Everything you need
to know about the DPP
The 18 most common questions about the Digital Product Passport: what it is, which legislation governs it, which products it affects, when it becomes mandatory and how to prepare your organisation. Based on official European Commission documentation.
The basics
The DPP is a digital identity card for every product. It brings together structured information about the product itself, its components and its materials, and makes it accessible throughout the entire life cycle, from design to recycling.
It serves three purposes: driving sustainability, enabling circularity and strengthening legal compliance for products placed on the European market.
The DPP works as a horizontal aggregator: a single electronic access point to product information that supports better decisions across the whole value chain.
- For consumers: making informed, sustainable purchasing decisions.
- For industry: improving supply chains, compliance and circularity.
- For authorities: automating customs and market surveillance.
Through a physical data carrier placed on the product, its packaging or the accompanying documentation. The most common is a QR code, though NFC tags and other formats are also covered.
- QR: scanned straight from a phone camera, no app required.
- NFC: by tapping the phone against the product or the tag.
- European web portal: browsing and comparison from any device.
- Online marketplaces: the DPP visible on the product listing itself.
OKTICS OKOTags combine QR and NFC in a single carrier, with the information managed from OKOCloud and updatable without reprinting the label.
Four actors share a single source of truth:
- Economic operator: compiles the data, registers the DPP, attaches the data carrier and keeps the information up to date throughout the life cycle.
- Consumer: scans the carrier or visits the European portal to access pre- and post-purchase information.
- Public authority: customs verify the DPP registration at the border, and surveillance authorities scan products to consult the documentation.
- Repair and recycling: access disassembly instructions, spare parts, composition and substances of concern.
Legislation and timeline
From the Ecodesign for Sustainable Products Regulation (ESPR), in force since 18 July 2024, which establishes the DPP as the key tool for enforcing sustainability requirements in each product category.
- Objective: more durable, repairable, recyclable and energy-efficient products on the European market.
- Mechanism: delegated acts specific to each product group, based on prior studies and impact assessments.
- Scope: almost all physical goods placed on the EU market, with some exclusions such as food and medicines.
The ESPR Working Plan sets indicative dates for adopting the final rules for each product group:
- 2026 — Iron and steel.
- 2026-2029 — Energy-related products.
- 2027 — Textiles, tyres and aluminium.
- 2028 — Furniture.
- 2029 — Mattresses and ICT products.
Worth noting: inclusion in the Working Plan does not automatically make the DPP mandatory. Each group first requires an in-depth study and an impact assessment.
Beyond the ESPR, six European regulations already carry digital passport obligations, each with its own timeline:
- Batteries Regulation — sustainability, safety and recycling. First mandatory DPPs for large batteries in early 2027.
- Construction Products Regulation — safety and performance. Applies from January 2026; the DPP follows 18 months after the delegated act.
- Critical Raw Materials Act — securing the supply of critical raw materials. DPP information required towards the end of 2028.
- Packaging Regulation (PPWR) — reducing packaging waste and impact. Labelling from August 2028, pending the implementing act.
- Toy Safety Regulation — applies from 1 August 2030; delegated powers over the DPP start in January 2026.
- Detergents and surfactants — composition and labelling. Political agreement reached, with a timeline expected in early 2026.
The European Commission is building the DPP infrastructure alongside the legislation:
- Mid-2026 — the CEN-CENELEC JTC 24 committee finalises the eight core technical standards for the DPP.
- July 2026 — the DPP Registry is now live: the central European index linking each product identifier to the location of its data.
- Coming years — the DPP Web Portal, the public interface for consulting and comparing product information.
- Four years — customs interconnection with automated exchange with national customs authorities.
Yes. Every product entering the European market must carry a DPP once the relevant delegated act requires it, regardless of where it was manufactured. That includes goods sold through online marketplaces.
The framework respects World Trade Organization rules: it is non-discriminatory, proportionate and transparent.
Oversight works in three layers:
- Market surveillance: national authorities verify the accuracy and completeness of the information.
- Customs: automated checks at the EU border via the DPP Registry.
- Consumers: the right to compensation for damages arising from non-compliance.
Products without a compliant DPP will lose access to the European market, with a direct impact on revenue and distribution strategy.
Content and technology
The specific detail is set by each delegated act, but the information travelling with the product is organised into eight blocks: identification, composition, origin, performance, use and maintenance, end of life, compliance and warranty.
You can find the full breakdown of the data categories required by the ESPR in the What information must the DPP include? section of the main DPP page.
No. The European architecture combines a centralised index with decentralised data.
- DPP Registry (centralised): a secure EU-level database storing unique product identifiers. It does not hold the detailed data: it links each identifier to the location of its DPP.
- Data and portal (decentralised): the detailed data is hosted by economic operators or DPP service providers. A public web portal allows people to consult it and compare products.
This means every company needs its own infrastructure to issue, host and serve DPPs reliably and persistently.
The CEN-CENELEC JTC 24 committee is developing eight harmonised standards, due to be finalised by mid-2026:
- Unique identifiers
- Data carriers
- Access rights and security
- Interoperability
- Data processing and formats
- Storage and persistence
- Authentication and integrity
- Life cycle management APIs
For businesses
No. The system is designed with privacy by default and is fully aligned with the General Data Protection Regulation (GDPR).
- Anonymous access: general lookups do not require identification.
- No personal data: customer personal data will not be stored in the DPP.
- Consent only: any link to personal data requires explicit consent under the GDPR.
The DPP is not only a regulatory requirement: handled well, it becomes a measurable competitive advantage.
- Stronger market position: competing on verifiable durability, repairability and impact, not just on price.
- Simpler compliance: digitising certificates and declarations means less paperwork and smoother audits.
- Circular revenue: enabling professional repair, remanufacturing and high-quality recycling.
- End-to-end traceability: machine-readable data across the whole value chain, from design to recycling.
Yes. Article 22 of the Ecodesign Regulation explicitly recognises the role of SMEs and provides for support at both European and national level.
- From the Commission: guidelines tailored to SME needs, free digital tools to ease implementation, and public consultations and impact assessments before imposing a DPP.
- From Member States: mandatory one-stop shops for awareness and networking, possible financial assistance and tax advantages, and specialised training with organisational and technical support.
For consumers
With the assessment: identifying which categories in your portfolio will be affected and on what timeline. From there, audit the quality and traceability of your product, supplier and material data, and define your systems architecture.
The full roadmap is broken down in the 4 steps to readiness section of the main DPP page.
Verifiable information at the moment of purchase and afterwards too, when it comes to using, repairing or disposing of the product:
- Circularity: durability, repairability and recyclability.
- Composition: materials and components used.
- Use and maintenance: manuals, repair guides and available spare parts.
- End of life: disassembly, reuse and recycling instructions.
For the brand, each of those scans is also a direct digital channel to the end user after the sale.
What we get asked most
about the battery DPP
The 8 most common questions from battery manufacturers: which passport level applies, how suppliers are managed and who is responsible for each piece of data throughout the battery's life.
It depends on the type of battery and how it is placed on the market. For an LMT or EV battery, the mandatory level usually matches the pack itself, since there is no smaller sales unit. For an industrial or stationary storage battery, the pack or system carries the QR code, but internal modules can keep their own identifier if they are replaceable.
In every case the principle is the same: the passport sits at the level of what is placed on the market, with supplier data (composition, carbon footprint, origin) linked underneath, whether by batch or by unit.
The passport still belongs to the battery, not the device. The OKOTag is placed somewhere accessible without disassembly, and the device manufacturer is responsible for making the passport available before selling the assembly.
Not only. It is the combination of the product identifier (the GTIN, which says which model it is) and the serial number of that specific unit. Together they form the global unique identifier encoded in the QR/NFC via GS1 Digital Link, pointing to that particular battery's passport rather than a generic model sheet.
With a pilot: we map a representative battery model, separate what you already have in-house from what depends on suppliers, and replicate that process across the rest of the catalogue.
OKOCloud supports restricted access: the supplier uploads its information once and you control who sees it. Competitors and the public don't access the same layers as your technicians or an auditor.
Whoever carries out the work: the repair shop, the refurbisher or the manufacturer itself. OKO Identity can give authorised third parties limited access so they can add the repair event without touching the rest of the data.
Responsibility is layered: each party signs what it declares itself, not what others declared. The manufacturer doesn't have to sign again for a repair it didn't carry out.
The manufacturer retains legal responsibility for the content. OKO Identity provides the platform, the link to the EU DPP Registry and access control.
From that date batteries cannot be sold in the EU without a passport, so we recommend starting early enough to design, connect suppliers and validate before the deadline.
Download the complete DPP guide
The whole European framework in a single document: sector-by-sector timeline, mandatory data categories and the steps to get your organisation ready.
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