regarding the implementation of DPP, and what tech infrastructure updates are due.
What is a Digital Product Passport?
The Digital Product Passport, or DPP, is a digital document that was proposed as part of the European Union’s strategy for circular economy and environmental impact reduction in 2022, and is to be formally adopted in 2025, with real changes hitting the market by 2026. Introduced under the European Green Deal and specifically mandated by the Ecodesign for Sustainable Products Regulation (ESPR), a DPP is meant to be required for manufacturers, retailers, and supply chain partners, making data more accessible and transparent across the entire product lifecycle.
The goal is primarily to support sustainable production and consumption, that is, to make detailed, standardized information about the materials, environmental footprint, repairability and recyclability readily available via a QR code or similar digital interfaces.
Who needs a DPP?
For companies operating in the EU, the DPP is not optional. According to the proposed ESPR, any business placing products on the EU market that fall under specific high-impact categories will need to comply. These include, but are not limited to:
- Textiles
- Electronics, batteries
- Furniture
- Construction materials
- Industrial and consumer equipment
The European Commission has prioritized these sectors due to their high environmental and resource footprints. Starting from 2026–2027, companies in these industries will likely be among the first required to implement DPPs as part of CE-marking and market access.
What about non-European companies that simply sell on the EU market? These might not be part of the first wave of implementation, but the requirement will expand to these gradually, regardless of where the goods were manufactured.
What information is included in a Digital Product Passport?
The exact data fields will of course differ depending on the product category, and sector-specific delegated acts are being developed and updated right now. What the DPP will typically include in most cases is the following:
- Product composition and materials
- Carbon and environmental footprint data
- Repair, reuse, and recycling instructions
- Energy and resource efficiency ratings
- Durability and lifespan estimates
- Information on hazardous substances
- Compliance certifications and declarations
- Manufacturing origin and supply chain data
Unlike the traditional approach where it was up to the business to decide how to present certain types of such information, the DPP aims to unify the format. The added benefit is that since the data is standardized, it is also machine-readable, which helps to cut some red tape during import and other procedures. It is also searchable and accessible to different stakeholder groups — including consumers, recyclers, regulators, and customs authorities – while preserving sensitive or proprietary business information.
How DPP will affect businesses
At the first glance, DPPs seem like just another compliance requirement, but since they presuppose unified information, the actual implications are much broader than that.
First of all, digital product passports will influence operational, digital, and supply chain processes, since the data that goes in there comes from different stages of the product lifecycle. Companies will have to adopt new ways to collect, verify, store and share product data, and that means some workflows need to be altered. According to a 2023 Capgemini report, over 70% of manufacturers in Europe say they lack the digital maturity needed to meet sustainability data demands, indicating a steep learning curve ahead.
And that spreads to every actor in the supply chain – from raw material providers to recyclers, meaning the demand for digital system interoperability will rise, alongside with data governance and cybersecurity.
As inconvenient as it sounds, this also means more opportunities to gain a competitive edge as the market is going to be somewhat reshuffled. According to McKinsey, 66% of consumers in Europe now consider sustainability when making a purchase, and nearly 80% of EU policymakers believe that product transparency drives better environmental outcomes. Early movers also benefit from smoother access to green finance, ESG ratings, and public procurement opportunities. The DPP becomes a tool for differentiation, showcasing a company’s commitment to transparency, circularity, and innovation.
With that in mind, let’s explore what businesses need to do – at the infrastructure level – to prepare for and thrive under the new Digital Product Passport regime.
Implementing Digital Product Passports
Complying with DPP requirements means adjustments at the level of operations, on the one hand, and making the company’s digital infrastructure support them, on the other. Let’s explore the main aspects separately, since in many cases, DPP compliance doesn’t require an all-new specialized or overarching system – it’s about integrations and interoperability. In Edison’s words, you just need to know where to strike.
#1 Structured data collection and standardization
First of all, there’s the need to structure and standardize data, which often comes from different sources. In many cases, this calls for a product information management system (PIM), or a PLM (product lifecycle management system). The trick is to make them work as centralized repositories, and for that, data transformation pipelines will be necessary to clean, normalize, and convert input data into standardized formats like ML or JSON-LD. Some work needs to be done around metadata schema support to align your internal data structures with sector-specific EU requirements (e.g., for electronics, textiles, or batteries).
#2 System interoperability and integrations
Now, since some data initially rests with different parties in the supply chain, there needs to be seamless data sharing between manufacturers, suppliers, regulators, and consumers. Technologically, this translates to API-first architectures and middleware or ESB (connecting ERPD, CRM, PLM, and partner systems). For some products, compatibility with EU platforms (like EUDAMED for medical products) is also important.
#3 Data privacy and cybersecurity
DPP data may contain sensitive information about product origin, composition, or proprietary processes. That’s why it’s a good idea to enforce role-based access controls (RBAC) to ensure that only authorized users can view or edit sensitive data. Another aspect is end-to-end encryption for data in transit (via TLS) and at rest (e.g., AES-256).
#4 Collaborative supply chain data exchange
Timely data contribution by suppliers and partners is another concern, which is now typically addressed with supplier portals or third-party integrations. With some types of products, blockchain or distributed ledgers provide an extra level of confidence.
#5 Unique product identification and traceability
Each product or batch needs a unique identifier that links directly to its passport. This can be implemented with product ID generation and management systems (e.g., GTINs or UUIDs) aligned with EU specifications. Alongside that, QR codes or RFID tags that can be scanned by retailers, regulators, and consumers are implemented.
#6 Sustainability and circular economy data
Environmental and circularity data are core to DPP compliance. The associated tech includes LCA (Life Cycle Assessment) tools and sometimes CO₂ calculators to feed data into passports.
#7 Automated compliance
With DPP regulations evolving, staying up-to-date is essential, but may require extra effort. To minimize it, implement a regulatory compliance module to flag gaps or changes in data requirements, set up automated alerts for relevant stakeholders when rules are updated, or use reporting/export functions that generate EU-compliant DPP records on demand.
Where to start
Even though there are some fears that the digital product passport requirements will put a bureaucratic and technological burden on SMEs, the actual implementation can be done with aligning the preexisting infrastructure and adding the necessary modules or tools where it’s insufficient. The best place to start here is not tech, but an audit of the existing product and supply chain data.
Once you’ve identified where information is chronically missing, you can start discovering the solutions for scalable digital infrastructure and integrations.
Launching a pilot project with one product line can provide valuable insights before scaling efforts across the full portfolio. Businesses that start early will reduce long-term compliance costs, avoid disruption, and position themselves to lead in an increasingly circular, transparent economy.
If your organization is looking to align with EU DPP requirements and turn compliance into opportunity—now’s the moment to act. Lionwood.software has teams dedicated to custom software development and integration across supply chains, as well as flexible routines for software product discovery. You can contact us to consider the best possible options for the exact needs of your business.
