Digital Product Passports: What Your Brand Needs to Know

The European Union is rolling out one of the most significant regulatory changes for product transparency and sustainability: Digital Product Passports (DPPs). If your brand sells products into the EU market, this regulation will impact how you do business, and the timeline is closer than you might think.
Here's what you need to know.
What is a Digital Product Passport?
A Digital Product Passport is essentially a digital identity card for products. Accessible via QR codes, barcodes, or electronic tags, it contains comprehensive lifecycle information including product origin, materials used, environmental impact, durability specifications, repair instructions, and end-of-life disposal recommendations.
The DPP is designed to close the transparency gap between what consumers, investors, and regulators demand and what's currently available. It provides accessible, verifiable data throughout a product's entire value chain.
What's Driving This?
The DPP initiative stems from the EU's Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, which entered into force in mid 2024. This regulation is a cornerstone of the European Green Deal and aims to make environmentally sustainable products the norm across the EU by 2050.
The regulation extends far beyond traditional energy efficiency concerns to encompass the entire product lifecycle - from material sourcing and manufacturing through to use and end-of-life management. The goal is to promote circularity, reduce resource dependency, and minimize environmental impact. Sounds amazing right? But it will require brands with already tight margins to invest time and resources into compliance (the difference now though is that this is not limited to “sustainable brands”).
Which Product Categories Are Impacted?
Nearly all physical goods placed on the EU market will eventually require DPPs, with limited exceptions for food, feed, medicines, and certain vehicles subject to sector-specific regulations.
The EU Commission published its first ESPR Working Plan 2025-2030 on April 16, 2025, identifying priority product groups based on environmental impact and improvement potential.
First wave priority products (2026-2029):
Textiles, particularly apparel (first requirements expected 2027)
Furniture, including mattresses (2028-2029)
Tyres (2027)
Household appliances (various timelines 2026-2028, continuation from previous regulations)
What about beauty, personal care, and home products?
Beauty and cosmetics: According to industry analysis from Mintel, cosmetics are currently seventh in line for DPP compliance, with implementation expected "by 2027 at the earliest or, more likely, 2030 at the latest." While the ESPR regulation mentions cosmetics as eventually requiring DPPs, they're not in the first wave.
Detergents and cleaning products: These were initially on the priority list but have been excluded from the first working plan. They're already governed by other product-specific sustainability legislation like the EU Detergent Regulation and were determined to have lower environmental impact and improvement potential than the selected priority products.
Home textiles (towels, linens, soft furnishings): Excluded from the first working plan due to "lower impacts and lower improvement potential" compared to apparel, plus distinct use of materials and supply chains.
Important note: A mid-term review in 2028 will allow the Commission to adjust priorities and potentially include additional product groups.
Which Brands Are Impacted?
The DPP applies to any product sold in the European market, regardless of where it's manufactured or where the company is headquartered.
If you sell products into the EU, you'll need to comply (whether you're based in Australia, the US, Asia, or anywhere else). The regulation covers manufacturers, importers, distributors, and any economic operator placing products on the EU market or putting them into service.
What's the Timeline?
The ESPR framework is already in force, but specific product requirements will be phased in through delegated acts. Here are the key dates:
July 18, 2024: ESPR entered into force
July 19, 2026: DPP registry becomes operational / Destruction ban on unsold apparel and footwear begins for major enterprises
2027: First wave of DPPs expected for textiles/apparel, tyres, and other priority categories
2028-2029: Second wave covering electronics, furniture
2030: Most high-impact product categories likely to be included
The first delegated acts with specific requirements are expected in 2026, with minimum 18-month transition periods before requirements become enforceable. So for apparel, the first requirements could apply from 2028.
What Could This Mean Going Forward?
The EU is setting a global precedent. As the world's largest single market, the EU's standards often become de facto global standards as international brands adapt their entire production lines to meet EU requirements rather than maintaining separate processes.
Beyond regulatory compliance, DPPs could fundamentally shift consumer expectations. Once shoppers in the EU can access detailed sustainability information via a simple QR code scan, similar transparency may become an expected norm in other markets.
Services Offering Support
Several companies are developing solutions to help brands comply with DPP requirements:
Avery Dennison's atma.io provides DPP as a Service (DPPaaS) with end-to-end deployment for fashion and other industries
Spherity's VERA offers industry-specific DPP solutions for textiles, tyres, and metals
Circularise specializes in traceability and compliance solutions across multiple sectors
PicoNext provides AI-powered DPP creation tools with cloud and blockchain publishing options
EZ Lab offers Digital Product Passport solutions specifically for cosmetics and personal care products
The key for brands is to start preparing. Even if your product category isn't in the first wave, companies need to begin mapping supply chains, documenting materials and processes, and developing the digital infrastructure to collect and share the required data.
I hope this was useful!
Joy
P.S. I’d be grateful if you shared this with other sustainable brand founders 🙏
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