02.12.2025

Author: Mario Voge

FAQ EU Digital Product Passport (DPP)

Answering the six key questions

The EU's Ecodesign for Sustainable Products Regulation (ESPR) is ushering in a new era of product transparency, circularity, and accountability. At the center of this shift stands the Digital Product Passport (DPP). This digital record will become mandatory for product manufacturers and dealers in the European Union and accompany millions of products on the market. The new regulation raises questions for many organizations, and we have collected some of the most important ones to deliver a concise overview.

What exactly is the Digital Product Passport (DPP)?

The DPP is a digital record containing structured data about a product, including information on its components, materials, chemical substances, origin, repairability, and end-of-life options. It can be accessed digitally, for example, by scanning a QR code or RFID chip on a machine or product. For consumers and regulatory authorities, the DPP is a powerful tool for establishing liability and taking action against supply chain abuses, even when suppliers are located outside the EU. However, for manufacturers and distributors, this can present a significant challenge, as they are not held liable for the mistakes of their business partners.

When do companies need to comply?

Key milestones include:

ESPR entered into force: July 18, 2024

EU DPP registry launch: expected July 2026

First mandatory product group (batteries): February 18, 2027

Further delegated acts: expected 2026–2030 for textiles, tires, furniture, metals, and others. Industries will probably receive a transition period to comply after their delegated act is published. Given the experience of other regulations, this is usually between 12 and 18 months.

Who is affected and what is the liability exposure?

Approximately 1.1 million EU companies and 10 to 20 billion products will be impacted by the DPP in the coming years. This means that manufacturers and distributors of products subject to the regulation will be legally responsible for the accuracy and authenticity of DPP data, even when it originates from third-party sources, such as suppliers. This liability shift is one of the regulation's most significant implications.

Possible consequences include:

Fines up to 2% of a company's annual turnover

Exclusion from the EU market

Personal liability for responsible executives or employees

Loss of public procurement eligibility

What are the challenges concerning supplier data?

More than half of the information required for a Digital Product Passport typically originates from external suppliers. Yet, this data often arrives through paper-based exchanges, manual processes, inconsistent formats, and incompatible systems. These weaknesses not only introduce errors but also increase the risk of counterfeit or manipulated information, a risk heightened by increasingly realistic AI-generated content. As a result, manufacturers face substantial challenges in ensuring data accuracy straightforwardly and consistently.

How can companies achieve data accuracy and protect themselves from unjustified claims?

Manufacturers and trading companies can agree with their suppliers to use qualified electronic seals (qSeals). Issued by certified, audited trust service providers in accordance with the eIDAS Regulation, Seals are legally admissible in the EU and guarantee the integrity of electronic documents. Included timestamps ensure that all processes can be accurate, tamper-proof and ready to be traced during the future audits. They help companies:

Prove the authenticity and integrity of supplier data

Establish a tamper-proof audit trail

Transfer accountability to the data origin

Comply with ESPR Article 11(g) on data reliability

What can companies already do to prepare, and why is this advisable?

Companies should begin by mapping and analyzing their existing supply-chain data sources, updating supplier contracts to clarify accountability, and introducing electronic sealing alongside automated verification processes. They will also need to define a suitable DPP system strategy—whether to build or buy, and whether to choose a standalone or integrated solution—and ensure that PLM, ERP, and other lifecycle systems can connect to the forthcoming EU registry. Organizations that move early not only reduce future compliance risks but also gain tangible advantages, such as automated, scalable compliance processes, faster audits with fewer manual steps, improved data quality and supply-chain transparency, enhanced consumer trust through stronger sustainability credentials, and more effective collaboration with partners and regulators.

Learn more about the DPP and the EU ESPR regulation in our latest whitepaper, and delve deeper into creating frictionless, secure processes for product information management and DPP compliance.

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FAQ EU Digital Product Passport (DPP)

Answering the six key questions

What exactly is the Digital Product Passport (DPP)?

When do companies need to comply?

Who is affected and what is the liability exposure?

What are the challenges concerning supplier data?

How can companies achieve data accuracy and protect themselves from unjustified claims?

What can companies already do to prepare, and why is this advisable?

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