What Companies Need to Know Under the Ecodesign for Sustainable Products Regulation
January 2025
The European Union is fundamentally reshaping how product sustainability information is created, shared, and used. At the center of this shift is the Digital Product Passport (DPP), established under the Ecodesign for Sustainable Products Regulation (ESPR – Regulation (EU) 2024/1781).
The ESPR has been in force since 18 July 2024, and in April 2025 the European Commission adopted its first ESPR Working Plan for 2025–2030, setting out priority product groups for future requirements. While Digital Product Passports are not yet mandatory for most products, the regulatory framework is now firmly in place.
This article sets out the basics companies need to understand: what DPPs are, who they apply to, which dates matter, how to prepare, how they support sustainability goals, and how DPP data can be used beyond compliance.
What Is a Digital Product Passport?
A Digital Product Passport is a digital record linked to a physical product that contains structured information about the product’s sustainability, composition, and lifecycle characteristics. The passport is accessed via a data carrier (such as a QR code or similar identifier) placed on the product or its packaging.
Under the ESPR, DPPs are designed to:
- Improve transparency across product value chains
- Support repair, reuse, and recycling
- Enable better enforcement of sustainability requirements
- Reduce greenwashing through standardized product information
The ESPR establishes the framework for DPPs. The exact information required, who can access it, and how it must be provided will be defined later through product-specific delegated acts.
Who Do Digital Product Passports Apply To?
DPP requirements will apply to economic operators placing products on the EU market once a delegated act introduces obligations for a specific product group. This includes:
- Brands
- Manufacturers (EU and non-EU)
- Importers
- Authorized representatives
In some cases, distributors
The ESPR applies regardless of where a product is manufactured. Products explicitly excluded from the regulation include food, feed, and medicinal products.
How DPP Obligations Are Introduced
The ESPR itself does not impose immediate Digital Product Passport requirements across all products. Instead:
- The Commission adopts a delegated act for a specific product group
- The act defines DPP requirements, including content and access rules
- A transition period applies before compliance becomes mandatory
The Working Plan identifies priority product groups, but it does not set binding compliance dates.
Battery Passport: The Only Confirmed Mandatory DPP Date
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Battery Passport: The Only Confirmed Mandatory DPP Date
The EU Battery Regulation (Regulation (EU) 2023/1542) establishes the first legally binding product passport of this kind.
From 18 February 2027, a digital battery passport will be mandatory for:
- Electric vehicle batteries
- Industrial batteries with a capacity greater than 2 kWh
The battery passport must include information such as its carbon footprint, recycled content, performance, and durability. This requirement is separate from the ESPR but is closely aligned with the Digital Product Passport concept.
Priority Product Groups Under the ESPR (Indicative)
The ESPR Working Plan 2025–2030 identifies the following product groups as priorities for future delegated acts:
- Textiles and apparel
- Iron, steel, and aluminum
- Electronics and ICT products
- Furniture and mattresses
- Tires, detergents, paints, and lubricants
The timing, scope, and specific DPP requirements for these sectors will be set through delegated acts. No binding compliance dates have yet been adopted for these groups yet.
What Information Will a Digital Product Passport Contain?
While details will vary by product group, the ESPR sets out common principles for DPP content:
- Product identification information
- Material composition and substances of concern
- Environmental and sustainability performance information
- Instructions for use, repair, and maintenance
- End-of-life and recycling information
- Compliance documentation
Access to information will vary depending on the user (e.g. authorities, consumers, recyclers), balancing transparency with protection of commercially sensitive data.
How Companies Should Prepare
Although most DPP requirements are still forthcoming, companies can take practical steps now:
1. Identify Relevant Products
Assess whether products fall within the priority groups identified in the ESPR Working Plan.
2. Review Existing Data
Many required data points already exist in internal systems or supplier documentation but may not be standardized or easily accessible.
3. Strengthen Data Governance
The ESPR emphasizes interoperability and digital accessibility. Companies should prepare structured, machine-readable data that can be shared securely across the value chain.
4. Engage Suppliers
DPPs rely on upstream data. Early supplier engagement will be critical to ensure consistent and reliable information flows.
5. Monitor Delegated Acts
Track regulatory developments closely as delegated acts are proposed and adopted for relevant product groups.
How Digital Product Passports Support Sustainability Goals
Digital Product Passports are a key tool for delivering the objectives of the EU Circular Economy Action Plan. By making product lifecycle information available, DPPs support:
- More durable and repairable product design
- Improved recycling and material recovery
- Verified sustainability claims
- Reduced environmental impacts across value chains
The ESPR explicitly links DPPs to improving the environmental sustainability of products placed on the EU market.
Using DPP Data Beyond Compliance
While DPPs are a regulatory requirement, the data they generate can also support business value. Companies may use DPP data to:
- Improve internal decision-making on materials and design
- Enable circular business models such as repair and resale
- Enhance supply-chain transparency
- Build trust with customers and stakeholders
Conclusion
The Digital Product Passport is no longer a future concept. With the ESPR in force since July 2024 and the first Working Plan adopted in April 2025, the framework for implementation is established. Battery passports become mandatory from February 2027, and further product groups will follow through delegated acts under the ESPR.
For companies placing products on the EU market, now is the time to prepare—by strengthening data foundations, engaging suppliers, and monitoring regulatory developments—so that compliance can be met efficiently and aligned with broader sustainability goals.
Sources
- European Commission – Ecodesign for Sustainable Products Regulation (ESPR)
https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_ - European Commission – ESPR Working Plan 2025–2030 (adopted 16 April 2025)
https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en?filename=FAQ-UPDATE-4th-Iteration_clean.pdf - Regulation (EU) 2024/1781 – ESPR (EUR-Lex)
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1781 - European Commission – ESPR Frequently Asked Questions https://circabc.europa.eu/rest/download/25c48e7c-9ce3-41cb-96ac-d2942a8a29d6?ticket=
- Regulation (EU) 2023/1542 – EU Battery Regulation (Battery Passport)
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1542 - CIRPASS Project (Commission-mandated DPP pilot initiative)
https://cirpassproject.eu - European Commission – Circular Economy Action Plan
https://commission.europa.eu/circular-economy-action-plan