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Digital Product Passport: Companies should be aware of these EU requirements

EU regulations are changing.
Digital product passport is available.

Thomas Rödding spricht auf einer Konferenz, 'European Standardization Organization' und 'CEN-CLC JTC 24' sind zu sehen, 'Digital Product F'

Digital Product Passport:
2030 is not a goal. It's a deadline.

Introduction will be carried out sector by sector for all companies,
the products are traded in the EU.

The Digital Product Passport (DPP) is not recommended – it has been mandatory since July 2024. The DPP is enshrined in law in:

  • Ecodesign Regulation (ESPR)

  • EU Green Deal

  • Circular Economy Action Plan (CEAP)

  • Already defined (partly final) regulations:

    • EU Strategy for Sustainable Textiles

    • EU Battery Regulation

    • All others follow


The ESPR is the EU law that introduces and specifically defines the Digital Product Passport.

What makes the EU Ecodesign Regulation (ESPR) so important
and what exactly does it regulate?

The Ecodesign Regulation (Ecodesign for Sustainable Products Regulation – 2024/1781) is an EU-wide directive that focuses on sustainable product development and makes the DPP mandatory for the first time. While the Green Deal and CEAP provide policy frameworks and strategies, the ESPR is the legally binding regulation that precisely regulates:

  • Which products must receive a Digital Product Passport

  • What this passport must contain (e.g. data on materials, repairability, CO₂, recycling, etc.)

  • How access is achieved (e.g. via QR code or NFC)

  • And when the DPP will take effect in each sector (rollout plan)


Goal: Products should become more durable, repairable and recyclable.

Means:

Products must receive a digital file with all relevant information.

Specific data sets are prescribed that must be included in the Digital Product Passport.

Traceability of materials and CO₂ footprint becomes mandatory.

Digital Product Passport – an independent, legally binding instrument with many advantages:

Reduction & Optimization

The Digital Product Passport reduces manual effort and optimizes product lifecycle management – all the way to completely new customer insights.

Transparency &
Data control

The Digital Product Passport ensures significantly more traceable supply chain transparency and data control - and even makes this possible in the first place.

New Customer
Insights

The Digital Product Passport enables a new form of customer interaction and data-driven services.

Data management
4.0

The Digital Product Passport builds an interoperable, standardized data infrastructure for companies.

Digital product passport and reporting obligations:
Why one has nothing to do with the other

Digital tools such as the DPP do not replace reporting obligations, but rather enable efficient, sustainable business models.

The Digital Product Passport is not just another reporting tool, but a digital data management tool that offers companies tangible benefits.

The Digital Product Passport is not a reporting requirement. Rather, it is a transparency and control tool.

The EU’s recent OMNIBUS proposal also only concerns these reporting obligations, not the DPP.

These EU regulations do not affect the Digital Product Passport:

  • CSRD / CS3D / ESRS: Sustainability reporting at company level

  • EU Taxonomy: Classification of Sustainable Economic Activities: LkSG Supply Chain Due Diligence Obligations at Company Level

  • ESG Reporting / ESRS: Strategic Sustainability Indicators Supply Chain Transparency Initiatives

Deep Dive: Digital Product Passport vs. Supply Chain Act

The Digital Product Passport and the Supply Chain Act (LkSG) are often confused, but they have completely different objectives. While the DPP focuses on product transparency, the circular economy, and sustainability, the LkSG regulates social and human rights due diligence obligations along the supply chain.

  • The DPP is a digital data tool that provides transparency about a product's materials, repair options, recyclability, and environmental impact. Its goal is to promote sustainable product development and the circular economy.

  • The LkSG obliges companies to identify risks of human rights violations and environmental offences in their global supply chains and to take countermeasures. The focus is on labour conditions, environmental pollution and ethical responsibility.

The most important differences:

  • The DPP concerns the product itself, the LkSG concerns the entire supply chain.

  • The DPP promotes transparency about materials, repair and recycling, and the LkSG regulates social responsibility in procurement.

  • The DPP is part of the EU Ecodesign Regulation (ESPR), the LkSG is an independent regulation.

In short:

  • The DPP is a product-specific transparency solution for sustainable products.

  • The LkSG ensures ethical responsibility in the supply chain.

  • Both sets of rules complement each other but are not directly related.

Deep Dive & Update: Why the Digital Product Passport has a lot to do with the EU Packaging Regulation (PPWR)

It used to be said that the DPP had nothing to do with the Packaging Ordinance (PPWR) – this is no longer true.

In short:

 

Packaging does not automatically belong in the DPP, but depending on the product and requirements, a DPP obligation may also arise for packaging.

More on the current EU Packaging Regulation:

Blick aus dem Weltraum auf die Erde, mit einem deutlich sichtbaren Teil Südamerikas im Vordergrund, dem tiefblauen Atlantik und teils bewölktem Himmel.

2030 is still a long way off? No way.
Now is the time to act.
Why, tells you:

Klein Jens Herzog.jpg

Jens Herzog

Senior Sales Executive

Telephone: +49 (0)151 64 31 27 37

Email: jens.herzog@narravero.com

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