UNIVERSAL DPP IMPLEMENTATION GUIDE (2026 Insights)

The Digital Product Passport (DPP) is no longer theoretical; it is rapidly becoming the mandatory key to accessing the EU market. For manufacturers, importers, and exporters, the complexity can feel overwhelming. Fluxy.One cuts through this complexity, offering the Simple, Instant, and Guaranteed solution you need. We use cutting-edge AI automation and the foundation of GS1 standards to ensure your products achieve compliance and zero fines.

For All Industries

Based on ESPR (EU 2024/1781), Battery Regulation (EU 2023/1542), CIRPASS-2 Recommendations (November 2025), and Official EU Sources

WHAT IS A DIGITAL PRODUCT PASSPORT (DPP)?

A Digital Product Passport is a digital container of information about a product's lifecycle, sustainability, compliance, and safety. It's accessed via a QR code and is increasingly mandatory under EU regulations.

Key Facts:

• Mandatory under ESPR (Ecodesign for Sustainable Products Regulation)
• Required for specific product categories
• Carried on or with the product
• Accessible to regulators, businesses, and consumers
• Data hosted by a certified DPP Operator

WHY DPP MATTERS TO YOUR BUSINESS

The key to success is moving past complexity and embracing a strategy that is Simple, Instant, and Affordable.

• EU Market Access: Without a DPP, your products will eventually be blocked at EU borders or removed from shelves once the relevant deadlines for your industry come into force (starting from 2027).
• Trust & Competition: Transparency builds customer confidence and differentiates your brand.
• Compliance: Showing good-faith effort protects you from fines and penalties, ensuring zero fines and guaranteed compliance.
• Data Intelligence: Your data becomes an asset for improving products and supply chains.

THE FIVE-STEP UNIVERSAL APPROACH

Regardless of your industry, DPP implementation follows the same five steps:

STEP 1: Understand Data Granularity (Before Collecting Anything)

STEP 2: Map Your Product Portfolio

STEP 3: Collect Product Data

STEP 4: Validate Data

STEP 5: Create the DPP, Generate Links & Publish

Let's walk through each step in detail.

STEP 1: UNDERSTAND DATA GRANULARITY

[H4] What is Data Granularity?

Granularity is the detail level at which you identify and track products. Think of it like deciding whether to track:

• Every single item produced
• Groups of identical items (batches/lots)
• Product types (models, variants)

Three Levels of Granularity (from simplest to most complex):

• MODEL-LEVEL (Simplest): You create ONE DPP per unique product variant. Identified by: GTIN (Global Trade Item Number). Best for: Finished goods with consistent data across production.
• BATCH/LOT-LEVEL (More Detail): You create ONE DPP per batch of identical products. Identified by: GTIN + Lot Number. Best for: Raw materials, components, products with batch-specific certifications.
• ITEM-LEVEL (Most Detail): You track EVERY SINGLE PRODUCT with a unique identifier. Identified by: GTIN + Serial Number or RFID. Status: Mandatory for Batteries (EV, LMT, Industrial >2kWh) under EU 2023/1542.

How to Choose Your Granularity Level

Ask yourself: What is your product type?

• Does your data change by batch?
• Do regulators need batch info?

IMPORTANT: Your granularity choice affects how many DPPs you need to create. Lower granularity = fewer DPPs = less work = simple setup. Start with model-level or batch-level based on your product, unless you are in the Battery sector where item-level is required.

STEP 2: MAP YOUR PRODUCT PORTFOLIO

Now that you understand granularity, list ALL products that will have DPPs.

What You Need to Count:

• Product Models/Variants: Count different sizes, colors, configurations, and materials (e.g., $2 \times 3 \times 4 = 24$ SKUs/Models needing DPPs).
• Batches/Lots (if batch-level granularity): Count annual or regular batch production for each model.
• Supply Chain Touchpoints: Identify who handles your products (Manufacturer, Importer, Exporter, Distributor).

Output: A simple spreadsheet with Product name, Model/variant, GTIN (if you have one), Annual volume, Batch frequency, and Current data availability (%).

Don't worry if GTINs are missing. You'll register them next.

STEP 3: COLLECT PRODUCT DATA

Now collect the data your DPP will contain. You need to make "good-faith effort."

What is "Good-Faith Effort"?

This applies primarily to sustainability and supply chain transparency data. You must: Request data from your suppliers, document your requests, compile what they provide, and clearly mark missing data as "pending" or "unknown". Mandatory compliance data (safety tests, REACH) MUST be present.

Essential Data Categories (Universal)

Regardless of your industry, a DPP must include:

• PRODUCT IDENTIFICATION: GTIN or product code, Manufacturer, Manufacturing date and place.
• COMPOSITION & MATERIALS: Material types and percentages, Hazardous substances, Recycled vs. virgin content.
• SUPPLY CHAIN BASICS: Supplier name and location, Production facilities, Key certifications.
• COMPLIANCE & SAFETY: Test certificates, Safety data sheets (SDS), Compliance declarations.
• ENVIRONMENTAL DATA (if available): Carbon footprint, Recyclability info.

INDUSTRY-SPECIFIC GUIDANCE

The five-step process applies to ALL industries. However, specific data requirements vary by product type.

• TEXTILES & APPAREL: Primary Data: Material composition, origin, certifications (Oeko-Tex, GOTS, etc.). Granularity: Model-level. Key Requirement: GTIN per SKU, supply chain transparency.
• ELECTRONICS: Primary Data: Material composition, hazardous substances, recycled content, repairability. Granularity: Model-level or batch-level. Key Requirement: REACH compliance, RoHS declarations.
• BATTERIES: Primary Data: Chemistry, capacity, safety certifications, end-of-life instructions. Granularity: Item-level (for EV/LMT/Industrial >2kWh). Key Requirement: Unique Identifier (Regulation EU 2023/1542).
• FURNITURE & BEDDING: Primary Data: Materials, dimensions, care instructions, sustainability metrics. Granularity: Model-level. Key Requirement: Fire safety certifications, chemical declarations.
• RAW MATERIALS & CHEMICALS: Primary Data: Composition, hazards, REACH registration, certificates. Granularity: Batch-level (critical - each batch may differ). Key Requirement: Safety data sheets (SDS), COA (Certificate of Analysis).
• TOYS & CHILDREN'S PRODUCTS: Primary Data: Safety certifications, age recommendations, chemical content. Granularity: Model-level. Key Requirement: EN/ISO standards.
• BUILDING MATERIALS: Primary Data: Technical specs, environmental declarations, emissions (VOC). Granularity: Model-level or batch-level. Key Requirement: CE marking, EPD.

Where to Find Data

Use what you already have:

• Internal Sources (Fastest): Your product specifications, Invoices, Manufacturing records.
• Supplier Sources (Request Directly): Raw material certificates, Material safety data sheets.

Priority: Use internal + supplier data 95% of the time. Using specialized software can dramatically speed up extraction and formatting of this data for compliance, which helps in achieving instant results. For more details on the technical aspects of the data structure, review our guide on DPP data requirements.

STEP 4: VALIDATE DATA

Before publishing, verify your data is complete and accurate.

Validation Checklist:

✔︎ Product Identification (All products have GTIN or unique code)

✔︎ Material Composition (Percentages add up to 100% or "unknown" marked)

✔︎ Supply Chain Transparency (At least direct supplier info provided)

✔︎ Compliance & Safety (Test certificates attached or referenced)

✔︎ Data Accuracy (Verify all links work, check numbers/dates)

✔︎ Missing Data Documented (All "unknown" fields clearly marked and attempts documented)

What if You Can't Complete Everything?

• For Sustainability/Supply Chain Fields: Documented good-faith effort shows transparency.
• For Mandatory Compliance Fields (Safety/Chemicals): These must be completed to legally sell the product.

Your DPP is compliant when it transparently reflects the reality of your data availability while meeting minimum safety standards, ensuring guaranteed compliance.

STEP 5: CREATE THE DPP, GENERATE LINKS & PUBLISH

Once data is validated, you're ready for the final step: creating the DPP and applying it to your products.

Here's the key point: under ESPR, the responsible economic operator (you, the manufacturer/importer) is legally accountable for the existence and content of the DPP.

For Each Product (at your chosen granularity level):

• Generate the Digital Product Passport & Links:
  Use your system (or DPP Operator) to create the unique digital passport from your validated data. This process automatically generates the viewer pages, the unique digital link, and the QR code. This ensures a simple setup.
• Apply Identifier to Product:
  
  • Format: Print the unique QR code on a label (preferred method) or use direct product marking.
  • Placement: Apply the identifier to the product label (most common), packaging, or user documentation.
• Ongoing Management:
  
  • Monitor usage (who's scanning).
  • Keep product information updated in the system.
  • Maintain all records for the required period ($10+$ years).

IMPORTANT: You cannot modify DPP data after it's published. If something needs correction, you must create a new version.

THE FLUXY.ONE SOLUTION: Your Trusted Partner

A DPP Operator is a certified, third-party company responsible for securely hosting your DPP data and ensuring regulatory compliance.

Important Distinction

The "responsible economic operator" (manufacturer or importer) is legally accountable for DPP existence, content accuracy, and registry upload. The DPP Operator is a service provider who hosts, secures, and maintains accessibility of the data.

TIMELINE FOR YOUR INDUSTRY

Different product categories have different mandatory implementation dates under ESPR.

Rather than listing specific dates here, we recommend checking Fluxy.One's blog for the most current industry timelines and regulatory updates.

COMMON QUESTIONS ANSWERED (FAQ)

Q: Do I need a GTIN for every product?

A: GTINs are the standard identifier for DPP. If you don't have GTINs registered with GS1 standards, you'll need to register them before publishing DPPs.

Q: What is a GS1 code or GTIN?

A: A GS1 code or GTIN (Global Trade Item Number) is a globally unique product identifier, typically the number encoded in a standard barcode. You obtain it by registering with your local GS1 standards organization. It is essential for identifying the product linked to the DPP.

Q: What if my supplier won't provide data?

A: Document your request. Mark that data as "pending" or "unknown" in your DPP. As long as you show good-faith effort, you are demonstrating transparency. Mandatory safety data cannot be skipped.

Q: Can I change DPP data after publishing?

A: No. DPP data is immutable once published. If corrections are needed, you must create a new version.

Q: What happens if I don't publish a DPP?

A: Your products may be: Blocked at EU customs, Removed from shelves, or Subject to fines. Publication is not optional—it ensures zero fines.

Q: How long must I keep DPP records?

A: You must maintain data accessibility for the expected lifetime of the product, often exceeding $10$ years.

KEY TAKEAWAYS

✔︎ DPP implementation follows the same 5-step process across all industries.

✔︎Start with understanding your data granularity level (model, batch, or item).

✔︎ Good-faith effort applies to transparency data—document your collection attempts.

✔︎ Use a certified DPP Operator for secure hosting and regulatory compliance to achieve a simple setup.

✔︎ Plan early—data collection takes longer than you think, but specialized tools can help.

✔︎ DPP is not just compliance—it's a competitive advantage.

✔︎ Start NOW, regardless of your deadline.

Ready to Move Beyond Theory?

The timeline for ESPR, DPP, and GPSR compliance is accelerating. Fluxy.One makes your compliance journey Simple, Instant, and Affordable. Let our AI automation and GS1 standards expertise handle the complexity. Stop reading regulations and start implementing.

Book a free consultation to see the Fluxy.One platform in action and secure your zero-fine guarantee.

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