The Digital Product Passport (DPP): What companies need to know now

A new era of product transparency

From 2027, the Digital Product Passport (DPP) will be mandatory for the first product groups in the European Union. What initially appears to be another regulatory hurdle is in fact a fundamental paradigm shift: Products receive a “digital ID” that transparently documents their entire life cycle — from raw material extraction to recycling.

For manufacturing companies, this means that anyone who does not have control over their product data will face a massive compliance problem from 2027. However, anyone who acts now can turn this obligation into an opportunity — for more efficient processes, better customer loyalty and real competitive advantages.

What is the Digital Product Passport?

The digital product passport is a standardized, digital data set that provides comprehensive information about a product. It is the central instrument of the EU Ecodesign Regulation (ESPR — Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781), which came into force on July 18, 2024.

Legal basis

• Regulation (EU) 2024/1781 (ESPR) — framework regulation for sustainable products
• Regulation (EU) 2023/1542 — Battery Regulation (already in force)
• Regulation (EU) 2024/3110 — Construction Products Regulation (CPR)
• More product-specific delegated acts from 2026

What information does the DPP need to include?

Depending on the product group, the DPP must provide the following data:

• Product identification: Unique identifiers (GTIN, serial numbers, QR codes)‍
• Material composition: raw materials, recycled content, critical materials‍
• Manufacturing information: Production sites, supply chain, CO₂ footprint‍
• Performance features: durability, energy efficiency, repairability‍
• Instructions for use: User manuals, maintenance intervals, safety instructions‍
• End of life: Recyclability, disposal instructions, disassembly instructions

Important: The data must be “accurate, complete and up to date” (Article 9 ESPR). The DPP thus acts as proof that performance requirements have been met — and as a basis for market monitoring and compliance checks.

When does the DPP become mandatory? An overview of the schedule

The DPP is being introduced gradually. The ESPR has been in force since July 2024, but the specific requirements for individual product groups are set by delegated acts — and these will come from 2026.

2024: ESPR enters into force; first delegated acts are being prepared
2026: First delegated acts expected for textiles, batteries, electronics
2027: DPP becomes mandatory for first product groups (18 months after the entry into force of delegated acts)
2028-2030: Successive expansion to other product categories (machinery, construction products, chemicals, etc.)

Important: Even if your product group isn't affected until 2029 or 2030, the preparation time is short. In practice, data development, system integration and supply chain coordination take 12-24 months.

What happens in case of non-compliance? Risks and penalties

The ESPR is an EU regulation — it is directly applicable in all Member States, without national implementing laws. This means that the requirements are binding and violations have concrete consequences.

Legal consequences

1. Marketing ban
   Products without a valid DPP may not be placed on the market or put into service (Article 9 ESPR). This means: No CE marking, no market access.
2. Market surveillance and controls
   National market surveillance authorities check compliance on a random basis. Violations may result in:
   
   1. Product recalls
   2. Sales stops
   3. Fines (amount is set nationally, but is based on GDPR level)
3. Liability risks
   Incorrect or incomplete information in the DPP can lead to liability claims — particularly if safety or environmental information is missing or misleading.
4. Reputational damage
   In an increasingly transparent economy, compliance violations are becoming public. Customers, partners and investors expect sustainability — if you don't deliver, you lose trust and market share.

Economic risks

In addition to the legal consequences, there are significant economic risks:

• Delivery delays: Lack of DPP data blocks flows of goods at EU borders‍
• Loss of orders: Public clients and major customers demand DPP compliance as a prerequisite‍
• Higher costs: Subsequent data collection and system retrofits are 3—5x more expensive than planned introduction‍
• Competitive disadvantages: Competitors who start earlier secure market advantages

Why centralized data management is essential

The DPP is essentially a data management problem. The biggest challenge for companies is not the technical provision (QR code, API, portal), but the question: Where does the data come from — and how do I ensure that it is correct, complete and up-to-date?

The typical data problems in companies

1. data silos
   Product data is scattered across ERP, PLM, Excel, PDFs, and emails. No one has an overview of what information is up to date and where.
2. Inconsistent data
   Technical data in PLM, marketing texts in CMS, compliance information in Excel — the sources often contradict each other.
3. Missing supply chain data
   Information on raw materials, CO₂ footprint or recyclability is held by suppliers — and is not systematically collected.
4. Manual processes
   Data sheets are created manually, translations are coordinated via email, updates are forgotten. It doesn't scale.
5. No versioning
   Which product version has which material composition? When was something changed? There is often a lack of traceability.

The solution: Product Information Management (PIM)

A PIM system is the central data platform for all product-related information. It acts as a “single source of truth” and systematically solves the above problems:

• Central data storage: All product data in one place — structured, versioned, comprehensible‍
• Data quality: Validation rules, mandatory fields, consistency checks ensure completeness‍
• Multi-channel capability: Data can be derived for DPP, web shop, catalog, data sheets, ERP‍
• Supply chain integration: Interfaces with suppliers, automated data transfer, approval workflows‍
• Compliance security: Standards, certificates, safety data sheets can be linked directly‍
• scalability: Regardless of whether 100 or 100,000 products — the system grows with you

PIM as a backbone for the DPP

A PIM system is not the DPP itself — but it is the indispensable basis. The typical structure looks like this:

1. Data sources → PIM
   ERP, PLM, suppliers, laboratories, certification bodies deliver data to PIM‍
2. PIM = data backbone
   Validation, Enrichment, Translation, Approval, Versioning‍
3. PIM → DPP platform
   Structured data output to DPP service providers or your own DPP solution‍
4. DPP platform → Access
   QR code, API, portal for customers, authorities, recyclers, partners

practical example‍

A machine manufacturer with 5,000 product variants is introducing a PIM system. Results after 12 months:

• Data quality increases from 60% to 95% completeness
• Data sheet creation time is reduced from 4 hours to 15 minutes
• DPP readiness achieved for first product groups
• Side effect: Online shop conversion increases by 18% (better product data)

What companies should do now: 5-step roadmap

Step 1: Clarify concern

Ask yourself:

• Which of our products are covered by ESPR?
• When will the delegated acts for our sector come out?
• Do we export to the EU or do we produce there?

Tip: Swiss, UK or US companies are also affected when they deliver to the EU. The ESPR applies to all products that are marketed in the EU internal market.

Step 2: Perform data inventory

Capture the status quo:

• What product data do we already have?
• Where are they located (systems, formats, responsibilities)?
• Which DPP requirements can we already meet today?
• Where are the biggest gaps?

Outcome: Gap analysis with prioritized areas of action

Step 3: Develop a data management strategy

Decide:

• Do we need a PIM system? (Answer: Yes, if you have >500 products or complex variants)
• Which systems need to be integrated (ERP, PLM, CRM, web shop)?
• How do we integrate suppliers?
• Who is responsible internally (data governance)?

Tip: Start with a pilot project (such as a product family) instead of a big bang approach.

Step 4: Adapt and integrate IT systems

Technical implementation:

• Select and implement a PIM system
• Set up interfaces to ERP, PLM, suppliers
• Extend data model for DPP requirements
• Define workflows for approval, translation, update
• Connect the DPP platform (or develop your own solution)

Timeframe: 6-12 months, depending on complexity

Step 5: Establish and scale processes

Long-term assurance:

• Staff training (product management, sales, technology)
• Regular data quality audits
• Monitoring regulatory developments
• Continuous expansion to new product groups

Objective: DPP compliance becomes part of the standard product introduction process

Beyond compliance: The opportunities offered by the DPP

The DPP is more than just a compulsory exercise. Companies that use it strategically tap into new potential:

1. Competitive advantage through transparency
   Customers (B2B and B2C) are increasingly demanding sustainability certificates. Whoever can deliver them wins orders.‍
2. Efficiency gains
   Clean product data reduces errors, speeds up processes (preparation of offers, spare parts service, complaints) and reduces costs.‍
3. New business models
   DPP data enables services such as predictive maintenance, product-as-a-service, take-back systems, refurbishment programs.‍
4. Better customer loyalty
   Transparency creates trust. Customers who can easily access product information are happier and more loyal.‍
5. Minimize risks
   Complete supply chain transparency helps to identify risks (delivery failures, compliance violations, reputational damage) at an early stage.

Conclusion: Act now, don't wait

The digital product passport is coming — it's not a question of “if”, but of “when.” Companies that are now starting to structure their product data and set up centralized data management have three decisive advantages:

1. Compliance security: They comply with legal requirements in good time and avoid sanctions.‍
2. efficiency: Planned implementation is 3—5x cheaper than emergency retrofits under time pressure.‍
3. Competitive advantage: They use DPP data as a strategic asset, not just as a compulsory exercise.

Experience shows that companies that take data management seriously benefit far beyond compliance. A PIM system is not an end in itself, but the foundation for digital business processes, customer satisfaction and sustainable value creation.‍

The schedule is running. The question is not whether you implement the DPP — but how prepared you are when things get serious.

Next steps

Would you like to know how well your company is prepared for the Digital Product Passport? We support you with:

• DPP readiness check: Analyze your data landscape and identify a gap‍
• PIM advice: Selecting and implementing the right solution‍
• Data management strategy: Build scalable processes for long-term compliance

Contact us for a non-binding initial consultation.

Sources and further information

1. Regulation (EU) 2024/1781 (ESPR) — Ecodesign for sustainable products - https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng
2. European Commission: Ecodesign for Sustainable Products Regulation - https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en
3. Digital product passport — Wikipedia (overview and timetable) - https://de.wikipedia.org/wiki/Digitaler_Produktpass
4. Fraunhofer IPK: What is a digital product passport? - https://www.ipk.fraunhofer.de/de/kompetenzen-und-loesungen/industrietrends/kreislaufwirtschaft/digitaler-produktpass-dpp.html
5. KPMG: Digital Product Passport — Transparency and Compliance - https://kpmg.com/de/de/home/themen/2025/12/digitaler-produktpass-so-koennen-sich-unternehmen-einen-vorsprung-sichern.html
6. VCI: The Digital Product Passport (DPP) - https://www.vci.de/themen/europa/europa/der-digitale-produktpass-dpp-oekodesign-verordnung-der-eu.jsp