Digital Product Passport: Who It Applies To and Which Industries It Will Cover
The Digital Product Passport – who it applies to? First, to companies that place products covered by new ESPR rules or sector-specific regulations on the EU market. Battery manufacturers will be the first to be affected, followed by industries such as textiles, tires, furniture, mattresses, iron, steel, and aluminum. The requirements may apply to manufacturers, importers, brand owners, distributors, and certain suppliers in the supply chain.
The DPP, or Digital Product Passport, is a digital set of product information covering its composition, origin, parameters, repair, recycling, and end-of-life handling. The data is intended to be available electronically, for example through a QR code, NFC, or another data carrier. The European Commission describes the DPP as a digital identity card for products, components, and materials.
This issue should be especially important for people responsible for production, quality, procurement, ESG, regulatory compliance, product data, and sales in the EU market. If your company already collects data on raw materials, batches, suppliers, certificates, or inspection results, part of this work may soon become the foundation for preparing a Digital Product Passport.
Who Will the Digital Product Passport Apply To?
The new requirements will apply to companies that manufacture, import, or sell regulated products in the EU market. The scope of responsibility will depend on the industry, product type, and the company’s role in the supply chain.
The obligations may apply to:
• a manufacturer that produces a product under its own brand,
• an importer that brings a product into the EU from outside the EU,
• a brand owner, including private label models,
• a distributor or seller that makes a product available on the market,
• suppliers of raw materials, components, and semi-finished products if their data is needed to prepare the passport.
Not every entity will be responsible for the same things. A manufacturer may create the full passport, while a component supplier may provide data on composition, origin, certificates, batch numbers, or recycled material.
This is the first important change: even if you do not issue a passport for the final product, your customer may ask you for data they need in order to meet the new requirements themselves.
What Products Will the DPP Cover?
The ESPR, or Ecodesign for Sustainable Products Regulation, covers a broad group of physical goods placed on the EU market. It applies to products, components, and intermediate products, with exclusions including food, feed, medicinal products, and vehicle parts covered by separate regulations.
The Polish Ministry of Development and Technology indicates that the requirement to have a Digital Product Passport will be introduced gradually. The ESPR working plan for 2025–2030 primarily includes textiles, tires, furniture and mattresses, as well as intermediate products such as iron, steel, and aluminum.
| Product Group | Examples | What It Means for Your Company |
|---|---|---|
| Batteries | EV batteries, industrial batteries above 2 kWh, batteries for light means of transport | The first group with a specific deadline. The battery passport is expected to be required from February 18, 2027, for the indicated categories. |
| Textiles | apparel, footwear, home textiles | Data will be needed on composition, fiber origin, durability, repair, and recycling. |
| Tires | tires for vehicles and machinery | Data may relate to materials, performance parameters, durability, and recycling. |
| Furniture and mattresses | home, office, and hotel furniture, mattresses | Information on materials, components, disassembly, and spare parts will be important. |
| Iron, steel, aluminum | sheets, profiles, semi-finished products, components | Companies will need data on composition, origin, certificates, and environmental footprint. |
| Construction products | materials and products covered by CPR | New regulations create a framework for a product passport system in construction, aligned with the ESPR. |
| Detergents and surfactants | laundry and cleaning products | New rules provide for digital labeling and a product passport for detergents and surfactants. |
| Toys | toys manufactured in the EU and imported toys | The passport is intended to include safety and compliance information and make customs controls and market surveillance easier. |
The list will be expanded through delegated acts and sector-specific regulations. That means the presence of a product in a priority group does not yet mean that all details are known. However, it does mean that companies should already check where their product data is stored and who is responsible for it.
When Will the Digital Product Passport Become Mandatory?
There is no single date for all products.
A deadline has been set for batteries. From February 18, 2027, the battery passport is expected to be required for batteries for light means of transport, industrial batteries above 2 kWh, and electric vehicle batteries placed on the market or put into service in the EU.
For other product groups, deadlines will depend on detailed legal acts. This gives you time to prepare, but delaying the topic until the first customer request may be risky. The hardest part is usually not generating a QR code, but collecting reliable data from production, quality, procurement, and suppliers.
Examples of the Digital Product Passport in Different Industries
Industrial Battery Manufacturer
A battery passport may include a product identifier, data on composition, carbon footprint, recycled material, test results, durability, number of charging cycles, and battery state of health.
Some data may be publicly available, while some may be accessible only to selected entities, such as service providers, recyclers, or supervisory authorities. For a manufacturer, this means connecting technical, quality, environmental, and service data with a specific product.
Apparel Brand
A passport for a jacket may include material composition, fiber origin, substances used, durability, repair instructions, and recycling information.
Textiles are high on the list because they have a major environmental impact. The European Commission states that around 5 million tons of clothing are discarded in the EU every year, or about 12 kg per person, and only 1% of clothing material is recycled into new clothing.
For a brand, this means greater pressure to obtain data from fabric suppliers, trim suppliers, dye houses, and sewing facilities.
Furniture Manufacturer
A passport for an office chair may include data on steel, aluminum, plastics, foams, fabric, wood, spare parts, and disassembly instructions. For a B2B customer, this creates specific value. They can compare products not only by price, but also by durability, repairability, and environmental data.
Steel Component Supplier
A company supplies steel parts to a manufacturer of a final product. It may not have to create a passport for the finished product, but the customer may ask it for material composition, a certificate, batch number, material origin, or environmental data.
In this scenario, the DPP becomes a supply chain requirement. Data must be quickly available, well organized, and assigned to the correct product or batch.
What Data May Be Included in the Digital Product Passport?
The scope of data will depend on the industry and product type. The European Commission points to areas such as the product’s technical parameters, materials and their origin, repairs, recycling options, and environmental impact across the product life cycle.
In a manufacturing company, this will most often include information on:
• material composition,
• origin of raw materials,
• batches and serial numbers,
• certificates and declarations of conformity,
• quality parameters,
• environmental footprint,
• repair and spare parts,
• disassembly, reuse, and recycling.
This data is often scattered: some is in ERP, some in MES, some in quality systems, some with suppliers, and some in technical documentation. That is why preparing for the DPP starts with organizing product data.
Let’s prepare your company to implement the Product Passport.
Although the requirement to introduce the Digital Product Passport will be rolled out gradually, it is worth addressing it early so you can prepare your data properly. At explitia, we know this topic inside and out, and we can support you at every stage of the process, even if you are only starting to explore it. Let’s talk during a free consultation.
Does the Digital Product Passport Apply to SMEs?
Yes, if a small or medium-sized company is part of the supply chain for a covered product.
Example: a mattress manufacturer is preparing for the DPP and asks its foam supplier for data on composition, certificates, test results, and recyclability. The supplier does not create the passport for the finished mattress, but without its data, the manufacturer cannot prepare its own DPP.
For SMEs, this means one thing: it is worth checking now whether the company can quickly provide customers with reliable data on a product, material, or batch.
What Should You Do Now?
You do not need to start with a large project. Start with seven steps:
- Check whether your products are in priority groups.
- List product families, not just individual SKUs.
- Collect the data you already have: composition, certificates, batches, suppliers, inspection results, quality documents.
- Identify the data source: ERP, MES, QMS, PLM, traceability, supplier documentation.
- Mark manual and uncertain data, because this is what most often blocks DPP preparation.
- Talk to suppliers about what information they can provide and in what format.
- Check product traceability: whether you can connect the product with the raw material batch, production line, production time, and inspection results.
Let’s Prepare Your Production for the DPP
If you manufacture, assemble, or process products, it is worth starting DPP preparation with traceability: batches, components, raw materials, quality parameters, and product history.
First step: check whether today you can answer this question: what was a specific product made of, from which raw material batch, on which line, when, and with what inspection results? If the answer requires searching through several spreadsheets and emails, the DPP will not only be a regulatory obligation. It will also be a signal that product data needs to be organized sooner.
What Is the Most Important Thing to Remember?
The Digital Product Passport will apply to companies that place products covered by the ESPR or sector-specific regulations on the EU market. Batteries are closest to becoming subject to the requirement, followed by groups such as textiles, tires, furniture, mattresses, iron, steel, and aluminum. The DPP requires reliable data on the product, its composition, origin, quality, repair, and recycling. The sooner you check where this data is currently stored in your company, the easier it will be to prepare for customer and regulatory requirements.
FAQ – Digital Product Passport – Who It Applies To?
Will the Digital Product Passport Be Mandatory for Every Company?
Not immediately, and not for all products at the same time. The requirement will be introduced in stages, first for selected product groups. Batteries are closest to specific requirements, while the next industries listed in the ESPR working plan include textiles, tires, furniture, mattresses, iron, steel, and aluminum.
Does the DPP Apply Only to Manufacturers?
No. The manufacturer will usually be responsible for preparing the passport, but the data may come from the entire supply chain. This means the requirements may indirectly apply to importers, distributors, brand owners, and suppliers of raw materials, components, and semi-finished products.
What Information Will Need to Be Collected for the Product Passport?
The scope of data will depend on the industry and the specific legal act. Most often, it will include information on material composition, origin of raw materials, batch numbers, certificates, quality parameters, environmental footprint, repair, disassembly, and recycling.
Is a QR Code Enough to Meet DPP Requirements?
No. A QR code or another data carrier is only a way to access information. What matters most is whether the company has reliable, up-to-date, and well-organized data on the product, its components, batches, and documents.
Where Should You Start When Preparing for the Digital Product Passport?
The best place to start is by checking what product data your company already has and where it is stored. A good first step is a data map: ERP, MES, quality, technical documentation, suppliers, certificates, and the traceability system. This makes it easier to see what is missing and which information needs to be organized before detailed requirements come into force.
Find out what you need to do to be ready for DPP requirements.
