Regulation
·
August 27, 2024

How to Get Ready for Digital Product Passports: Definitions and Key Dates

Marta Bordignon
Content Writer

Digital Product Passports are being introduced progressively across product categories placed on the EU market. The Ecodesign for Sustainable Products Regulation establishes the common framework, while product-specific delegated acts will determine which products require a DPP, what information must be included and when the obligations begin to apply.

For textiles and apparel, the relevant requirements are still under development. However, the common infrastructure is already taking shape: the EU DPP Registry is operational, the first harmonised standards have been referenced by the European Commission and businesses can begin preparing their product data and internal processes.

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This article was originally published in August 2024 and is updated as new regulatory and technical developments are released. Last updated: September 2026.

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ESPR Regulation: The challenge

The Ecodesign for Sustainable Products Regulation entered into force in July 2024 and provides the legal framework for introducing ecodesign and product information requirements across a wide range of physical products.

The ESPR does not impose the same Digital Product Passport requirements on every product immediately. Specific delegated acts will define the applicable dataset, data granularity, access rights, data carrier and implementation timeline for each product group.

The 2025–2030 ESPR Working Plan identifies textiles, particularly apparel, among the priority product groups. Until the relevant delegated act is adopted, companies can prepare their systems and data without presenting today’s projects as evidence of compliance with requirements that have not yet been finalised.

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What’s a Digital Product Passport?

A Digital Product Passport is a structured digital record connected to a physical product through a data carrier, such as a QR code or another machine-readable identifier. It provides authorised users with access to product information defined by the legislation applicable to that product category.

The European system follows a decentralised architecture. Product information may be hosted by the economic operator or its service provider, while the EU DPP Registry stores at least the unique identifiers and the information required to register, verify and discover the passport. The Registry does not function as a central database containing every complete Digital Product Passport.

The exact information required will depend on the applicable product-specific legislation. Depending on the product category, a Digital Product Passport may include information relating to:

Technical Performance: Details on the product's functionality, durability, and efficiency, ensuring that it meets technical standards and performs as intended throughout its lifecycle.

Environmental Sustainability Performance: Information related to the environmental impact of the product, including carbon footprint, resource usage, and efforts to minimize ecological harm during production, use, and disposal.

Circular Aspects: Data on how the product supports circular economy principles, such as its recyclability, potential for reuse, and the use of recycled or renewable materials in its manufacturing process.

Legal Compliance: Documentation that confirms the product meets all relevant legal standards and regulations, ensuring it adheres to the necessary legal frameworks within the European Union and potentially other jurisdictions.

Product-Related Information: Additional details that provide insight into the product's origin, manufacturing process, and other relevant attributes that contribute to its overall sustainability profile.

The European Commission describes the DPP as a tool for providing digital access to product-specific information concerning sustainability, circularity and legal compliance.

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How DPP Unlocks New Business Opportunities

The Digital Product Passport (DPP) regulation aims to revolutionize the way product-related information is shared across the supply chain, ensuring transparency and traceability throughout a product's lifecycle. (European Commission, 2023)

By bridging the existing gap between the growing demand for transparency from consumers, investors, and other stakeholders and the current scarcity of reliable data on product journeys, DPPs are set to play a critical role in driving sustainable practices in the industry. In the future, the data collected and displayed under DPP requirements will not only serve to inform stakeholders but also establish a foundation for sustainability standards and practices that will accelerate the transition towards a circular economy.

For fashion brands, this means greater accountability, the ability to verify claims of sustainability, and enhanced trust with consumers. Additionally, DPPs help identify inefficiencies that inform strategies to improve sustainability performance and reporting. But for fashion brands there’s much more than ethics, sustainability and reputational gains.

The DPP also presents significant business opportunities by enabling brands to establish direct connections with the product owners, even at the final stages of the product life cycle, such as resale.

Through this new avenue, fashion brands can:

  • Foster deeper relationships with customers, leading to increased retention,
  • Offer innovative, product-based digital experiences that enhance brand engagement,
  • Capitalize on after-sales services, remanufacturing, and recycling opportunities,
  • Create new opportunities for consent-based customer registration and post-purchase engagement.

These advantages position DPPs not only as a tool for compliance but as a strategic asset that can drive growth and innovation in the fashion industry (Deloitte, 2024).

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How to Get Ready to Launch your Digital Product Passport

Preparing for Digital Product Passports starts with understanding how product information is currently created, managed and exchanged across the organisation and its supply chain.

Companies can begin with the following steps:

1. Define the products and markets in scope

Identify the product categories sold in the European Union and monitor the delegated acts that will determine the applicable requirements, timelines and exemptions. DPP obligations are introduced by product category, not according to company size.

2. Map existing product data

Review the information currently held across PLM, ERP, PIM, e-commerce, compliance documents and supplier files. Establish which data is already available at product, model, batch or item level and where it is stored.

3. Identify missing data and evidence

Compare available information with the product, supply-chain and compliance data likely to be required. Identify gaps, the evidence supporting each data point and the suppliers or internal teams responsible for providing it.

4. Establish data ownership and governance

Assign clear responsibility for collecting, reviewing, approving and updating each category of information. Define when data must be available during product development and how changes will be managed after the Digital Product Passport is published.

5. Prepare suppliers

Determine which information must come from the supply chain and introduce a repeatable process for requesting, receiving and maintaining it. Supplier involvement should form part of the operating process rather than being managed through isolated requests for each collection.

6. Define product identifiers and granularity

Assess whether Digital Product Passports will be created at model, batch or individual-item level. Companies should also determine how existing product identifiers can connect with the unique identifiers and registration processes required by the European framework.

7. Plan the data carrier

Define how users will access the Digital Product Passport, for example through a QR code placed on a label, hangtag, packaging or directly on the product. The data carrier must remain connected to the correct product and follow the requirements applicable to its category.

8. Connect the Digital Product Passport with existing systems

Plan how product data will move from existing systems into the DPP and how updates will be managed. Integrations with PLM, ERP, PIM, e-commerce and CRM systems can reduce manual work and make the process scalable across collections.

9. Select adaptable technology

Choose a solution that supports interoperability, data portability, European standards and connection with the EU DPP Registry. The system should also allow new data points and access rules to be incorporated once product-specific requirements are finalised.

10. Test the process on a defined scope

A pilot can be used to validate data availability, responsibilities, supplier participation, QR-code management and system integrations. The purpose is to build a repeatable operating model that can later be extended across a wider product portfolio.

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Selecting a DPP Service Provider

Digital Product Passports are not based on a single visual template. However, the European standards and the operational DPP Registry now provide a common technical foundation for identifiers, data carriers, access rights, interoperability, registration and data exchange.

When assessing a DPP solution, companies should verify whether it can:

  • connect with existing PLM, ERP, PIM, e-commerce and CRM systems;
  • manage passports at model, batch or individual-item level;
  • collect and update information from internal teams and suppliers;
  • maintain the link between each product, its unique identifier and its data carrier;
  • support registration through the EU DPP Registry;
  • apply different access rights to consumers, business partners and authorities;
  • incorporate new data points as product-specific requirements are defined;
  • allow product data to be exported and transferred without creating technological lock-in;
  • keep the Digital Product Passport accessible and up to date for the period required by the applicable legislation.

The assessment should therefore cover the full operating process, from data collection and supplier involvement to passport publication, maintenance and integration with consumer-facing channels.

Renoon supports fashion companies across this process, combining regulatory guidance, product and supply-chain data management, system integrations and the rollout of Digital Product Passports across products and collections.

Talk to our team about preparing and implementing your Digital Product Passport project.

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Where would you like to start?