The Digital Product Passport (DPP) for Economic Operators

For economic operators, the DPP is not only a legal obligation but also a real business opportunity. By improving transparency and traceability, it can support better supply chain performance, strengthen market position, increase efficiency, quality and compliance, unlock new opportunities in the circular economy and for green products, and help digitalise data exchange between companies, while harmonising practices for scaling digital solutions.

As DPP requirements are introduced progressively across different product groups, economic operators should begin preparing for upcoming obligations, understand the applicable requirements for their sector and follow the latest legislative developments. Following the adoption of Ecodesign Regulation (ESPR) delegated acts, economic operators will have a transition period of at least 18 months.

The first ESPR Working Plan sets out priority product categories with the following indicative timeline:  

• 2026 – Iron and steel 
• 2026 – 2029 – Energy-related products  
• 2027 – Textiles, tyres, and aluminium  
• 2028 – Furniture  
• 2029 – Mattresses and ICT products 

Specific DPP requirements for a product can also be defined through separate, standalone EU legislation, including the Batteries Regulation, Packaging and Packaging Waste Regulation (PPWR), European Critical Raw Materials Act, Toys Safety Regulation, Construction Products Regulation and Detergents & Surfactants Regulation). 

Who needs a DPP?

DPP obligations apply to all economic operators placing products within the scope of relevant EU legislation on the Union market, whether manufactured domestically or imported.

When products are placed in the EU market through distance selling, online marketplaces will need to make DPPs accessible.

Depending on the product group and applicable legislation, this may include:

• Manufacturers;
• Importers;
• Authorised representatives;
• Distributors;
• Dealers;
• Fulfilment service providers. 

What are my responsibilities?

The primary responsibility for the DPP's creation and accuracy rests with the economic operators placing the product on the EU market. 

Responsibilities include: 

• Data compilation: The economic operators must provide product data digitally, in accordance with the data structure and obligations set out in the relevant legislation. This information forms the content of the DPP. The economic operators must also ensure that a physical data carrier is attached to the product, its packaging, or on the documentation accompanying the product (as determined by the product specific legislation).
• Registration: The DPP must be registered in the EU DPP Registry in line with the relevant technical specifications and legal requirements. This registration is mandatory for placing the product on the Single Market. For imported products, DPP registration may also be relevant for customs clearance and release for free circulation.
• Lifecycle management: Economic operators must ensure that DPP information remains accurate throughout the product's lifecycle. The exact information requirements will depend on the product group and applicable legal framework.