What is a Digital Product Passport? A guide for manufacturers
KALIRA Research Team March 10, 2026 8 min read
- A Digital Product Passport (DPP) is a structured record containing a product's origin, composition, and end-of-life data. Mandatory for products sold in the EU under ESPR.
- Battery manufacturers face the first hard deadline: February 18, 2027. Construction products follow in Q4 2027.
- Importers of non-EU products are legally responsible for DPP compliance if the manufacturer has not provided one.
- Start now: register with GS1, collect product data, choose a DPP system, and pilot one product line before the deadline.
What is a Digital Product Passport?
A Digital Product Passport (DPP) is a structured digital record that contains information about a product's origin, composition, repairability, and end-of-life handling. Every product covered by the EU's Ecodesign for Sustainable Products Regulation (ESPR) will need one.
Think of it as a product's permanent file, accessible by scanning a QR code, NFC tag, or data carrier on the physical product. The DPP follows the product through its entire lifecycle: from manufacturing to use, repair, resale, and recycling.
The goal is transparency. Regulators want to verify compliance. Consumers want to know what they are buying. Recyclers need to know what a product contains before they process it. The DPP answers all three needs with a single, standardized data set.
Why DPPs exist
The EU introduced DPPs as part of the ESPR (Regulation 2024/1781), which replaced the older Ecodesign Directive. The reasoning: the EU cannot achieve its circular economy goals if nobody knows what products are made of, how long they last, or how to recycle them.
Previously, this information existed in scattered formats (product data sheets, CE declarations, safety data sheets, EPDs), none of which were standardized, machine-readable, or linked to the physical product.
DPPs change that. One data carrier on the product. One structured data set behind it. Accessible to anyone with the right permissions.
What data goes into a DPP?
The exact fields depend on the product category, but most DPPs include:
- Product identification: Unique identifier (typically a GS1 GTIN or SGTIN), manufacturer name, model, batch or serial number
- Material composition: What the product is made of, including hazardous substances and recycled content percentages
- Carbon footprint: Lifecycle greenhouse gas emissions, calculated per unit or per kilogram
- Compliance documentation: CE marking, Declaration of Conformity, test reports, certifications
- Repairability information: Available spare parts, repair instructions, disassembly guides
- End-of-life handling: Recycling instructions, material recovery potential, disposal requirements
- Supply chain data: Geographic origin of key materials, due diligence declarations
For batteries specifically, the EU Battery Regulation requires over 100 data attributes, including State of Health tracking over the battery's lifetime.
The ESPR timeline: when do you need a DPP?
DPPs will roll out in phases by product category. Key dates:
| Product Category | Regulation | DPP Required By |
|---|---|---|
| Industrial and EV batteries | EU Battery Regulation 2023/1542 | February 2027 |
| Construction products (steel, cement, insulation) | Construction Products Regulation 2024/3110 | Expected Q4 2027 |
| Textiles and footwear | ESPR delegated acts (in development) | Expected 2030 |
| Electronics and ICT | ESPR delegated acts (in development) | Expected 2030 |
| Furniture | ESPR delegated acts (in development) | Expected 2030-2032 |
The battery deadline is the most immediate. If you manufacture, import, or distribute batteries on the EU market, February 18, 2027 is non-negotiable.
Construction products are next. The revised CPR (2024/3110) includes provisions for digital documentation of environmental product declarations (EPDs) and material composition, the building blocks of a DPP.
Who is responsible for the DPP?
The "economic operator" placing the product on the EU market is responsible. This means:
- EU manufacturers: You create the DPP.
- Non-EU manufacturers selling directly into the EU: You create the DPP.
- Importers of non-EU products: You are responsible. If the manufacturer did not create a DPP, you must create one before the product clears customs.
- Distributors: You must verify the DPP exists and is accessible. You do not create it, but you cannot sell a product without one.
This is a common point of confusion. Many importers assume the manufacturer will handle DPP compliance. Legally, if the manufacturer has not provided a compliant DPP, the importer must.
How to prepare for DPP compliance
1. Register with GS1
DPPs require globally unique product identifiers. GS1 is the standard, specifically GS1 Digital Link URIs that encode product identity into scannable QR codes or NFC tags. Register your company with your national GS1 organization and obtain GTINs for your products.
2. Collect your product data
Start assembling the data you will need: material composition, supplier declarations, carbon footprint calculations, compliance documents. Most of this information exists somewhere in your organization. The challenge is structuring it.
For batteries: begin tracking carbon footprint by lifecycle stage (raw material extraction, manufacturing, transport) and collecting supply chain due diligence documentation.
For construction products: prepare Environmental Product Declarations (EPDs) per EN 15804+A2 if you have not already.
3. Choose a DPP system
You need software that can store your product data, generate standardized DPP records, link them to physical products via QR or NFC, and submit identifiers to the EU Central DPP Registry when it becomes operational.
Evaluate systems based on: support for your product category's data schema, GS1 Digital Link compliance, bulk passport generation capability, and API access for integration with your existing ERP.
4. Start with a pilot batch
Do not wait for the deadline. Generate DPPs for a single product line or production batch. This reveals data gaps, process issues, and supplier coordination challenges while there is still time to address them.
DPPs beyond the EU
While the EU is leading DPP regulation, other jurisdictions are watching. Indonesia is exploring sustainability disclosure frameworks through various regulatory bodies. Japan's Ministry of Economy is exploring digital traceability for battery supply chains. Companies that build DPP capability now will have an advantage as requirements spread.
Getting started
KALIRA generates Digital Product Passports for batteries, construction products, and industrial equipment. You enter your product data once, and KALIRA creates standardized, GS1-compliant passports in bulk, with QR codes ready to apply to your products.
Start generating Digital Product Passports with KALIRA. Free to start.
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