Frequently Asked Questions

Yes, Digital Product Passports are becoming mandatory in the European Union, but not all at once and not for all products at the same time. Under the Ecodesign for Sustainable Products Regulation (ESPR), DPP requirements are introduced progressively through product-specific delegated acts. Each product category becomes subject to a Digital Product Passport only once its delegated act is adopted and enters into force. The European Commission has identified priority product groups such as textiles, electronics, furniture, tyres, and metals, which are expected to be among the first to implement DPP requirements. In parallel, other EU regulations already introduce DPP-like requirements for specific sectors, such as batteries under the EU Batteries Regulation. In practice, this means that DPPs are not yet mandatory for all products today, but they will become a requirement for placing products on the EU market as these regulations are phased in over time.

The European Commission defines a Digital Product Passport as a digital container of product-specific information that acts as a digital identity for a product. This digital identity enables traceability and transparency throughout the product’s entire value chain - from manufacturing to use, reuse, and end of life. A DPP includes mandatory and voluntary information, such as product composition and materials, manufacturing processes and origin, carbon footprint and environmental data, certificates of conformity and legal compliance, instructions for use, repair, reuse, and disposal. All of this information is accessed through a data carrier, typically a QR code or similar, connected to digital systems such as registries and web portals.

According to the European Commission’s framework, Digital Product Passports rely on three core elements: a data carrier, typically a QR code or similar identifier that links the physical product to its digital passport; technical systems, including a Digital Product Passport registry and related infrastructure that enable data access and management; and product-specific data, defined through delegated acts for each product group. In practice, this system operates across two layers: a backend and a frontend. On the backend, brands collect and structure product-level data across the value chain. This includes information from internal systems such as ERP and PLM, as well as supplier and certification data. These datasets are aligned with regulatory requirements and connected to Digital Product Passport infrastructure, including the registry, which supports data discovery, standardisation, and controlled access. On the frontend, the physical product is linked to this data through the data carrier. When a QR code is scanned, the product’s unique identifier is resolved and the relevant information is retrieved and displayed. Different stakeholders, such as consumers, businesses, and authorities, can access different levels of information depending on their role. For brands, this system requires structured data collection, traceability across the supply chain, and verifiable documentation of materials, processes, and claims. For consumers, it enables direct access to product information, including composition, verified claims, and guidance on use, care, repair, and end-of-life.

No, full supply chain traceability is not required from the start. There is currently no fixed supply chain tier requirement defined under EU Digital Product Passport regulation. Under the ESPR framework, traceability is not defined by tiers (e.g. Tier 1, Tier 2, Tier 3) but by data requirements at product level, which are introduced through delegated acts for each product group. In practice, this means that companies are required to provide specific information, such as material composition, substances of concern, or manufacturing data, and must trace their supply chain only as far as needed to obtain and verify that information. For textiles, based on the Joint Research Centre (JRC) preparatory work, current proposals focus primarily on manufacturing stages (Tier 1–Tier 2) for several requirements, while upstream stages such as raw material sourcing are not consistently required yet and are expected to be introduced progressively over time.

Under the EU Ecodesign for Sustainable Products Regulation (ESPR), Digital Product Passport (DPP) compliance requirements are defined through product-specific delegated acts, within a common regulatory framework. Products must be linked to a Digital Product Passport through a data carrier, such as a QR code or similar technology, which provides access to structured product information. The information included in a DPP must be accurate, structured, and machine-readable, and must remain accessible throughout the product lifecycle to different stakeholders, including consumers, businesses, and authorities. Companies are required to provide product-level data such as identification, material composition, substances of concern, environmental performance, compliance documentation, and instructions for use, repair, and end-of-life handling. The ESPR does not define a single fixed DPP format. Instead, it establishes a framework, with detailed requirements introduced progressively by product category through delegated acts. In practice, this means that to be compliant, companies must ensure that each product has a digital identity, that relevant data is collected and structured across the supply chain, and that this data is accessible in a standardised and interoperable way.

Under the EU Ecodesign for Sustainable Products Regulation (ESPR), a Digital Product Passport contains structured product-level data that will be defined through delegated acts, based on the framework set out in Annex I and Annex III of the regulation and further developed through the European Commission and JRC milestones. In practice, a DPP includes both mandatory and additional voluntary information. Mandatory data is defined at product-category level and typically covers product identification, information on the manufacturer or economic operator, material composition and substances of concern, environmental performance, compliance documentation, and instructions for use, repair, and end-of-life handling. These requirements must be provided in a structured, machine-readable, and interoperable format. Beyond this, a DPP can include additional information depending on the product, regulatory developments, and use cases. This may cover aspects such as durability, repairability, recyclability, recycled content, environmental impact, or supply chain data. The scope of this additional information is not fixed and evolves over time as delegated acts are adopted (expected for Q3 2027) and requirements become more detailed (Digital Product Passport Registry confirmed for July 2026). Overall, the Digital Product Passport is designed as a dynamic system, where core mandatory data is defined by regulation, while additional information can expand to support transparency, circularity and added business value across the product lifecycle.

Digital Product Passports are managed through a combination of existing company systems and dedicated DPP infrastructure. At company level, brands typically use systems such as ERP, PLM, and supplier management tools to store and manage product data, including specifications, bills of materials, and supply chain information. These systems form the primary source of product-level data required for DPPs. At EU level, the framework introduces additional technical components, including a Digital Product Passport registry and related infrastructure, which enable data discovery, interoperability, and controlled access across stakeholders. To operationalise this, companies rely on specialised solutions that connect internal systems, structure product-level datasets in line with regulatory requirements, and manage data flows across the supply chain. In practice, managing Digital Product Passports requires integrating internal data systems with external infrastructure and ensuring that product data is structured, interoperable, and accessible throughout the product lifecycle.

Based on current EU policy developments and industry practice, moving from initial setup to full deployment typically takes between 18 and 24 months. This timeline reflects the operational work required to define the DPP scope, structure product data, connect internal systems such as ERP and PLM, collect and validate supplier information, and deploy Digital Product Passports across products. According to recent updates from the European Commission and the JRC preparatory work for textiles, delegated acts are expected to be adopted in Q3 2027, with compliance becoming operational shortly after. As a result, brands aiming to be compliant by 2028 need to already have a structured implementation plan in place. Digital Product Passports should be approached as a phased process, starting with data readiness and pilots, and scaling to full deployment over time.

Brands collect data for Digital Product Passports by combining information from internal systems with data gathered across their supply chain. In practice, this process starts internally. Companies extract existing product data from systems such as ERP and PLM, including product specifications, bills of materials, and manufacturing information. At the same time, they must collect additional data from suppliers, such as material origins, processing details, and certifications, which are often not centrally available and require direct engagement across the value chain. Under the EU framework, this data must be structured at product level and aligned with regulatory requirements defined through delegated acts. This includes information on materials, substances of concern, environmental performance, and compliance documentation. Because much of this information is distributed across different actors, data collection typically requires mapping the supply chain, requesting and validating supplier inputs, and progressively filling data gaps. Building this dataset is one of the most time-intensive parts of DPP implementation, particularly due to the need for traceability and verification across multiple tiers. In practice, brands do not collect all data at once. They prioritise the most relevant product and supplier data first, structure it according to regulatory requirements, and expand coverage over time as requirements become more detailed. To support this process, many brands work with specialised providers that help define data requirements, structure product-level datasets, and manage supplier data collection. Platforms like Renoon support this by connecting existing systems, guiding data collection across the supply chain, and structuring the information needed to generate compliant Digital Product Passports.

If a company does not comply with Digital Product Passport requirements, its products may not be allowed on the EU market. Under the EU Ecodesign for Sustainable Products Regulation (ESPR), compliance is a condition for placing products on the market once the relevant delegated act for a product group enters into force. This means that products without the required Digital Product Passport cannot legally be sold in the EU. In addition, companies may face enforcement actions by national authorities, including penalties, restrictions, or product withdrawals, depending on how the regulation is implemented at Member State level. In practice, non-compliance creates both regulatory and commercial risk. Companies risk losing access to the EU market, facing disruptions in distribution, and being unable to demonstrate required product information to authorities, partners, and customers.

Digital Product Passports are expected to apply across all product categories over time, but not under a single regulation and not at the same time. Under the EU Ecodesign for Sustainable Products Regulation (ESPR), DPP requirements are introduced progressively through delegated acts, starting with priority product groups such as textiles, steel, tyres, electronics, furniture, and others identified in the ESPR Working Plan. In parallel, additional product categories are addressed through other EU regulations aligned with the Digital Product Passport concept, including batteries, packaging, construction products, and products containing critical raw materials. As a result, Digital Product Passports are being rolled out across product categories through multiple regulatory frameworks. While requirements start with priority sectors from 2026–2027, coverage expands over time, with broad application across products by around 2030.

Digital Product Passport (DPP) requirements are introduced progressively under the EU Ecodesign for Sustainable Products Regulation (ESPR) through product-specific delegated acts, starting with priority product groups identified in the European Commission’s ESPR Working Plan 2025–2030. These include sectors such as batteries, textiles and apparel, electronics, furniture, tyres, mattresses, and key materials like steel and aluminium.
The rollout follows a clear timeline. The Digital Product Passport Registry is expected to be introduced from July 2026, as a core system component where Digital Product Passports and their mandatory data are registered, ahead of the first requirements. The first mandatory Digital Product Passports will apply to batteries from February 2027. For textiles and apparel, delegated acts are expected around Q3 2027, following the preparatory work led by the European Commission and the Joint Research Centre. Once these delegated acts are adopted, companies are typically given around 18 months to comply. This means that for textiles, Digital Product Passports will become mandatory on the EU market between 2028 and 2029.

Digital Product Passports enable resale and repair by making product-level information accessible, structured, and verifiable throughout the product lifecycle. Under the EU framework, DPPs provide data on materials, composition, durability, and care, which allows products to be correctly identified, assessed, and handled after the initial sale. This reduces information gaps that typically limit repair and resale activities. For repair, DPPs can include instructions for use, maintenance, and repair, as well as information on components and materials. This enables repair providers to understand how a product is made and how it can be fixed or maintained. For resale, DPPs support product authentication, proof of origin, and ownership tracking. This allows both brands and secondary market platforms to verify product authenticity and condition, increasing trust and enabling more efficient resale processes. Beyond this, Digital Product Passports can also act as a direct service layer. When activated by the brand, they allow customers to request services such as repair or resale directly through the product interface, without relying on third-party platforms. This creates a direct link between the product, the customer, and the brand. By combining structured product data with direct service access, Digital Product Passports enable both the operational and commercial infrastructure needed to extend product lifecycles and activate circular business models.

Digital Product Passports are introduced under EU regulation to ensure compliance by making product-level data accessible, structured, and standardized. They allow products to carry verified information on materials, origin, and production, strengthening transparency and trust at the point of purchase and beyond. However, their role goes beyond this. In practice, DPPs act as a digital layer that connects products to data, systems, and users, turning each product into an ongoing touchpoint. This allows brands to create direct customer interactions through QR or similar technologies, collect first-party data, and manage relationships after purchase. It also enables use cases such as product authentication, warranty and ownership tracking, and supports services like repair, resale, and other circular models. As a result, Digital Product Passports transform products from static items into connected assets that continue to generate value across their lifecycle.

Yes. While Digital Product Passports are introduced as a regulatory requirement under EU legislation, they can also be used as an operational and customer-facing layer beyond compliance. At product level, a DPP creates a direct digital connection between the product and the brand. This allows companies to activate use cases such as customer registration, ownership tracking, and ongoing interaction through product-linked digital experiences. In practice, this turns each product into a recurring touchpoint rather than a one-time transaction. Digital Product Passports can also support commercial and lifecycle use cases. These include enabling services such as repair, resale, and warranty management, as well as providing structured product data that can be reused across e-commerce, customer engagement, and internal systems. In addition, DPPs enable brands to communicate verified product information directly to consumers, improving transparency and trust while supporting differentiation at launch and throughout the product lifecycle. As a result, while compliance is mandatory, Digital Product Passports can also function as a foundation for customer engagement, operational efficiency, and new post-purchase revenue models.

Renoon is a company specialized in end to end Digital Product Passport solutions that combine advisory, technology, and operational support.
We define DPP roadmaps and operating models aligned with compliance, ESG, and supply chain traceability requirements. We design and integrate scalable DPP platforms with existing company systems, ensuring secure data management and interoperability. We also support operational implementation, from platform configuration to supply chain coordination and go live management.
By unifying strategy, system integration, and managed services, Renoon turns Digital Product Passport requirements into a structured, connected product system that supports compliance and long term business value.

No. Renoon is not a fashion app or marketplace. Renoon is a specialized company focused on Digital Product Passports, helping brands manage product-level data, ensure compliance with EU regulations, and implement DPP systems at scale. Brands work with Renoon to connect existing systems such as ERP and PLM, collect and structure supply chain data, and generate Digital Product Passports that can be accessed through QR codes or integrated into e-commerce and product experiences. Renoon acts as the operational layer that enables brands to move from fragmented product data to a structured, compliant, and connected product system.