What to Consider When Implementing the Digital Product Passport (DPP)

Rolling out the Digital Product Passport (DPP) imposes comprehensive technical, procedural, and legal requirements on companies across the entire value chain. The DPP is a key component of the Ecodesign for Sustainable Products Regulation (ESPR) and creates obligations for manufacturers, importers, retailers, distributors, and even DPP service providers.

Below are the central points companies must keep in mind when implementing the DPP:

1) General product and conformity requirements

The most fundamental requirement is that products may only be placed on the market or put into service if they meet the applicable ecodesign requirements and a Digital Product Passport is available.

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2) Specific requirements for the Digital Product Passport (DPP)

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The DPP has to meet certain core technical and functional conditions:

2.1 Data and technology

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• Data quality: The data in the DPP must be accurate, complete, and up to date.
• Data carrier: The DPP must be linked via a data carrier (e.g., QR code) to a permanent Unique Product Identifier (UPI). The carrier must be affixed to the product, its packaging, or accompanying documents.
• Standardisation and interoperability: All data must be based on open standards, created in an interoperable format, and be machine‑readable, structured, and searchable. End‑to‑end communication and data transfer must be fully interoperable with other DPPs.
• Data protection: Personal data of customers must not be stored in the DPP unless there is explicit consent.
• Availability: The DPP must remain available for the period set in the applicable DA, which must be at least the expected lifetime of the product.
• Data backup: The economic operator placing the product on the market must make a backup copy of the DPP available via an independent third‑party DPP service provider.
• Access control: Access to data must be governed by differentiated access rights, depending on whether the user is a customer, repairer, refurbisher, recycler, or an authority.
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2.2 Role of the importer

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Importers carry particular responsibility because they place products from third countries on the EU market. They are considered manufacturers if they place the product on the market under their own name or brand, or modify it in a way that affects conformity.

• Verification: Importers must ensure the manufacturer has performed the conformity assessment, prepared the technical documentation, and provided the DPP.
• Customs control: Importers must provide customs authorities with the product’s Unique Registration Identifier so that they can verify the existence and authenticity of the DPP.
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2.3 Role of the retailer and e‑commerce provider

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• Information duties: Retailers must ensure that customers and potential customers have easy access to the DPP, especially in distance selling (e‑commerce).
• Advertising material: Retailers must reference the information shown on the required labels in visual or technical advertising materials for a product.
• Online marketplaces: Providers of online marketplaces must work closely with market surveillance authorities and, on instruction, remove content relating to non‑compliant products.
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3) Preventing unfair practices

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Companies must refrain from practices aimed at circumventing ecodesign requirements or degrading product performance:

• Circumvention: Economic operators must not engage in contractual, business, or technical behaviour that undermines product conformity.
• Defeat devices / performance downgrading: Products may not be placed on the market if they are designed to alter behaviour or characteristics during testing to achieve a more favourable result (e.g., automatic performance adjustments).
• Obsolescence (premature ageing): Ecodesign requirements are intended to prevent products from becoming prematurely obsolete— for example, through design choices that make components less robust or through unavailable repair information or spare parts.
• Software updates: Software or firmware updates must not degrade product performance beyond an acceptable level unless the customer has given explicit consent. Under no circumstances may updates render the product non‑compliant with the originally applicable requirements.
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4) Handling unsold consumer products (ban on destruction)

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Companies must take measures to prevent the destruction of unsold consumer products.

• Transparency obligation (for large/medium‑sized companies): Economic operators (micro and small enterprises excluded; medium‑sized enterprises from 19 July 2030) must disclose annually:
  • The number and weight of unsold consumer products disposed of;
  • The reasons for disposal;
  • The share of products prepared for reuse, recycled, otherwise recovered, or disposed of (in line with the waste hierarchy);
  • Planned measures to avoid destruction.
• Ban (from 2026): From 19 July 2026, destroying unsold consumer products listed in Annex VII (including clothing, fashion accessories, and footwear) is prohibited.
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Sources & further reading

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