Digital Product Passport Requirements

The Digital Product Passport (DPP) stands as a cornerstone of the European Union's ambitious plan to transition towards a circular economy. Outlined in the Ecodesign for Sustainable Products Regulation (ESPR), the DPP will function as a digital repository of product information, accessible electronically via a data carrier such as a QR code.

This article will lay out the broad technical and data requirements manufacturers must meet to comply with these new regulations. These requirements seek to enhance transparency and traceability throughout a product's lifecycle, empowering informed decision-making by consumers, businesses, and authorities, ultimately driving the market toward more sustainable products.

Although the ESPR outlines the broad requirements for a Digital Product Passport, more specific requirements will be outlined in subsequent “delegated acts” that address individual product categories.

Goal of Digital Product Passport Requirements

A Digital Product Passport is a collection of product-specific data that includes information specified in the applicable delegated act and is accessible electronically through a data carrier. The data in the Digital Product Passport needs to be accurate, complete, and up to date.

The Digital Product Passport requirements aim to:

• Ensure that actors along the value chain can easily access and understand product information relevant to them
• Facilitate the verification of product compliance by competent national authorities
• Improve the traceability of products along the value chain

Products can only be placed on the market or put into service if a Digital Product Passport is available in accordance with the applicable delegated acts.

Delegated acts: Outlining requirements for DPPs

The delegated acts for a product category will specify:

• The data to be included in the Digital Product Passport
• One or more data carriers to be used
• The layout in which the data carrier is to be presented, and its positioning
• Whether the Digital Product Passport is to be established at the model, batch or item level
• The manner in which the Digital Product Passport is to be made accessible to customers before they are bound by a contract for sale, hire, or hire purchase
• The people/organisations that are to have access to data in the Digital Product Passport, and to what data they are to have access
• The people/organisations that are to create or update the Digital Product Passport, and what data they may introduce or update
• The detailed arrangements for introducing or updating data
• The period during which the Digital Product Passport is to remain available (which shall correspond to at least the expected lifetime of the product)

Essential requirements for Digital Product Passports

As outlined by the ESPR, a Digital Product Passport needs to fulfil several broad requirements including:

• A DPP shall be connected through a data carrier to a persistent unique product identifier
• The data carrier shall be physically present on the product, its packaging, or on documentation accompanying the product
• The data carrier and unique product identifier shall comply with one or more of the standards referred to in the ESPR legislation (or equivalent European or international standards)
• All data included in the Digital Product Passport shall be based on open standards, developed with an interoperable format, and shall be machine-readable, structured, searchable, and transferable through an open interoperable data exchange network
• Personal data relating to customers shall not be stored in the Digital Product Passport without their explicit consent
• The data included in the Digital Product Passport shall refer to the product model, batch, or item
• Access to data included in the Digital Product Passport shall be regulated in accordance with the essential requirements
• The Digital Product Passport shall be fully interoperable with other Digital Product Passports
• Customers, manufacturers, importers, distributors, dealers, professional repairers, independent operators, refurbishers, remanufacturers, recyclers, market surveillance authorities, customs authorities, civil society organisations, trade unions, and other relevant actors shall have free of charge and easy access to the Digital Product Passport based on their respective access rights
• The Digital Product Passport shall be stored by the economic operator responsible for its creation or by Digital Product Passport service providers
• Where a new Digital Product Passport is created for a product that already has a Digital Product Passport, the new Digital Product Passport shall be linked to the original Digital Product Passport(s)
• The Digital Product Passport shall remain available for the period specified in delegated acts adopted, including after an insolvency, a liquidation, or a cessation of activity in the Union of the economic operator responsible for the creation of the Digital Product Passport
• The rights to introduce, modify, or update data in the Digital Product Passport shall be restricted
• Data authentication, reliability, and integrity shall be ensured
• Digital product passports shall be designed and operated to ensure a high level of security and privacy, and avoid fraud

Data to be included in the Digital Product Passport

In addition, the ESPR outlines these broad data requirements, which may become more specific with a delegated act.

• Information required as to the product’s environmental performance, or about substances of concern
• The unique product identifier at the level indicated in the applicable delegated act
• The Global Trade Identification Number
• Relevant commodity codes, such as a TARIC code
• Compliance documentation and information applicable to the product, such as the declaration of conformity, technical documentation, or conformity certificates
• User manuals, instructions, warnings, or safety information as applicable to the product
• Information related to the manufacturer, such as its unique operator identifier
• Digital information about the product, including about
  • Installation, use, maintenance, and repair
  • Third-party operating systems required to use the product
  • Collection for refurbishment or remanufacture
• Unique operator identifiers other than that of the manufacturer
• Unique facility identifiers
• Production date and location
• Information related to the product’s expected lifetime and to the availability of software updates, spare parts, and repair services
• Information on how to return or handle the product at the end-of-life
• The reference of the Digital Product Passport service provider hosting the back-up copy of the Digital Product Passport

Exemptions from Digital Product Passport requirements

The Commission may exempt product groups from the requirement to have a Digital Product Passport where:

• Technical specifications of the Digital Product Passport are not available in relation to the essential requirements
• Another EU law already provides a digital system for product information that effectively achieves the goals of:
  • Accessible product information: Making relevant product information readily available to various stakeholders along the value chain.
  • Compliance certification: Enabling national authorities to easily verify a product's compliance with the ESPR's ecodesign requirements

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