The Digital Product Passport (DPP) is now active – a revolution in the European Single Market. How will our purchases change?

Translated by Martina Ravasi

Have you just read “passport”, and you came up with the Caribbean as your next holiday destination? Unfortunately, we won’t talk about that type of passport, but we’ll deal with DPPs, the Digital Product Passport introduced by the EU that will change our way of purchasing.

DPPs have been established according to ESPR – UE 2024/1781, the Ecodesign for Sustainable Products Regulation, which was voted by the European Parliament and came into force on July 18th, 2024. This guideline appeals to previous guidelines on the same issue to create a single and simplified new guideline on procedures for implementing transparency and environmental sustainability. These two values have been promoted over the last two years by the EU – most recently with the 2019 Green Deal.

What DPPs are?

It's a digital document – just like a normal passport – containing all information regarding a product. It can be updated with the passing of time, and it doesn't have an expiration date. DPPs will be necessary for European products as well as for imported ones. The information contained in DPPs can vary not only according to the typology of goods, but also to their relative guidelines. For instance, DPPs for electric batteries are stipulated by ESPR, and at the same time they must comply with their European guidelines about electric batteries (UE – 2023/0542).

However, regardless of their category, there are some indicators that are mandatory for all goods – such as their origin and composition in terms of raw materials. Moreover, their environmental performances as well as their circularity are compulsory to be added. The latter includes repairability indexes and guidelines for correct recycling.

How do DPPs work concretely?

Each DPP has a unique code once it has been registered in the DPPs European register, which has been active since last July 20th. Each good will have a QR code or an NFC tag on its label or packaging, and both can be scanned with a mobile phone. These data will give access to the status of the product as well as all real-time information about it. For instance, if we have to buy a spare battery for an electric bicycle, we can have access to all the information about the battery on its DPP simply by scanning its QR code. Therefore, people can make a more sustainable and conscious purchase. Moreover, if we need to fix the battery, the DPP will update and we can see the result of the fixing on the DPP.

Who is responsible for the information about products?

A DPP must be filled in, and the product must be registered in the European register. In this way, the product will be associated to a unique code, and it will be accessible to all economic operators launching on the market any product responding to its respective EU legislation. Who are economic operators? We refer to manufacturers, importers, authorized representatives, distributors, retailers, and fulfilment service providers. They're responsible not only for DPP accuracy, but also for their registration in the European register as well as for the application of QR codes and NFC tags on labels.

However, for economic operators, DPP is not only a legal obligation, but also an opportunity. Indeed, while improving transparency and traceability of products, they will be able to identify gaps in the supply chain and improve it, thereby increasing product quality and compliance. Moreover, if economic operators improve the efficiency of the supply chain, they can improve their market position and become more competitive.

Who are DPPs addressed to?

We may think that the Digital Product Platform is useful just for consumers, but the reality is different. Indeed, DPPs are addressed to recyclers, competent authorities and repairmen, who have to catch precious information on spare parts when it comes to fixing a product. On the contrary, authorities have to check and monitor the efficiency of the whole system and sanction violations.

DPPs will become the centralized tool used by authorities to counter illegal products and at the same time they will help to improve control systems not only in the country where goods circulate, but also across the EU. When we speak about “authorities”, we refer to competent national authorities, market surveillance authorities and customs authorities.

Which is the implementing plan?

We didn’t take the example of electric batteries randomly. This sector, combined with the steel and iron ones, will be the first to have their DPPs by 2026.

When the register of products comes into force, operators will have 18 to 24 months to comply with the law. Therefore, it’s necessary to register a DPP and put it on the European register. Once the unique code has been received, operators must print it on the product label through a QR code or NCF.

In 2027, textile products, tyres and aluminium will follow. In 2028, DPPs will be extended to furniture and in 2029 to mattresses. Lastly, in 2030, they will be compulsory for toys, mobile phones and tablets.

Some sectors – including food, pharmaceuticals, animal feed, plants, animals and cars – are currently excluded from DPPs, since there are already specific norms for them.

How will economic operators comply with this law and what do they risk if they don’t do so?

There is no denying that there will be a shift in market perspective following the introduction of DPPs, even though their introduction will be gradual not by chance.

For sure there will be something about supply chain platforms to be revised, but we don’t have to start from scratch. Indeed, the EU has had the GS1 standard and QR codes for years. They're reliable international standards allowing economic operators to add some information whenever they want without modifying the code printed on a packaging.

If economic operators don’t comply with DPPs norms or timeframes, their products will be excluded from the market. And the same goes for those products imported from outside the EU.

Potential administrative sanctions to adopt, as well as their timeframes and implementation modalities, are up to single member States.

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