Digital Product Passports are coming - How prepared are you?

Digital product passports (DPPs) have been a hot topic for a while. The latest updates from EU confirm that Ecodesign driven product regulation will be carried out throughout the EU markets. DPP requires enhancements in product and business design as well as data management, IT systems and operational processes. The time to act is now.

Digital product Passport, or more familiarly called DPP, is part of the EU´s Ecodesign for Sustainable Products Regulation (ESPR). According to European Commissions working plan 2025-2030, the first impacted industries will be iron, steel, textiles, tyres, aluminium, furniture, mattresses, ICT and energy related products.

DPP is aimed at promoting circular economy, increasing transparency, improving supervision and supporting responsible choices by consumers, companies and organizations. In addition to reviewing your business models and product processes, DPP exposes a substantial need to enhance data availability throughout the whole product value chain.

Data requirements will be set progressively for key products placed on the EU market, and new product groups may be added under ESPR during the mid-term review in 2028.

DPP is a technological concept that compiles information from product´s life cycle related to sustainability, raw materials and safety. Required data points can be, for example, country of manufacture, batch /product ID, material and chemical composition, the amount of recycled material content or instructions for safe product use and end-life disposal.

The key ESPR requirements for product design include considering aspects such as durability and repairability, refurbishment, material and energy efficiency, recycling, end-of-life treatment as well as environmental impacts. The detailed product specific requirements and data points will be defined in the delegated acts.

Commission adopted the first ESRP working plan for 2025-2030 including an indicative list of targeted industries. The mid-term review for ESPR in 2028 will reassess whether to include previously excluded or new product groups.

Indicative timeline for adoption and impacted industries: ​

• Iron and Steel (2026)​
• Textiles/ Apparel (2027)​
• Tyres (2027)​
• Aluminium (2027)​
• Furniture (2028)​
• Mattresses (2029)​
• Energy related products (2026-2030)​

ICT products will be covered in the horizontal requirements (2027-2029), which introduce repairability scores and recyclability criteria for electrical and electronic products. 16 out of 35 energy-related products under Ecodesign Directive are already included in the 2025-2030 plan.

Product groups currently excluded from ESPR: detergents, paints, lubricants, footwear and chemicals.

Upcoming regulation calls for renewed thinking around product design and potential business models. A systematic approach concerning the whole product value chain should cover processes, IT systems as well as the operational model to manage the DPP data. Depending on your digital maturity and strategic aims, DPP will require investments in reporting capabilities, data analytics and means to enhance the data quality.

Additionally, new kinds of competences and practices are needed. Understanding your role in the DPP data ecosystem and shared added value with key partners is crucial. You should also start engaging and training your partners throughout the supply chain, to elevate data availability incrementally over time.

Implementing a Digital Product Passport is a strategic step toward compliance, transparency, and circularity. To ensure success, organizations should follow a structured approach from the outset.

1. Benchmark Against ESPR & Other Requirements

Compare relevant regulatory, industry and other stakeholder requirements with your current product data availability and business model

2. Document Current Digital Maturity

Evaluate and map your organization’s digital readiness including IT architecture, systems, processes, and reporting capabilities to define a realistic roadmap.

3. Define Business Requirements & Gap Analysis

Analyze gaps between current capabilities and DPP requirements and prioritize actions

4. Scope, Goals & Roadmap Creation

Identify short- and long-term goals for product and DPP data management

5. Develop a Business Capability & Data Catalogue

Map out your DPP data operating model and align it with your technology landscape.

6. Plan for Incremental Implementation

Start with PoC pilot projects and scale gradually while refining processes.

7. Engage Suppliers & Partners

Involve material/component suppliers and manufacturing partners early in the process.

Start by assembling a cross-functional team to define a joint DPP vision and understand your current state. To accelerate progress and ensure regulatory alignment, consider partnering with an experienced partner. Building the required technical and business capabilities, along with reporting skills and competencies, requires sustained effort and commitment.

We at adesso, can help you design a scalable roadmap, close capability gaps, and effectively integrate DPP solutions across your value chain. The earlier you begin, the better positioned you'll be to meet regulatory timelines and lead in sustainable innovation.

Read more about out adesso's DPP services: Digital Product Passport Services