Industries covered by the DPP: check if it can involve you

Industries covered by the DPP will be subject to new requirements in phases. The earliest specific deadline applies to certain types of batteries. The EU’s immediate priorities also include textiles, clothing, footwear, tires, furniture, mattresses, iron, steel, and aluminum.

If you’re responsible for production, quality, compliance, IT, or product data, check below to see if your sector is among the priorities. You’ll also learn what information you should organize before it’s required by regulation or a customer.

The ESPR Regulation establishes a legal framework for the digital product passport. It covers physical goods placed on the market or put into service in the European Union, including components and intermediate products. Excluded, among other things, are food, feed, medicinal products, and live plants and animals.

However, there is no single deadline that applies to all manufacturers. The specific requirements will be set forth in subsequent regulations concerning specific product groups. These regulations will define the scope of data, the level of product identification, the rules for access, and the effective date of the requirement.

The first ESPR work plan for 2025–2030 covers, among other things, iron and steel, aluminum, textiles (especially clothing and footwear), furniture (including mattresses), and tires. The list also includes detergents, paints, lubricants, chemicals, energy-related products, ICT equipment, and other electronics.

The inclusion of a product in the work plan does not yet imply an active DPP obligation. However, it confirms that this group is to be prioritized in the work on ecodesign requirements.

Effective February 18, 2027, a battery passport will be required for:

The deadline is set forth in EU Regulation 2023/1542.

The electronic passport is to contain information regarding the battery model as well as data specific to a particular unit. This will include, among other things, identification, composition, technical parameters, and information needed by entities involved in repair, reuse, and recycling. Some of the data will be public, while access to sensitive information will be restricted to designated groups.

For the vehicle manufacturer, this means that the battery must be linked to a specific vehicle. Suppliers of cells, modules, and materials will provide data to the company responsible for the vehicle passport.

The first step should be to identify the source of each field. The information may come from design documentation, production systems, test results, and supplier declarations. A QR code will provide a ready-made dataset, but it will not create it on its own.

Textiles—with a particular focus on clothing and footwear—have taken center stage in the ESPR’s work. EU regulations do not yet specify a single effective date for the entire sector.

A future digital product passport for clothing could include information on:

The exact set of fields will be specified in the regulation governing this product group. Therefore, the company should not build a complete solution based on unofficial lists circulating in the industry.

The biggest gap in the textile sector concerns data from suppliers. The brand knows the model, size, color, and basic composition of the product, but information about the origin of the fiber, chemical additives, or materials used in buttons and stiffeners may already be held by several different entities.

A sample shirt consists of fabric, thread, buttons, and stiffening elements. A change in the supplier of any one component should be assigned to the appropriate product version. Without version control, the product passport may display data from a previous batch.

A good place to start is with a single collection or product family. Review the complete list of materials, supplier documents, and the ability to link information to a specific model.

The automotive sector must be analyzed at the level of parts and materials. Car manufacturers use batteries, tires, steel, aluminum, textiles, plastics, and electronics. Several of these categories are already included in the EU’s work plan or are subject to their own regulations.

The extent of the changes therefore depends on the product.

The wheel manufacturer may be asked to provide information on the alloy grade, the origin of the material, and the percentage of recycled aluminum. The seat supplier will need data on fabrics, foams, plastics, and how the components are separated, and the battery manufacturer must prepare for the requirements taking effect in 2027.

A component supplier will not always issue a final certificate. It may still be responsible for providing verified data to the vehicle manufacturer. Such requirements may be included in the purchasing specifications before a formal obligation is established for a given part.

The greatest risk concerns information not related to the part number and product version. A change in raw materials, formulation, or subcontractor may then not be reflected in the data provided to the customer.

An automotive company should review the product’s material structure, versioning rules, and OEM customer requirements. A well-prepared process will enable the company to respond to a customer inquiry without having to manually review documents from multiple orders.

Tires, furniture, and mattresses have been identified as priorities in the ESPR work plan. Detailed requirements will be developed separately for each group.

When it comes to furniture, the types of wood, metals, fabrics, foams, plastics, and adhesives can be important. The manufacturer should be able to link these materials to a specific model and the current version of the documentation.

A mattress consists of several layers that may need to be separated at the end of its useful life. Information such as “foam and fabric” is not sufficient when the individual materials come from different suppliers and require different methods of disposal.

For tire manufacturers, the composition of the compound, durability, wear, and the content of recycled materials may be important. The final scope of the data will be determined by future regulations.

You can already check whether the suppliers’ declarations match the product currently being manufactured. The document received with the first order may no longer be current after a change in the formula.

Iron, steel, and aluminum are priority products under the ESPR. This is important for steel mills, foundries, and manufacturers of sheet metal, profiles, and machined parts.

Customers may need information about:

A manufacturer that declares the percentage of recycled aluminum in a device must specify which component contains that material, as general information regarding the supplier’s entire product line may not be sufficient.

The material supplier should prepare a standard set of information to be provided along with the lot number and product identifier. This will streamline the handling of customer inquiries and reduce the need to manually create separate reports.

The sector’s name alone does not provide a complete answer. You need to check the product, component, or material.

Start by asking yourself a few questions:

The information in the passport must be accurate, complete, and up-to-date. A product covered by the relevant act may be placed on the market or put into service only if the required passport is available.

Select a representative product and compile a list of information describing its composition, origin, production, and use.

An ERP system typically stores the item number, lot number, and supplier data. An MES system tracks the production process, while a PLM system manages the product structure and technical documentation. Certificates, declarations, and test results may be stored outside of these systems.

For each field, specify:

Such a map will show whether it’s enough to organize the documentation or whether system integration will be necessary. Only then is it worth choosing an application for publishing passports.

Detailed requirements will be published gradually, but collecting data from suppliers may take much longer than configuring the passport itself.

It’s best to start with a single product family, a list of sources, and a shortage log. This will allow the company to understand the actual scope of work before requesting data becomes a condition of the order.

The battery passport has a specific deadline. The ESPR’s initial plan also highlights textiles, clothing, footwear, tires, furniture, mattresses, iron, steel, and aluminum.

A single date has not yet been set for the entire apparel sector. Textiles are among the priority groups, but the deadline and scope of the data will be specified in a separate act.

This depends on the product and the applicable regulations. However, the supplier may be responsible for providing the data to the final manufacturer, who prepares the product passport.

The regulations do not mandate a specific software program. However, the company must ensure that the data is accurate, complete, up-to-date, and accessible. With dispersed data sources, it may be necessary to integrate existing systems.