Preparing for the DPP: What You Need to Know

These Regulations demonstrate a major shift in terms of how retailers generate, share and verify product information in the European market. Understanding how the ESPR and DPP requirements will impact retailers’ operations can help companies prepare now for compliance.

Why the DPP is being introduced in Europe

The Digital Product Passport (DPP) is a key component of the EU’s Circular Economy Action Plan and Green Deal, intended to make product information more transparent and actionable. By giving consumers, regulators and economic operators access to structured data on sustainability, safety and compliance, the DPP can support smarter decisions, longer product life cycles, easier repair and recycling, and stronger traceability across supply chains.

This focus on digital product information is also reflected in sector-specific legislation. For example, the proposed revision of the Toy Safety Regulation is expected to expand digital information requirements related to product safety and conformity.

DPP defined

Developed as a structured, machine-readable record, an EU DPP tracks a product through its life cycle, from raw materials to end of life. The DPP is accessible via a data carrier such as a QR code printed on or embedded in the product.

The relationship between DPP and data carriers

For retailers, it’s important to understand the difference between the DPP and the data carrier that connects users to it. The DPP is the structured digital record associated with a product, while the data carrier is the access point that makes that information available.

In practice, that access point may be a QR code, barcode, radio-frequency identification (RFID) tag or similar technology placed on the product, packaging or accompanying documentation. The European Commission’s implementing acts and related technical standards are expected to clarify the specific requirements. When scanned or read, the data carrier connects users to the DPP stored in a digital system.

Put simply, the data carrier is not the passport; it is the gateway to the passport. That distinction is important for retailers because, even if they are not responsible for managing all underlying data, they may still need to confirm that the data carrier is present, functional and accessible at the point of sale and throughout the product life cycle.

What information will the DPP include?

The DPP is expected to feature several categories of product information differentiated according to access rights – data for consumers, regulators, market surveillance, etc. Such information will include:

Product and operator identification – Unique identifiers (unique product/facility/operator identifier); model, batch or item references; and commodity codes

Information on chemical composition, including information on substances of concern to be tracked throughout the products’ life cycle 

Environmental performance and information – Carbon and water footprint, durability, repairability, recycled content, recyclability  

Compliance documentation – Conformity certificates, declarations of conformity, technical documentation 

Life cycle information – Maintenance, repair, reuse and recycling instructions; expected generation of waste

DPP registry and the role of DPP service providers

Another key element of the DPP ecosystem will be the DPP registry. Expected to operate as a system or network of systems, the registry will index DPPs through their unique identifiers and help make them accessible to authorized users. The European Commission will establish and maintain the registry. A public consultation on the registry implementing act has recently closed, with the final text expected soon.

The DPP framework also establishes the role of the DPP service provider. This independent third party, authorized by the economic operator placing a product on the EU market or putting it into service, processes DPP data so it can be made available to other economic operators and relevant actors with access rights under applicable legislation. A public consultation on this role was carried out in August 2025, and adoption of the final delegated act is expected soon.

Testing, inspection, and certification (TIC) providers are expected to play an important role in supporting a functional DPP ecosystem. Their support may include verifying the accuracy of product claims and technical data, linking verified compliance documentation to DPPs through certification and conformity assessment, strengthening supply chain resilience and serving as DPP service providers.

As trusted third parties, TIC companies can help retailers and manufacturers manage complex regulatory requirements while building confidence with regulators and consumers.

What is still to be defined for DPP

While the DPP framework is taking shape, several important details are still being finalized. These include standards and legislation covering data structures, IT architecture, access systems and the specific requirements that will apply to individual product categories.

Some sector-specific requirements are already emerging. Requirements for toys and batteries are available, while the draft delegated act for textiles is expected by the end of 2026.

What retailers can do now

While full details on DPP implementation have yet to be released, retailers can take steps to prepare such as:

Mapping product portfolios – Identify categories likely to be prioritized under ESPR, e.g., textiles, electronics, batteries  

Engaging suppliers – Assess current data availability and establish expectations for transparency and data sharing

Collaborating with partners – Support alignment on testing, certification and digital compliance requirements