| Digital Product Passports

EU Digital Product Passports: A business guide

Authored by

Aimee Campanella

Development Director - Textiles EPR

Reconomy

Last updated: 27 February 2026 at 2:40 pm - 11 min read

The EU’s Digital Product Passports (DPPs) are set to transform how products are designed, tracked, and managed across EU businesses’ supply chains.

Under the Ecodesign for Sustainable Products Regulation (ESPR), DPPs are seen to underpin how sustainability, durability, repairability, and end-of-life obligations are implemented and enforced.

In this blog, we look at what EU businesses need to know about Digital Product Passports, what is coming next, and how to prepare.

Infographic showing a Digital Product Passport on a smartphone with key data types including traceability, sustainability, and compliance.

What are EU Digital Product Passports?

EU Digital Product Passports are digital records that hold standardised information about a business’s products placed on the EU market.

It is best understood not as a static document, but as a digital container that:

  • Is linked to a physical product via a data carrier (such as a QR code or RFID tag)
  • Stores product-level sustainability and compliance information
  • Travels with the product across its lifecycle
  • Enables different stakeholders to access relevant data

Each Digital Product Passport is linked to a physical product via a digital carrier, such as a QR code or RFID tag, enabling access to relevant information when needed. For businesses, this means product data can no longer remain fragmented across internal systems. It must be structured, verifiable, and interoperable across value chains.

Why the EU is introducing Digital Product Passports

According to a Green Claims study by the European Commission, 53.3% of environmental product claims in Europe are vague or misleading, and 40% are made without supporting evidence, highlighting the need for verified, standardised product data.

Digital Product Passports aim to address this gap by making sustainability data transparent, auditable and trustworthy. These structural issues in today’s economic model have prompted the EU to implement Digital Product Passports.

For EU businesses, this puts all products entering the market under the microscope. It means that product information can no longer sit in disconnected systems or remain inaccessible once a product is sold. Instead, it needs to be structured, accurate, and shareable across the full value chain.

The EU’s move toward Digital Product Passports responds to three key structural challenges:

1)     Fragmented product information

Today, data on materials, chemicals, recyclability, and overall environmental performance are often incomplete or inconsistent across sectors. This limits repair, reuse, and high-quality recycling.

2)   Low circularity rates

Despite the ambitions of certain policies, material reuse and recovery rates remain low. In 2025, the global circularity gap was reported at 6.9%, meaning that the world is only 6.9% circular (source: Circularity Gap Report 2025), and that over 70% of materials being used are wasted. Valuable resources are frequently lost due to poor product design and the lack of end-of-life information available.

3)   Increasing regulatory complexity

EU policy now spans many areas, with policies such as REACH, PPWR, GPSR, Green Claims Directive, CSRD, Textile Labelling and Extended Producer Responsibility (EPR) being rolled out.Regulators, now more than ever, need reliable product-level data to meet this legislation.

Digital Product Passports provide the data infrastructure needed to help companies address compliance gaps.

Learn about EPR

The regulatory framework behind EU Digital Product Passports

Digital Product Passports are delivered through the Ecodesign for Sustainable Products Regulation (ESPR).

ESPR:

  • Replaces the Ecodesign Directive
  • Expands beyond energy-related products
  • Introduces product-level requirements on durability, repairability, recyclability, and environmental performance.
  • Applies directly across all EU Member States

DPPs are one of ESPR’s core implementation tools. They operationalise sustainability requirements by ensuring that the required product data exists and is accessible.

In parallel, other legislation reinforces Digital Product Passport requirements, including:

Together, Digital Product Passports and Extended Producer Responsibility form a connected compliance ecosystem built on accurate, product-level data.

Learn more about EPR

Digital Product Passports as digital infrastructure, and how they work in practice

Digital Product Passports (DPPs) should not be viewed as another compliance form.

They are digital infrastructure for the circular economy.

A DPP typically includes:

  • A unique product identifier
  • A digital carrier linked to the physical product
  • A secure data repository
  • Defined access rights for different user groups

Different stakeholders will access different data layers:

  • Consumers: durability, repair instructions, sustainability indicators
  • Recyclers: material composition, disassembly guidance
  • Regulators: conformity declarations, compliance data
  • Producers: lifecycle tracking and reporting

Crucially, the passport is designed to be dynamic. It can be updated to reflect repair, refurbishment, resale or recycling , helping preserve product value and reduce information loss across lifecycles.

In this sense, DPPs act as a digital thread running through the entire product journey.

Which products will require Digital Product Passports?

EU Digital Product Passports will not be introduced all at once. Instead, the aim is to roll them out by individual product category.

Priority sectors include:

  • Batteries
  • Textiles
  • Electronics and ICT equipment
  • Construction products
  • Furniture and furnishings

Batteries are already subject to mandatory Digital Product Passports, making this the first sector for full implementation.

Over time, most products placed on the EU market are expected to fall within scope.

What data must EU businesses provide?

While detailed requirements vary by sector, EU Digital Product Passports are expected to include several core data categories.

Product identification

So that products can be accurately identified and traced across the EU market, Digital Product Passports will likely need to define who placed the product on the market and how it can be uniquely recognised.

This may include key details like:

  • Manufacturer or importer details
  • Product model and type
  • Any unique identifiers
Magnifying glass icon symbolising product identification and traceability in a Digital Product Passport system.

Material composition

Understanding what a product is made of is critical to improving recyclability, managing substances of concern, and keeping materials in circulation for longer.

Key indicators that could be captured include

  • Types of materials used
  • Presence of substances of concern
  • Use of recycled content
Business analytics icon showing sector performance and reporting data linked to Digital Product Passport requirements.

Environmental performance

Digital Product Passports also capture key indicators that help assess a product’s environmental impact and long-term sustainability.

They capture key data like:

  • Carbon footprint indicators
  • Resource efficiency metrics

Durability and repairability data

Tree and magnifying glass icon representing sustainability impact assessment within a Digital Product Passport.

Circularity

To support circularity efforts, Digital Product Passports provide practical guidance on how products should be handled throughout their first life.

This includes information such as:

  • Repair instructions
  • Disassembly guidance
  • Recycling and recovery requirements
Circular arrows icon illustrating circularity data, material recovery and lifecycle tracking in a Digital Product Passport.

Compliance and declarations

Finally, Digital Product Passports bring together essential regulatory information, helping businesses demonstrate compliance and meet their legal obligations across the EU.

In return, this helps:

  • Alignment with EU regulations
  • Links to EPR reporting obligations
  • Conformity assessments

For EU businesses, this requires robust data governance and supply chain visibility.

Open book icon representing regulatory compliance and documentation within a Digital Product Passport.

Textiles: linking ESPR, DPP and EPR / eco-modulation

Textiles are a priority product group under ESPR and the EU Circular Economy Action Plan.

Here, the interaction between regulations becomes particularly important.

Step 1: ESPR sets product design requirements

For textiles, delegated acts under eco-design are expected to address:

  • Durability
  • Fibre composition
  • Recyclability
  • Substances of concern
  • Potential restrictions on the destruction of unsold goods

Step 2: DPP operationalises product data

The Digital Product Passport becomes the mechanism that stores and communicates:

  • Fibre-level composition
  • Recycled content
  • Presence of hazardous substances
  • Repairability information
  • End-of-life instructions

This creates traceability and transparency at the product level.

Step 3: EPR and eco-modulation use that data

Under the Waste Framework Directive, Member States must introduce textile Extended Producer Responsibility (EPR) schemes.

Increasingly, EPR systems are expected to apply eco-modulation, where producer fees vary depending on product design characteristics such as:

  • Recyclability
  • Durability
  • Fibre blends
  • Presence of problematic materials

Digital Product Passports provide the verified product-level data that may underpin these differentiated fees.

Learn more about EPR

What data will EU businesses need to provide?

Under ESPR, priority sectors will need to provide specific data to help meet necessary compliance. While this is yet to be finalised, sector-specific delegated acts likely need to define precise data points, and core categories are likely to include:

Product identification

  • Manufacturer or importer details
  • Unique product identifier
  • Model or batch references

Material composition

  • Fibre types and percentages
  • Substances of concern
  • Recycled content

Environmental performance

  • Durability metrics
  • Repairability indicators
  • Resource efficiency data

Circularity and end-of-life information

  • Disassembly guidance
  • Recycling instructions
  • Sorting-relevant data

Compliance and regulatory declarations

  • Alignment with ESPR requirements
  • Links to EPR reporting
  • Conformity documentation

For textiles in particular, fibre-level traceability and recyclability data will be critical.

Key timelines and what EU businesses should expect

Digital Product Passports are now moving from policy design into phased implementation under the Ecodesign for Sustainable Products Regulation (ESPR).

As of 2026, the regulatory landscape looks as follows:

Batteries: first mandatory implementation

Batteries are the first product group with legally binding Digital Product Passport requirements under the EU Batteries Regulation

  • Certain data and labelling obligations are already in force
  • Mandatory DPP requirements are now beginning to apply in 2027

This sector sets the practical benchmark for how DPP systems function across the EU, including digital carriers, access rights, and structured product data requirements.

Textiles and other priority sectors

For other product groups, including textiles, electronics, construction products and furniture, detailed requirements continue to be defined through delegated acts under ESPR.

As of 2026:

  • Textiles remain a priority sector under the ESPR Working Plan
  • Draft technical requirements are under development
  • Finalised scope, data fields, and mandatory compliance dates are still being formalised

While implementation for these sectors is expected to follow batteries, any timeline beyond 2026 remains indicative until the relevant delegated acts are adopted and published.

For businesses placing textiles and other priority products on the EU market, this means:

  • Direction of travel is clear
  • Data expectations are becoming more defined
  • Exact compliance dates remain subject to legislative finalisation

In practical terms, 2026 is the year where preparation shifts from “early awareness” to active readiness, even where formal deadlines are still evolving.

Learn about Textiles EPR

How Digital Product Passports support EU circular economy goals

Digital Product Passports are seen as a key enabler of the EU’s circular economy strategy.

They aim support circularity by:

  • Making products easier to repair and maintain
  • Improving sorting and recycling accuracy
  • Reducing information loss across value chains
  • Enabling secondary markets and resale
  • Encouraging better product design upstream

Instead of managing waste at the end of life, Digital Product Passports allow businesses to manage products as long-term resource assets

Challenges EU businesses are likely to face

EU Digital Product Passports introduce new operational and strategic challenges. Some of the challenges involved with implementing Digital Product Passports include:

  • Data availability: Many businesses do not yet have reliable data on material composition, recycled content, or chemical substances.
  • Supply chain complexity: Suppliers that a business uses may be spread across multiple regions with varying data maturity and regulatory awareness.
  • System integration: DPPs require integration across product design, procurement, compliance, and IT systems.
  • Compliance risk: Incomplete or inaccurate data may result in enforcement action, restricted market access, or reputational damage.

Addressing these challenges early reduces long-term cost and risk.

How EU businesses should prepare now

Preparation for EU Digital Product Passports should start well before obligations become mandatory.

  1. Identify exposure: Understand which products and markets will be affected first.
  2. Assess data readiness: Map existing data sources and identify gaps.
  3. Align internal teams: Digital Product Passports span across sustainability, compliance, IT, design, and procurement.
  4. Engage suppliers early: Clear expectations and data standards are essential across the value chain.
  5. Invest in scalable systems: Interoperable, future-proof data infrastructure is critical.

Early action enables smoother compliance and stronger circular outcomes.

Digital Product Passport benefits for EU businesses

According to the European Commission, more than half of EU consumers already consider environmental impact when making purchasing decisions. The survey ‘Attitudes of Europeans towards the Environment’ found that 56% of EU consumers say environmental impact directly influences what they buy. This reflects a clear shift toward more conscious, sustainability-led purchasing behaviour across European markets.

For EU businesses, Digital Product Passports present a powerful opportunity to respond to this demand with credibility and clarity.

By providing verified, product-level sustainability data, including material composition, carbon footprint, repairability, recycled content and end-of-life instructions, Digital Product Passports enable brands to move beyond high-level sustainability claims and demonstrate measurable impact. This level of transparency builds consumer trust, strengthens brand integrity and reduces the risk of greenwashing allegations.

Crucially, Digital Product Passports also empower businesses to communicate how products should be repaired, reused, refurbished or recycled at the end of life. This supports informed consumer decision-making, encourages responsible disposal behaviour and reinforces circular economy principles

Rather than being viewed solely as a compliance requirement under EU Ecodesign and sustainability regulations, Digital Product Passports can act as a strategic differentiator. Businesses that proactively embed transparent product data into customer journeys can:

  • Strengthen brand loyalty through verified sustainability credentials
  • Enhance product traceability and lifecycle accountability
  • Increase customer confidence in durability and repairability
  • Support take-back schemes and closed-loop material recovery
  • Align with growing expectations for circular business models

In a market where environmental transparency is becoming a baseline expectation rather than a value-add, Digital Product Passports offer EU businesses a tangible way to demonstrate leadership, accelerate circularity and convert sustainability performance into competitive advantage.

Final summary: Preparing for EU Digital Product Passports

EU Digital Product Passports represent a structural shift in how products are regulated, designed, and managed across the EU.

They are not just a compliance requirement. They are a foundation for transparency, circularity, and long-term resilience.

For EU businesses, early preparation reduces risk, improves efficiency, and supports competitive advantage in a rapidly evolving regulatory landscape.

Professional providing training and guidance to support digital product passports compliance and implementation.

How Reconomy supports Digital Product Passport readiness

At Reconomy, we help EU businesses translate complex regulation into practical, scalable action.

Our support includes:

  • Regulatory interpretation across EU markets
  • Digital Product Passport strategy and readiness assessments
  • Data governance and reporting alignment
  • Integration with EPR, compliance, and sustainability reporting
  • Technology-enabled insight across product lifecycles

By combining regulatory expertise with data and operational delivery, we help businesses move from obligation to opportunity.

FAQs: EU Digital Product Passports

Reconomy supports EU businesses with regulatory insight, data strategy, compliance alignment, and digital solutions for Digital Product Passports.

Learn more about our offering

Digital Product Passports will be introduced by product category from 2027 onwards, with batteries and textiles already in scope.

Manufacturers, importers, and distributors placing products on the EU market will be affected.

The role of the EU Digital Product Passport regulation is to create a standardised, digital system for sharing product information across the EU market.

It ensures that reliable data on a product’s materials, environmental performance, and end-of-life handling is available throughout its lifecycle. By doing so, the regulation supports regulatory compliance, improves transparency across supply chains, and enables repair, reuse, and recycling, helping the EU transition toward a more circular economy.

They enable repair, reuse, recycling, and traceability by making product data accessible across the full lifecycle.

Chat with our experts

Please complete the details below and one of our team will contact you shortly.