Under Articles 9 and 10 of the Ecodesign Regulation (ESPR), a Digital Product Passport (DPP) must act as a central data pool for the product's life cycle. The data requirements are divided into specific categories that ensure traceability, chemical safety and verifiable environmental data.

Legal requirements for unique identification (UID)

Traceability is the foundation of the DPP architecture. For a product passport to be valid, it must contain three types of unique identifiers that enable precise tracking across the whole value chain:

  • Product identifier: A unique code (for example based on GS1 standards) for the product model or the specific unit, depending on the requirements for the product category.
  • Operator identifier: Digital IDs for all economic operators involved in the product's journey, from manufacturer to importer.
  • Facility identifier: Identification of the specific factories or locations where raw materials have been processed or the product has been assembled.

Special requirements apply to batteries from February 2027. Read our guide to digital battery passports.

Materials and chemical transparency

The EU now requires full transparency about substances to enable safe recycling. These are not just technical specifications, but mandatory declarations:

  • Substances of Concern (SoC)

    Mandatory information on substances identified under the REACH or CLP Regulations. Companies must be able to state the concentration of these substances and their exact location in the product.

  • Recycled content shares

    Documentation of the content of secondary raw materials (recycled content), which must be verified through documented information from suppliers.

Verifiable environmental footprint (PEF)

Climate data in a DPP must not be based on estimates. The PEF method (Product Environmental Footprint) is the legally defined framework for calculating the product's environmental impact:

Climate footprint (Global Warming Potential)
Quantitative data on CO2 emissions from cradle to grave, including production and logistics.
Resource use
Documentation of water use, land use and the use of non-renewable resources.

Compliance and technical documentation

An important part of the DPP content is the digitisation of documents that used to be kept in closed archives or followed the product on paper:

  • EU declaration of conformity: The digital CE declaration confirming compliance with all relevant EU directives.
  • Test reports: Verifiable results from laboratories that support technical and environmental claims.
  • Instructions and manuals: Information on safety, maintenance, repair and disassembly to extend the product's life.

Access rights and data governance

To protect trade secrets, the DPP works with different access levels. This ensures that only the necessary actors have access to sensitive data:

User type Data access
Consumers Environmental labelling, carbon footprint and manuals.
Professional repairers Spare parts catalogues and technical disassembly guides.
Authorities Full chemical composition and compliance documentation.

Summary

The data requirements for a Digital Product Passport are defined to create a comparable market for sustainable products. It is the manufacturer's or importer's legal responsibility to ensure that the data is correct and up to date. Missing or outdated data in the passport can result in trade barriers in the internal market once the product-specific rules take effect.