Digital Product Passport: Complete Guide for Manufacturers 2025–2026

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Article 01 / DPP

Digital Product Passport (DPP): A Complete Guide for Manufacturers in 2025-2026

The Digital Product Passport is becoming one of the most important EU regulatory obligations of the coming decade. This guide explains what the DPP is, who it applies to, what data it must contain, and how to prepare it in line with the Ecodesign for Sustainable Products Regulation (ESPR), step by step.

Based on a certified ISO 14067 methodology, TÜV Nord, and GS1 standards.

April 2025Reading time: approx. 12 minEU regulationsLCAEcodesign

Introduction

Imagine that every product on a store shelf has a built-in “digital identity card”: a set of verifiable data showing what the product is made of, what environmental footprint it has, how long it will last, and how it should be recycled. That is the core idea behind the Digital Product Passport (DPP).

This regulation, introduced under the Ecodesign for Sustainable Products Regulation (ESPR), is one of the foundations of the European Green Deal. For manufacturers and importers, it means more than a new compliance obligation. It is also a major opportunity: companies that prepare early can gain a competitive advantage, easier access to the EU market, and greater credibility with increasingly demanding B2B and B2C buyers.

In this guide, we explain everything you need to know about DPP: the legal basis, implementation timeline, required data, its connection with LCA and ISO 14067, and the practical process of creating a product passport.

1. What is a Digital Product Passport?

A Digital Product Passport (DPP) is a structured, digitally accessible set of data assigned to a specific product or product group. It contains environmental, material, and technical information that must remain available to consumers, regulators, recyclers, and supply chain participants throughout the product life cycle, from production to disposal.

A DPP is not just an eco-label or a PDF document. It is a dynamic digital record linked to a unique identifier, most commonly a QR code, RFID tag, or decentralized identifier (DID), and connected to the central European Union registry. The data can be updated throughout the product life cycle, for example when the material composition or production processes change.

Regulatory definition

Under Regulation (EU) 2024/1781, the Digital Product Passport is a set of product data compiled in accordance with the relevant delegated act and made available digitally through a data carrier. Each passport must have a unique product identifier linked to the EUDPP registry maintained by the European Commission.

Key features that distinguish the DPP from previous information requirements:

  1. Digital and machine-readable: data must be accessible through an API, not only readable by humans.
  2. Dynamic: updated throughout the product life cycle.
  3. Based on verified data: it requires an LCA methodology or a product carbon footprint compliant with ISO 14067.
  4. Connected to the EU registry: each DPP is linked to the European EUDPP system.
  5. Available to multiple stakeholders: different access levels for consumers, authorities, B2B partners, and recyclers.

2. Legal basis: the ESPR Regulation

The Digital Product Passport stems from Regulation (EU) 2024/1781 on ecodesign requirements for sustainable products, known as the Ecodesign for Sustainable Products Regulation (ESPR). It entered into force in July 2024 and replaced the previous Ecodesign Directive 2009/125/EC.

The ESPR has a much broader scope than the former directive. It covers virtually all categories of physical products placed on the EU market, not only selected energy-related product groups. Its main pillars are:

  1. Ecodesign requirements: durability, repairability, recyclability, and recycled material content.
  2. A ban on destroying unsold goods: especially clothing and electronics.
  3. The Digital Product Passport (DPP): mandatory for all covered product categories.
  4. Requirements for substances of very high concern (SVHC): mandatory disclosure of chemical composition.
Important

The ESPR is a regulation, not a directive. This means it applies directly in all EU Member States without requiring transposition into national law. Detailed requirements for individual product categories are set out in delegated acts adopted separately by the European Commission.

3. Implementation timeline by product category

DPP obligations will enter into force gradually, separately for each product category, after the relevant delegated act has been adopted. The table below shows the currently known implementation timeline:

Product category DPP date Status Key DPP requirements
Batteries and accumulators From 2027 Coming soon Carbon footprint, recycled content, performance, durability
Textiles and apparel From 2027 Coming soon Fibre composition, country of production, care instructions, recycling
Electronics and ICT 2027-2028 In preparation Repairability, spare parts, hazardous substances (RoHS), carbon footprint
Furniture and furnishings From 2028 Planned Wood origin (EUDR), material composition, durability
Construction materials 2028-2029 Planned Full LCA (EPD), SVHC, material composition, embodied energy
Chemicals and cleaning products From 2029 Planned Chemical composition, SVHC, environmental footprint (PEF), packaging
Steel, aluminium, plastics 2029-2031 Planned Recycled content, product carbon footprint (PCF), CBAM compliance
Timeline note

The dates are indicative and depend on the adoption of delegated acts by the European Commission. The Commission may adjust priorities during annual reviews of the ESPR Working Plan. We recommend monitoring official announcements on EUR-Lex and the EUDPP registry.

4. What data must a DPP contain?

The exact data scope depends on the product category and the relevant delegated act. However, the ESPR defines common information pillars that will be mandatory for all product passports. The key categories are:

🌍 Environmental footprint

Product carbon footprint (PCF) compliant with ISO 14067 or full LCA according to PEF. Results in kg CO₂e or extended environmental impact categories.

🧪 Material composition

List of materials and SVHC substances compliant with REACH. Percentage share of recycled materials.

♻️ End-of-life and circularity

Instructions for disassembly, sorting, and recycling. Collection points, recyclability certificates, and recycled content.

🔧 Repairability and durability

Repairability index, spare parts availability, service instructions, and warranty information.

📍 Product identification

Unique identifier (GTIN/EAN from the GS1 registry), model number, country of production, manufacturer or importer.

📜 Certificates and declarations

EPD, CE conformity certificates, performance test results, and verification links such as TÜV Nord.

Who has access to which DPP data?

The ESPR provides for differentiated access levels to the data stored in the passport:

  1. Consumers (public access): basic environmental information, care instructions, recycling, and repairability.
  2. B2B partners in the supply chain: full material composition, data for Scope 3 calculations, and certificates.
  3. Regulatory and customs authorities: full access, including SVHC data and REACH/CBAM compliance information.
  4. Recyclers and end-of-life operators: disassembly information, composition data, and hazardous substances.

5. Why is LCA the core of the DPP?

Of all the data required in the Digital Product Passport, life cycle assessment (LCA) and the resulting environmental footprint are the most difficult to prepare and, at the same time, the most important. LCA data answers the central question: what is the product’s actual environmental impact?

ISO 14067 standard

A product carbon footprint (PCF) calculated in accordance with ISO 14067:2018 is the minimum environmental requirement for most DPP categories. ISO 14067 is based on the LCA methodology defined in ISO 14044 and specifies the rules for calculating CO₂-equivalent emissions per functional unit of a product. The Envirly LCA platform is certified by TÜV Nord in accordance with ISO 14067.

LCA covers every stage of a product’s life cycle: raw material extraction, production, distribution, use, and disposal (cradle-to-grave). For DPP purposes, depending on the product category, either the full life cycle or a cradle-to-gate approach, up to the point when the product leaves the factory, may be required.

LCA environmental categories for DPP

A full LCA prepared for DPP may cover not only the carbon footprint (climate impact), but a broad set of environmental impact categories, depending on the selected methodology (PEF or ISO 14044):

  1. Climate change (kg CO₂e), always required
  2. Ozone layer depletion
  3. Acidification of soil and water
  4. Eutrophication of freshwater, marine, and terrestrial ecosystems
  5. Photochemical smog
  6. Water resource use
  7. Use of mineral and fossil resources
  8. Human toxicity, carcinogenic and non-carcinogenic
  9. Freshwater ecotoxicity
  10. Land use

6. Product identifier: GS1, GTIN, and QR code

Every Digital Product Passport must be linked to a unique and persistent product identifier accessible through a standard data carrier, most commonly a QR code (2D), RFID, or NFC.

GS1, the global organization for product identification standards, is a natural partner in the DPP ecosystem. The GTIN (Global Trade Item Number), known from EAN barcodes, is already widely used by manufacturers and retailers around the world. GS1 is developing extensions to the standard, including GS1 Digital Link, that allow a QR code to connect directly to DPP data.

Envirly as a trusted GS1 partner

The Envirly LCA platform is integrated with the GS1 system. During product identification, it can automatically retrieve data from the GS1 registry based on the GTIN/EAN number, including product name, manufacturer, GPC category, and country of origin. This shortens the time required to prepare DPP data and ensures that product identification is consistent with the global standard.

7. How to generate a DPP in 4 steps with Envirly LCA

Traditional preparation of data for a Digital Product Passport, involving external LCA consultants and manual data collection, can take several weeks to several months and cost tens of thousands of PLN for a single product.

The Envirly LCA by Quantifier platform shortens and automates this process by guiding the user through four stages:

1

Select the framework and purpose of the analysis

Choose the standard that matches your needs: ISO 14067 (PCF), PEF, EPD, DPP, or product-level Scope 3. The platform guides you through the choice of methodology and system boundaries, such as cradle-to-gate or cradle-to-grave.

2

Complete the product data

Import data through the GS1 integration, automatically retrieving identification data based on the GTIN; upload an Excel/CSV file with the BOM (Bill of Materials); or enter data manually. The platform maps materials to the ecoinvent database.

3

Complete the emissions flowchart

The life cycle flowchart visualizes every stage: raw materials → production → distribution → use → end of life. The platform identifies missing nodes and suggests emission factors. Scenario modelling and Monte Carlo simulation are also available.

4

Generate the product passport, report, or one-pager

The platform generates a full LCA report (PDF), a one-pager with key environmental results for market communication, and a Digital Product Passport with a QR code compliant with GS1 Digital Link, ready to share with consumers, B2B partners, and regulators.

Built-in ecoinvent database, no additional cost

Ecoinvent is the global standard database for LCA emission factors. A standard licence usually costs several thousand euros per year. Envirly LCA provides access to the ecoinvent database within the subscription, with no need to purchase a separate licence.

8. DPP vs EPD: what is the difference?

Two terms are often confused: DPP (Digital Product Passport) and EPD (Environmental Product Declaration). Here are the key differences:

Feature DPP EPD
Nature Dynamic digital record, updated throughout the product life cycle Static document (PDF), updated every 5 years
Legal basis Mandatory (ESPR 2024/1781) for covered categories Voluntary (ISO 14025) or required by the buyer
Access Digital, via API and QR code, with different access levels Public PDF document in an EPD programme database
Data scope Broad: environmental + material + technical + SVHC Environmental: LCA results according to PCR (Product Category Rules)
Relationship An EPD can be a source of environmental data feeding the DPP -

If your product requires both an EPD, for example for construction tenders, and a DPP under the ESPR, the good news is that the data prepared for the EPD is largely the same data that will feed the Digital Product Passport. Envirly LCA allows both documents to be prepared from a single LCA model.

9. How the DPP connects with Scope 3 and CSRD reporting

Data collected for the DPP has direct applications in corporate ESG reporting, especially in the context of Scope 3 under the GHG Protocol and obligations arising from the Corporate Sustainability Reporting Directive (CSRD).

  1. Scope 3, Category 1 (Purchased goods and services): the product carbon footprint (PCF) from the DPP provides a precise basis for calculating Scope 3 emissions at the buyer level, replacing inaccurate industry-average emission factors.
  2. Scope 3, Category 11 (Use of sold products): LCA data from the DPP covers the use phase, which is necessary for Category 11 calculations.
  3. CSRD, ESRS E1 (Climate change): the DPP provides data for product-level footprint disclosures required under ESRS E1.
  4. CBAM (Carbon Border Adjustment Mechanism): LCA data complements CBAM reporting obligations for steel, cement, aluminium, and fertilisers.
One analysis, multiple uses

The Envirly LCA platform is integrated with GHG (Scope 1-3) and CSRD modules. Data prepared for the DPP automatically feeds corporate reporting, without the need to collect the same information twice.

10. FAQ: the most common questions about the Digital Product Passport

What is a Digital Product Passport (DPP)?

A DPP is a structured, digitally accessible record of environmental, material, and technical data assigned to a specific product. It is required by Regulation (EU) 2024/1781, available through a QR code or RFID, and linked to the EUDPP registry. It includes the carbon footprint, material composition, and recycling information.

When does the DPP become mandatory in Poland and across the EU?

The first DPP obligations will apply to batteries in 2027, textiles and electronics in 2027-2028, and construction materials in 2028-2030. The dates depend on the adoption of delegated acts by the European Commission. As an EU regulation, the ESPR applies directly in Poland without requiring implementation into national law.

Does the DPP apply to importers from outside the EU?

Yes. Every entity placing products on the EU market must ensure that a DPP is available, regardless of where the product is manufactured. In practice, this means non-EU importers become responsible for collecting environmental data from their suppliers.

What is the difference between DPP and EPD?

An EPD (Environmental Product Declaration) is a static PDF document with LCA results, updated every 5 years, and either voluntary or required by the buyer. A DPP is a dynamic digital record, mandatory under the ESPR, covering a broader data scope: environmental, material, and technical information. An EPD can be one of the data sources feeding the DPP.

Does a small company need to prepare a DPP?

The DPP applies to all manufacturers and importers, regardless of company size. Longer transition periods and possible simplifications for SMEs may be provided in the detailed delegated acts. Ultimately, however, the obligation is expected to cover companies of every size.

Is the Envirly LCA platform certified to generate DPPs?

The Envirly LCA platform is certified by TÜV Nord in accordance with ISO 14067 and is a trusted GS1 partner. It generates product passports with GS1 Digital Link integration (QR code), supports EPD and PEF standards, and includes the built-in ecoinvent database to support compliance with ESPR methodology requirements.

How much does it cost to generate a DPP?

A traditional LCA performed by external consultants costs from PLN 8,000 to PLN 40,000 per product. Envirly LCA significantly reduces this cost through automated data collection, the built-in ecoinvent database, and the ability to reuse models for similar products.

How does the DPP connect with CSRD and Scope 3 obligations?

DPP data, especially the product carbon footprint (PCF), is a key source for calculating Scope 3 Category 1 emissions (purchased goods) and Category 11 emissions (use of sold products) required under CSRD reporting according to ESRS E1.

Prepare your Digital Product Passport today

Envirly LCA guides you through the entire process in four steps, from selecting the right framework to generating a ready-to-use DPP with a QR code. The built-in ecoinvent database, GS1 integration, and TÜV Nord certification help ensure compliance with ESPR requirements.

Book a free demo →

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