With the European Commission now developing the delegated act that sets requirements for DPP service providers, manufacturers must prepare for strict rules on data accuracy, interoperability, security, and serialisation. This means manufacturers need to establish ways to centralise and manage sustainability data.
What Is the Digital Product Passport?
A Digital Product Passport is a structured, machine-readable data set, accessible via a data carrier (typically a QR code) applied directly to the product or its packaging. It replaces scattered spreadsheets, supplier PDFs, and disconnected documents with one verifiable, machine-readable source of truth.
The DPP will contain details such as:
- A unique product identifier (model, serial, batch)
- Materials and chemical composition
- Energy and environmental performance
- Instructions for repair, reuse, refurbishment, and recycling
- End-of-life management guidance
- Risk assessments and conformity documentation
- Contact details for responsible economic operators
- Traceability data across the supply chain
This aligns with requirements under GPSR, REACH, RoHS, and the wider circular economy framework.
Why Is the EU Strengthening DPP Rules Now?
Since ESPR entered into force in July 2024, the Commission has begun defining:
- Data formats
- Interoperability protocols
- Cybersecurity safeguards
- Mandatory fields for each product group
- Authentication checks by customs
- Harmonised standards for DPP implementation
- Requirements for registry integration (expected 2026)
This is necessary to prevent fragmented, incompatible passport systems across the Single Market. Now, the Commission has been preparing the next major step: detailed requirements for Digital Product Passport service providers.
A call for evidence is now open until 10 December 2024, inviting manufacturers, importers, industry groups, and technology providers to comment on proposed rules and a potential certification scheme. These rules will determine:
- Who can act as a DPP service provider
- How DPP data must be processed and secured
- What access rights apply to consumers, authorities, and supply chain actors
- How authenticity and interoperability will be guaranteed
- How customs authorities perform automatic checks
In short: the EU wants a robust, tamper-proof system that ensures consistency, security, and trust. For companies, choosing the right software to help manage their sustainability data will become crucial.
How the DPP Works Across the Product Lifecycle
The passport follows a product from design → production → placing on the market → use phase → end-of-life.
During that journey it enables:
Supply Chain Transparency
Manufacturers will need to map materials, components, and environmental impacts in a structured, machine-readable way. This means unified material declarations, bill of materials, and supplier-provided datasets.
Conformity and Safety Checks
Authorities can automatically verify compliance under ESPR and GPSR.
Circular Economy Enablement
Service providers, recyclers, repairers, and second-life operators gain insight into components, hazardous substances, spare parts, and disassembly instructions.
Customs Verification
Border authorities can automatically authenticate DPPs, preventing fraudulent entries and improving import controls.
What Will the Delegated Act Specify?
The delegated act will define detailed requirements for DPP service providers, including:
- Data standards and formats
- Security protocols and access management
- Obligations for data updates and version control
- Certification or accreditation schemes
- Interoperability with the EU’s central DPP registry (expected 2026)
This means that companies will need to ensure their data systems are built for this level of traceability, structure, or frequency of updates.
The Big Challenge: Data Readiness
Here is the reality: most manufacturers don’t have sustainability data in a structured, machine-readable, interoperable format. Most companies today rely on scattered supplier documents, ad-hoc LCAs, manual EPD processes, and static product reports.
The biggest bottlenecks include:
- inconsistent supplier documentation
- incompatible file formats
- missing component-level impacts
- multiple data silos
- outdated LCAs or EPDs
- lack of serialisation and identifier logic
- no system for automatic updates
A Digital Product Passport changes everything. Manufacturers will need to get these things in place:
- A unified sustainability data layer
- Traceable datasets linked to verified sources
- Clean, structured input from suppliers
- A system that can scale and update in real time
- Automated generation of environmental impacts
- Consistency across EPDs, LCAs, CSRD disclosures, and DPP content
Get Digital Product Passport Ready with EandoX
Most treat the DPP as a reporting requirement. It’s not. It’s a data transformation requirement.
Companies with chaotic, scattered sustainability data will struggle. Companies with a unified, connected, automated data layer will thrive.
The EandoX software is built to give you a connected, unified product data layer that mirrors the data structure required in the DPP.
A Data Architecture Built for the DPP
EandoX uses a connected, unified product data layer that mirrors the data structure required in the DPP:
- materials
- components
- sub-assemblies
- packaging
- factories
- transport
- impacts
This creates digital twinning-level clarity for every product.
AI That Converts Supplier Chaos into DPP-Ready Data
EandoX CoPilot extracts and structures data from supplier PDFs, technical sheets, and declarations — turning a major bottleneck into a scalable workflow.
Automatic Updates Across the Entire Product Catalogue
When a material changes, EandoX updates:
- EPDs
- LCAs
- CSRD data
- CBAM values
- AND the upcoming Digital Product Passport fields
Built for Regulatory Expansion
EandoX already aligns with EN 15804 and ISO 14040–44. The same structure will support ESPR product group rules as they are released.
Secure, Role-Based Access for Collaboration
Designed to support the same access control logic the Commission envisions for DPP service providers: suppliers, sustainability teams, and authorities each get the data they need.
Timeline: When Does Your Company Need to Act?
The DPP rolls out in phases:
- 2024: Pilot projects & preparatory rulemaking
- 2025: Delegated acts for product groups + service provider rules
- 2026: EU’s central DPP registry expected
- 2027–2030: Gradual expansion to high-impact product categories (textiles, electronics, batteries, furniture, construction products)
Many companies will need several years to clean, structure, and connect their data. Starting late means struggling to catch up.
What Manufacturers Should Do Now
To stay ahead of DPP requirements, you should:
- Map your technical documentation
- Implement serialisation and product identifiers
- Clean supplier data
- Build a structured product data model
- Ensure traceability and version control
- Prepare for interoperability and registry submission
- Participate in the Commission’s call for evidence
For most organisations, this isn’t a workflow tweak — it’s a structural shift. The Digital Product Passport demands a level of data quality, traceability, and interoperability that manual processes simply can’t support. But with the right system in place, the DPP becomes far more than a compliance obligation — it becomes a competitive advantage.
Stay Ahead of the DPP Curve with EandoX
EandoX gives manufacturers a connected sustainability data foundation built for the next regulatory decade. Are you ready to prepare your organisation for the Digital Product Passport?
See how a unified sustainability data foundation can help you stay compliant, competitive, and future-proof.
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