The EU Digital Product Passport: what manufacturers need to know in 2026
A Digital Product Passport (DPP) is a standardised digital record linked to a physical product through a QR code, RFID tag or data matrix. Under the EU Ecodesign for Sustainable Products Regulation (ESPR), it holds the product’s identity, environmental performance, material composition, circularity and traceability data. Unlike an EPD, it has to stay accurate for the product’s whole life and for at least ten years after.
There is no single DPP deadline. Each product group gets its own delegated act, and the compliance clock only starts once that act is published. The first fixed date is 18 February 2027, when battery passports become mandatory.
This page summarises our free guide for construction and industrial manufacturers. The full PDF, with the timeline table and the data checklist, is on the Resources page.
What is a Digital Product Passport?
An EPD is a static PDF, produced to ISO 14040/14044 or EN 15804 and updated every few years. A DPP is a live, machine-readable record. It doesn’t replace your EPD; it takes the EPD data and adds product identity, material traceability, performance declarations, circularity data and end-of-life instructions around it.
That means your existing LCA and EPD work feeds straight into the passport. What it doesn’t give you is the infrastructure around it: product-level identifiers, structured data, a link to the EU DPP Registry and someone responsible for keeping the record current.
What data does a DPP contain?
The ESPR sets out the same basic categories for every sector:
- Product identity: unique identifier, manufacturer, country of origin, batch or serial data
- Environmental performance: carbon footprint (GWP/PCF) per ISO 14067, or a full LCA per PEF, with more indicators added through delegated acts from 2030
- Material composition: list of materials, recycled content and substances of very high concern under REACH
- Circularity and end of life: recyclability, disassembly instructions, collection points, recycled content certification
- Repairability: repairability index where relevant, spare parts and service documents
- Traceability: supplier locations from tier 1 to tier 3, and chain-of-custody evidence for raw materials and key components
When do the deadlines apply?
The 2025–2030 ESPR Working Plan, adopted in April 2025, sets the order. After a delegated act is published, large companies typically get 18 to 24 months to comply, and SMEs a further 12 to 18 months.
- July 2024: ESPR enters into force
- July 2026: the EU DPP Registry goes live
- 2026: iron and steel delegated act, the first product-specific act (subject to final adoption)
- 18 February 2027: battery passport mandatory for EV, industrial (2 kWh and above) and light means of transport batteries
- 2027: textiles and aluminium delegated acts, with compliance expected around 2028/29
- 2028: furniture delegated act, enforcement expected around 2029/30
- 2028–2029: electronics and ICT delegated acts, enforcement expected around 2029/30
The 2025 Omnibus simplification package changed CSRD and CSDDD but left ESPR and the DPP untouched. Construction product manufacturers have a second track to watch: the revised Construction Products Regulation, (EU) 2024/3110, in force since January 2025, phases in DPP-style data requirements for priority construction products through 2032.
Do my existing EPDs count?
Yes, and they put you ahead. The GWP figure in your EPD maps directly to the environmental performance section of the passport. If you have EN 15804+A2 verified EPDs, the inventory behind them can also supply material composition, manufacturing location and waste stream data.
The gap is usually infrastructure, not data science. A passport needs a unique product identifier, a data carrier, registration in the EU DPP Registry and ongoing upkeep. The technical standards for this, including CEN/CENELEC work and GS1 Digital Link, are being finalised alongside the delegated acts.
Three decisions to make before your deadline
- Confirm your category deadline. Map your products against the ESPR Working Plan and the Battery Regulation. If you sell EV, industrial or LMT batteries in the EU, your deadline is February 2027, whatever your main industry. Construction product makers also need to follow the revised CPR. In textiles, steel or aluminium, start scoping now, before the exact requirements are out.
- Check your data readiness. Run a gap analysis against the categories above. LCA and EPD work covers part of the picture. The gaps are usually supplier visibility beyond tier 1, product serialisation and machine-readable identifiers, and, for batteries, state-of-health data. Analysts often put the lead time for building this infrastructure at 12 to 18 months.
- Choose your platform and data carrier. You’ll need to decide whether to build on your current LCA tools or use a dedicated DPP platform, how to collect data from several supplier tiers, and how to control access so that consumers, business customers and authorities each see the right data.
Manufacturers who treat the DPP as a data infrastructure project rather than a reporting task will be in a better position to use it with specifiers and procurement teams.
Download the full guide
The PDF includes the full timeline table, the data category overview and the three-step framework in more detail. Download it from the Resources page; enter your email address and it opens right away.
If you’d like help, we offer a DPP readiness audit and roadmap, EPD-to-DPP data mapping, and independent advice on EPD platforms and LCA tools. Every engagement starts with a short scoping call.