EU electronics manufacturers face strict new rules under the ESPR. This guide shows how to create compliant Digital Product Passports (DPPs) using GS1 Digital Link, EPREL, and other standards. Learn how to structure product data, assign unique identifiers, and stay ahead of the 2026 deadline.
Did you know that DPPs are set to revolutionize product traceability across the European Union, with 48% of manufacturers still unprepared for implementation?
The clock is ticking for European electronics manufacturers facing mandatory Digital Product Passport requirements. Unlike traditional documentation, these digital identifiers will track products throughout their entire lifecycle, creating unprecedented transparency from production to recycling. Systems like GS1 Digital Link, TCO Certified, and EPREL already demonstrate the potential of this approach, while solutions such as Fluxy.One offer implementation pathways for companies starting their compliance journey.
However, many manufacturers struggle with the technical specifications, data requirements, and security protocols needed for effective DPP deployment. The challenge isn't simply about compliance – it's about transforming your entire approach to product information management.
This practical guide breaks down the essential steps to implement Digital Product Passports in your manufacturing operation. From understanding the legal framework to building the necessary technical infrastructure, we'll walk you through the process of preparing your business for this significant shift in EU product regulations.
Compliance doesn’t have to be painful. Just send us your existing product docs — and Fluxy.One will generate a fully ESPR-ready Digital Product Passport in minutes. With GS1 Digital Link, EPREL integration, and TCO-ready formatting — zero code, zero stress. Book your free consultation today
Digital Product Passports (DPPs) represent a fundamental shift in how product information is tracked and shared throughout supply chains. First of all, let's explore what these digital tools are and why they're becoming central to EU manufacturing requirements.
A Digital Product Passport is a structured collection of product-related data with pre-defined scope and agreed data management and access rights, conveyed through a unique identifier and accessible via electronic means through a data carrier. In essence, DPPs function as comprehensive digital records containing detailed information about a product's entire value chain, from materials used to disposal recommendations.
Each DPP includes:
This digital passport will typically be attached to products through QR codes, NFC chips, or RFID tags, linking to cloud-hosted information that complies with global traceability standards.
The European Union is introducing DPPs as part of the Ecodesign for Sustainable Products Regulation (ESPR), which came into force on July 18th, 2024. This regulation aims to make sustainable products the norm in the EU market while reducing their environmental and climate impact.
Starting in 2024, the EU will implement regulations requiring nearly all products sold in the EU to feature a Digital Product Passport. This broad implementation is expected to unfold gradually, with DPPs becoming mandatory for various products between 2026 and 2030 across all 27 EU member countries.
The EU Commission will manage a public web portal enabling consumers to search for and compare sustainability information provided in product passports. Additionally, the DPP will serve as a tool to close the gap between transparency demanded by consumers, investors, and other stakeholders and the current lack of reliable data on product journeys.
Digital Product Passports are specifically designed to be a core instrument for building a circular economy, which is itself a key enabler of climate neutrality. The intended scope of DPPs primarily focuses on information related to sustainability, circularity, and value retention for re-use, remanufacturing, and recycling.
DPPs contribute to circular economy goals by:
Furthermore, DPPs enable all stakeholders to gain a deeper understanding of materials used in products and their associated environmental impacts. This improved access to data allows more businesses to implement service and repair-based business models, creating additional value through circular approaches.
Research has identified seven key data clusters within DPPs: usage and maintenance, product identification, products and materials, guidelines and manuals, supply chain and reverse logistics, environmental data, and compliance. Through these data points, DPPs will fundamentally transform how products are designed, used, and eventually recycled across industries.
The European Union's regulatory framework for DPPs demands manufacturers' immediate attention. The legal landscape for Digital Product Passports is complex but navigating it properly now will save significant headaches later.
The Ecodesign for Sustainable Products Regulation (ESPR) came into force on July 18, 2024, replacing the older Ecodesign Directive 2009/125/EC. This regulation represents the cornerstone of the EU Commission's approach to creating more environmentally sustainable and circular products.
The ESPR significantly expands the scope of ecodesign requirements in two crucial ways. First, it extends beyond energy-related products to cover virtually all physical goods. Second, it reinforces the range of requirements that can be set for products, including durability, circularity, and overall environmental footprint reduction.
As part of the 2020 Circular Economy Action Plan, the ESPR aims to contribute to helping the EU reach its environmental goals, double its circularity rate of material use, and achieve energy efficiency targets by 2030. The regulation enables setting performance and information rules for almost all categories of physical goods to improve their sustainability characteristics.
The ESPR applies to almost all physical goods placed on the EU market, regardless of whether they are produced inside or outside the EU. According to the regulation, the first working plan will prioritize products with high environmental impact and potential for sustainability improvements .
These priority product categories include:
Notably, certain exemptions apply. Food and feed, medicinal products, veterinary products, living plants and animals, products of human origin, and certain vehicles covered under sector-specific EU legislative acts are excluded from the ESPR's scope.
Manufacturers must prepare for a phased rollout of the ESPR requirements over the coming years:
Some product groups face even earlier deadlines. For example, industrial and electric vehicle batteries must be equipped with a Battery Passport by February 18, 2027.
In parallel, the European Commission will launch a public web portal where consumers and stakeholders can search for and compare product sustainability information provided via DPPs.
It is essential to understand that DPP compliance requirements extend across the entire value chain. That includes not only manufacturers, but also importers, distributors, and retailers — all of whom must ensure that DPPs are accessible by the relevant deadlines.
Ultimately, the ESPR establishes mandatory design and data standards for sustainable products, redefining the baseline for doing business in the EU.
Preparing comprehensive product data forms the foundation of successful DPP implementation. This critical step requires thorough planning and systematic organization before any technical infrastructure development begins.
Successful DPP implementation starts with a thorough audit of your product data. First, identify gaps in current product, materials, and sustainability information, then determine where this data currently resides—whether in ERP systems, supplier databases, or spreadsheets. Though specific data requirements will vary by product category and will be established through industry-wide stakeholder consultation, certain fundamental elements must be included:
The ESPR mandates that all information in the DPP must be written in an open, standard, interoperable format that is machine-readable, structured, and searchable. This approach ensures consistency across products and enables automated processing by various stakeholders.
Consequently, you'll need to implement standardization across your data management systems. This might involve converting existing documentation into structured formats or adopting new systems capable of producing DPP-compatible data. Moreover, all product information must be based on open standards to maintain interoperability across platforms and stakeholders.
Each DPP must connect to a unique product identifier through a data carrier such as a QR code. This identifier must be physically present on the product, packaging, or product documentation and comply with the ISO/IEC 15459:2015 standard.
GS1 standards align perfectly with these requirements, as they have long partnered with ISO to ensure compliance. The data model established for digital links allows manufacturers to add granular information about the product using qualifiers and attributes, enabling representation at the model, batch, lot, or individual item level.
Access to DPP information must be regulated according to the essential requirements in Article 9 of the ESPR. This means establishing differentiated access rights for various stakeholders based on their legitimate needs:
Simultaneously, you must protect proprietary data while maintaining transparency. The DPP system should distinguish between public and restricted data, with appropriate access controls implementing the "need-to-know" principle.
By methodically addressing these four key areas, European manufacturers can build a robust foundation for their DPP implementation strategy before moving on to technical infrastructure development.
Building the right technical infrastructure forms the backbone of any successful DPP implementation. Once your product data is properly structured, your focus must shift toward creating systems that can reliably store, transmit, and display this information.
When designing your DPP infrastructure, your first decision concerns how data will be stored and accessed. Two primary approaches exist:
For many manufacturers, a decentralized approach offers superior protection for proprietary information through zero-knowledge proofs, allowing you to substantiate claims without revealing sensitive product data. This technology enables verification of compliance without exposing underlying technical details that might compromise trade secrets.
Successful DPP implementation requires seamless integration with your existing enterprise systems. Mapping your information sources provides a crucial 360-degree view of your supply chain and system interoperability. This mapping helps connect people and systems while defining DPP responsibilities throughout your organization.
During integration planning, determine where product master data currently resides, identify it, and cleanse it. This prevents the same data from being maintained in multiple systems simultaneously. The optimal approach connects PLM data (design specifications) with ERP systems (production planning) without duplicating work across platforms.
Selecting appropriate data carriers is essential for connecting physical products to their digital information. Your options include:
QR codes represent the most cost-effective solution, as they can be scanned by standard smartphone cameras and dynamically updated after printing. Furthermore, dynamic, serialized QR codes enable product identification down to individual units.
Alternatively, RFID tags offer automated tracking capabilities that function without direct line-of-sight. RFID-tagged products generate read events at scanning points, which synchronize with backend systems like EPCIS (Electronic Product Code Information Services). This creates complete visibility of a product's journey from factory to consumer.
For optimal consumer engagement, consider combining RFID with QR codes – RFID for supply chain tracking and QR codes for consumer-facing information access.
Interoperability across technical, semantic, legal, and organizational dimensions enables diverse stakeholders to understand and reuse data consistently. The emerging DPP ecosystem requires a standardized data schema to prevent compatibility problems between platforms and technological solutions.
To achieve this interoperability, your DPP infrastructure must:
Implementing these interoperability standards allows your DPP system to exchange information reliably with EU data spaces, ensuring your products remain compliant with evolving regulatory requirements.
Security concerns often become the biggest hurdle in DPP implementation. For European electronics manufacturers, balancing transparency requirements with protecting sensitive business information remains a critical challenge throughout the DPP lifecycle.
Safeguarding intellectual property requires sophisticated encryption approaches. Data security is essential for protecting trade secrets when creating digital product passports. Companies can implement centralized or decentralized storage combined with encryption techniques to protect their proprietary information. For maximum protection:
The ESPR categorizes data stored within DPPs as either public or private, with the European Commission defining permissions to access, modify, or update information.
Zero-knowledge proofs (ZKPs) represent a breakthrough for manufacturers needing to verify regulatory compliance without exposing sensitive details. This technology allows businesses to substantiate green claims without sharing proprietary information—even in encrypted form.
In practice, ZKPs enable one party to prove to another that a statement is true without revealing specific information about the statement itself. For instance, a manufacturer can prove their product meets sustainability requirements without disclosing exact material compositions or manufacturing processes that might reveal trade secrets.
Implementing immutable record-keeping is fundamental for compliance verification. Blockchain technology creates a secure, transparent, and unchangeable record of a product's journey from production to end consumer. Each transaction is verified by network participants, and once added to the blockchain, it cannot be altered.
This immutability ensures all transactions and related documents are securely recorded, providing non-repudiation of digital transactions and secure data sharing across borders.
Prior to implementation, thoroughly evaluate your DPP solution against regulatory requirements. The World Business Council for Sustainable Development offers a Readiness Assessment Tool developed in collaboration with ERM. This tool allows companies to:
Ongoing testing is crucial as regulations evolve and new product categories come under DPP requirements.
Digital Product Passports represent a significant shift for European manufacturers, fundamentally changing how product information is managed throughout entire lifecycles. Preparation for this regulatory change requires comprehensive understanding of the ESPR framework, thorough product data organization, robust technical infrastructure, and stringent security measures.
Companies that start their DPP implementation process early will gain substantial advantages. First and foremost, early adopters can avoid the rush when mandatory deadlines approach between 2026 and 2030. Additionally, manufacturers who embrace this transition can transform compliance requirements into competitive advantages through improved sustainability metrics and enhanced consumer transparency.
The technical aspects of DPP implementation certainly present challenges. Nevertheless, solutions exist through proper data structuring, appropriate identification systems, and security protocols that protect proprietary information while meeting regulatory requirements. Manufacturers must balance transparency with trade secret protection using technologies like zero-knowledge proofs and sophisticated encryption.
Remember that DPPs serve multiple purposes beyond regulatory compliance. These digital tools support circular economy principles, empower consumers with better product information, and create opportunities for new business models based on repair and reuse.
Time remains your most valuable asset in this transition. Manufacturers should begin identifying required data fields, structuring their information, and evaluating technical solutions now rather than waiting for enforcement deadlines. The manufacturers who view DPPs as strategic investments rather than regulatory burdens will undoubtedly position themselves advantageously in the evolving European market.
Still figuring it out? Don’t. With Fluxy.One, you upload the docs — we do the rest. Fully compliant DPPs, instantly translated, linked to GS1 + EPREL, and ready to deploy. No IT department required.
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A Digital Product Passport is a machine-readable product profile that includes information on composition, origin, sustainability indicators, repair instructions, and end-of-life handling. Mandated by the ESPR regulation, DPPs are essential tools for transparency, sustainability, and EU regulatory compliance.
Your DPP must contain:
Electronics, batteries, and industrial equipment are among the first affected sectors.
You will need:
We convert your existing documentation into fully EU-compliant Digital Product Passports — multilingual, GS1-ready, and validated — in minutes. No IT team required. Our platform supports automated validation, GS1 Digital Link generation, and EPREL export.
Our passports are fully aligned with:
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