Starting in 2027/2028, the European Union will mandate many products sold within the EU to feature a Digital Product Passport (DPP). This requirement is part of the broader Ecodesign for Sustainable Products Regulation (ESPR) framework, a set of eco-design regulations aimed at increasing product sustainability and supply chain transparency and providing consumers with detailed information about products’ origins, materials, and environmental impact.
As the Digital Product Passport (DPP) framework continues to evolve, now is the time to start preparing for upcoming regulatory changes. While the specifics of how these regulations will apply to different product categories are still taking shape, key elements are beginning to come together. It’s evident that meeting DPP regulations will require that businesses have a strong grasp of their product and supplier data, and effective regulatory compliance solutions. They will also need to update product labeling for affected goods and create DPPs for their regulated items.
With specific delegated acts expected to come between 2026 and 2027, Trace One is closely tracking the changes to provide you with the most up-to-date information. Our team of experts is here to help businesses stay ahead of these evolving requirements, seamlessly implementing necessary changes to ensure regulatory compliance while maintaining operational efficiency.
A Digital Product Passport is a set of product-specific data that is accessible electronically through a data carrier. This data will be linked to a unique product identifier embedded in the data carrier.
Before we dive into the details below, here are some helpful definitions to familiarize yourself further with the DPP.
The DPP will apply to most products sold in the EU with the exception of food, feed, and medicines. The content of the DPP is still being determined by EU bodies, and Trace One is closely following the developments as they unfold. For now, we know that it will vary based on product type, but generally it will include:
Some requirements of the DPP are already defined, including the need for unique product identifiers, manufacturer information, and data carrier requirements such as QR codes. However, additional specifics including product-specific information requirements, how long DPPs should remain available, and whether they will apply to individual items, batches, or models, will be determined through delegated acts.
The DPP will require new processes for data collection, storage, and sharing, along with increased transparency for consumers. Information that was previously confined to safety data sheets will now be available to the public.
Businesses will need to upload unique product and operator identifiers to the Central DPP Registry, a searchable web portal maintained by the EU Commission. Once uploaded, the system will generate a unique registration identifier for each product.
Key Steps in the DPP Process:
Manufacturers must conduct a conformity assessment according to product-specific regulations, prepare necessary technical documentation, and draft the 'EU Declaration of Conformity,' including any required CE markings.
The definition of “substances of concern” encompasses several lists that we already provide and maintain within our PLM software at Trace One.
These include:
Consumers are demanding increasing transparency and data on product materials. The DPP will help businesses meet this demand—and help consumers gain the visibility they want—by making information on substances of concern more accessible, including information on those substances classified as carcinogenic or with reproductive effects.
While the main framework has been published, specific delegated acts are expected to come between 2026 and 2027. Product-specific delegated acts for detergents, chemicals, and lubricants are expected by the end of 2025. Additionally, the standard for the DPP is also expected to be finalized by the end of 2025, with obligations for certain products beginning in 2027-2028.
Products included:Products specifically excluded:
Although detailed regulations for each product are still pending, the current draft update for detergent regulation gives us insight into what will be required for the DPP.
For detergents, the DPP will need to include:
Additionally, the DPP will include a message such as, "More comprehensive information on the product is available online.”
Trace One’s PLM solutions already collect much of the relevant information required for DPP compliance. Our regulatory compliance software is supported by regulatory experts and libraries as well as a long-term vision of the horizon ahead to help ensure you stay compliant as developments evolve. As data management hygiene and effective supplier information management become more critical, we’ll be here to support you.
Working from a Single Source of Truth (SSOT) digitized platform for every product decision you make requires unifying both your data and processes effectively. Our integrated PLM solution with package management and regulatory compliance software is critical in streamlining the flow of product and supplier data across your entire value chain and thanks to our unified platform, you can better manage product lifecycle data while maintaining transparency, traceability, and compliance.
By providing consumers with a detailed digital record of a product’s lifecycle, the DPP will enhance supply chain management and ensure regulatory compliance.
As the regulatory landscape continues to evolve, businesses need to prepare for the upcoming deadlines in 2028. While the DPP regulation continues to take shape, Trace One is actively monitoring its progress to ensure we’re ready to act when the path becomes clearer and to support companies in staying compliant. With our product lifecycle management software, DPP compliance can be done on time and without unnecessary stress or delays.
Discover how Trace One’s PLM and Compliance platform can help you stay ahead. Our PLM software supports your teams across the entire product lifecycle—so you’re always ready for what’s next. Get in touch with us to explore how we can help you prepare for the upcoming DPP regulation and navigate change with confidence.
For more information from the European Union on how the Digital Product Passport is advancing transparency and sustainability, visit this link.