Digital Product Passport (DPP) is a structured digital identity record for products, components, and materials that provides access to relevant information throughout the product's entire life cycle. It links a physical product to its digital data through a data carrier such as a QR code, barcode, or another machine-readable identifier.
Depending on the applicable product-specific requirements, a DPP may contain information regarding material composition, environmental performance, durability, repairability, substances of concern, conformity documents, maintenance, and end-of-life management.
The Digital Product Passport is being implemented under the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781 and separate sector-specific EU legislation for product groups such as batteries and construction products.
As the requirements enter into force gradually through product-specific delegated acts, manufacturers must assess the obligations applicable to their product categories and establish a reliable system for collecting, managing, publishing, and updating product data.
Similar to environmental declarations such as the Environmental Product Declaration (EPD) and studies such as Life Cycle Assessment (LCA), the DPP also supports transparency, sustainability, circularity, and regulatory compliance.
However, the passport has a broader scope: it brings together identity, environmental performance, conformity, and life cycle data in a single interoperable digital record accessible to authorized stakeholders.
Since 2007, ERKE has been a trusted partner in Life Cycle Assessment (LCA), Environmental Product Declaration (EPD), product sustainability, carbon assessment, and environmental certification services.
With our offices in Istanbul, London, and Dubai and more than 210 completed sustainable product certification processes, we help manufacturers and international project teams confidently manage complex regulatory and environmental requirements.
ERKE's Digital Product Passport consultancy brings together regulatory assessment, environmental expertise, product data management, and supply chain coordination.
Our multidisciplinary team helps manufacturers identify the information required for their products, assess existing documentation, collect missing supplier data, and prepare a structured DPP implementation roadmap.
Our services are intended for both EU-based manufacturers and companies exporting products to the European market and cover the entire process, from the initial regulatory and data gap assessment to the preparation and publication of the digital passport and the management of life cycle data.
The Digital Product Passport preparation process is a coordinated effort involving regulatory analysis, product identification, technical documentation, environmental data, supply chain information, and digital data management.
At ERKE, we follow a structured approach consisting of five main stages:
Assessment of Product and Regulatory Scope: We review the applicable EU legislation, product category, delegated acts, and implementation timelines and confirm the appropriate DPP level for your product on a model, batch, or individual product basis.
DPP Data Gap Analysis: By comparing existing documents such as technical data sheets, declarations of conformity, EPDs, LCA studies, and material declarations with the expected DPP data requirements, we identify all missing, incomplete, or outdated areas.
Data Collection and Verification: We collect the required product and supply chain information from internal departments, production facilities, and suppliers; distinguish between publicly available, restricted, and confidential data; and check the completeness, consistency, and traceability of the information.
DPP Structure and Digital Integration: We organize the information in a structured and interoperable digital format, define unique identifiers, economic operator information, and access levels, and select the appropriate data carrier.
Publication, Registration, and Life Cycle Management: We prepare the passport for publication, register unique identifiers in the EU DPP Registry when required, and establish a governance procedure to ensure that the passport remains accurate and up to date throughout the product's life.
The exact content of a DPP is defined separately for each product group through the applicable delegated act or sector-specific legislation. Therefore, not every passport contains the same information.
Depending on the product category, a Digital Product Passport may contain the following information:
Product Identity and Traceability: Unique product identifier, model, batch or serial information, manufacturer and economic operator information, production facility, and supply chain traceability.
Materials and Composition: Materials, components, recycled content, critical raw materials, and substances of concern.
Environmental Performance: Verified data obtained from an Environmental Product Declaration, Life Cycle Assessment, Product Environmental Footprint study, or carbon footprint calculation.
Durability, Repairability, and Maintenance: Expected service life, maintenance requirements, spare parts, repair instructions, diagnostic information, and compatible tools.
Conformity Documents: Declarations of conformity, test reports, certificates, and safety information demonstrating compliance with applicable EU legislation.
End-of-Life and Circularity: Instructions for disassembly, reuse, refurbishment, remanufacturing, and the safe recycling of materials and components.
The European DPP framework combines centralized and decentralized elements.
While the EU DPP Registry operates as a centralized indexing system that stores unique identifiers associated with products, detailed product information is generally stored in a decentralized structure by the responsible economic operator or a specialist DPP service provider acting on its behalf.
Consumers, businesses, repair service providers, recycling organizations, customs authorities, and market surveillance authorities can access the information permitted for their respective stakeholder groups through the product's data carrier or the relevant digital interface.
This hybrid structure allows economic operators to manage their own product information while maintaining consistent access, interoperability, and regulatory oversight across the European Union.
Primary responsibility lies with the economic operator placing the product on the EU market. Depending on the structure of the supply chain, this person or organization may be the manufacturer, authorized representative, importer, or distributor.
The responsible operator must ensure;
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For imported products, the DPP must be ready before the product is released for free circulation in the European Union. Therefore, the obligation applies both to manufacturers in the EU and to manufacturers outside the EU whose products enter the European market.
There is currently no single date by which every product placed on the EU market must have a Digital Product Passport. Implementation enters into force gradually through product-specific delegated acts and sectoral legislation.
The inclusion of a product category in the ESPR Working Plan does not automatically make the DPP mandatory. It means that technical studies, an impact assessment, and stakeholder consultations will be carried out for that group before the final requirements and compliance dates are established.
The first ESPR Working Plan identifies the following product groups as priority areas:
Batteries and construction products follow their own sectoral legislation and implementation timelines.
Digital Product Passport consultancy helps manufacturers prepare for EU market requirements while improving product data management and sustainability communication.
Early preparation provides the following significant advantages:
Preparation for the EU Market: Early preparation helps manufacturers identify upcoming regulatory obligations and reduce the risk of delays when product-specific DPP requirements enter into force.
Strengthening Regulatory Compliance: A structured passport brings together product documentation, environmental information, certificates, and conformity records within a controlled digital framework.
Supply Chain Transparency: The DPP process encourages manufacturers to improve communication with suppliers and establish more reliable systems for collecting material, component, and production data.
Effective Product Data Management: Standardized and reusable digital information reduces repetitive documentation work and supports communication with authorities, customers, and distributors.
Supporting Circular Business Models: Repair, refurbishment, reuse, remanufacturing, and recycling activities are supported by providing authorized stakeholders with accurate technical and material information, reinforcing a stronger circular economy approach.
Integration with EPD and LCA Studies: Existing EPD, LCA, and product carbon footprint studies provide valuable environmental data for the DPP. However, additional information regarding regulatory requirements, technical matters, and the life cycle must also be provided.
Stronger Market Position: Transparent and verifiable information regarding environmental impact, durability, and material composition increases customer confidence and differentiates products in sustainability-focused markets.
A Digital Product Passport is a structured digital record that links a physical product to its life cycle information through a data carrier such as a QR code. It may contain data regarding identity, materials, environmental performance, conformity, durability, and end-of-life processes and makes this data accessible to authorized stakeholders throughout the value chain.
While an EPD reports the verified environmental impacts of a product based on a Life Cycle Assessment, the Digital Product Passport is a broader digital record. In addition to environmental data, the passport may also contain information regarding identity, conformity, repairability, and circularity. A verified EPD may provide part of the passport's environmental content; however, it does not replace the passport.
The first ESPR Working Plan identifies priority groups such as iron and steel, textiles, tyres, aluminium, furniture, mattresses, energy-related products, and information and communication technology products. Batteries and construction products follow their own sectoral legislation and timelines. The exact requirements and dates are determined by the delegated acts published for each group.
Yes. The obligation applies to all products placed on the EU market, regardless of where they are manufactured. For imported products, the passport must be ready before the product is released for free circulation in the EU. Therefore, manufacturers and exporters outside the EU must prepare the same product data as EU-based manufacturers.
Manufacturers in the UAE exporting to Europe are subject to the same DPP obligations as manufacturers in the EU. Through our Dubai office, ERKE helps UAE-based companies assess which requirements apply to them, close data gaps, and prepare compliant passports for their target EU markets.
Yes. Saudi manufacturers exporting products to the EU must prepare a Digital Product Passport for the relevant product categories. ERKE supports companies in Saudi Arabia by assessing regulatory scope, collecting supplier data, and creating a structured DPP roadmap for access to the European market.
Companies in the United Kingdom selling products to the EU market must meet the EU DPP requirements for the relevant product groups, independently of regulations in the United Kingdom. Through our London office, ERKE helps exporters in the United Kingdom align their product data with EU requirements and prepare their passports before their products enter free circulation.
A QR code is one of the accepted data carriers; however, it is not the passport itself. The legislation also permits other data carriers such as barcodes, RFID tags, and NFC chips. What matters is that the data carrier reliably links the physical product to its structured digital data through a unique identifier.
Yes. Verified EPD, LCA, and carbon footprint results are among the most valuable inputs for the environmental section of the passport. As this data has been verified by a third party, it generally requires less rework; however, additional information regarding regulatory requirements, the supply chain, and the life cycle is still required.
The Digital Product Passport must remain accurate and up to date for the period required for the product. The passport must be updated when the product, product documentation, or applicable requirements change. Clearly defining data ownership and the update procedure ensures that the passport remains reliable over time.
ERKE guides manufacturers throughout the entire process, from regulatory scope assessment and data gap analysis to data collection, digital structuring, publication, and life cycle management. With our offices in Istanbul, London, and Dubai and our experience in LCA, EPD, and product sustainability, we support both EU and non-EU manufacturers in completing their DPP preparations.
