Digital Product Passports will be required in the future to sell products on the EU market.

 In May 2024, the European Government published a new binding regulation for manufacturers that want to sell products in all EU countries, the Eco-design for Sustainable Products Regulation (ESPR). One of the headline novelties is the introduction of mandatory Digital Product Passports (DPPs) for over 30 specific product groups in the 2028-2033 period. 

 DPPs are expected to host mandatory legal information requirements, such as environmental parameters, user manuals, and market conformity certificates. For each product group specific legal information requirements to be published in a DPP are defined in a specific delegated act. TRACID provides a DPP service for manufacturers to comply with this regulation.  

 The timeline when DPP's are required for sales in the EU for manufacturers varies for each product group, such as textiles, steel, toys and furniture. In general, a delegated act is developed for a product group and once ascended into law manufacturers will have 18 months to comply. First in line product groups include textiles and steel products, for which delegated acts are in preparation for 2026, such that by 2028 manufacturers of these products will be required to have a Digital Product Passport in place.  

Expected product groups for which products need to have Digital Product Passports to be sold on the EU market based on EU regulation in the 2028-2033 period include: 

• Iron, steel and aluminium products,  
• Textiles incl. garments and footwear, furniture,  
• Appliances, electronic products, IT products, other energy using products. 
• Mattresses, tyres, toys*. 
• Chemical products, detergents, paints and varnishes, lubricants,  
• Construction products**  

Specific timelines for each product group will be set in the EU commission working plan to be published by 19 April 2025.   DPP requirements for further product groups are expected over time such as for ceramics, glass, pulp & paper and plastic products.  

* Based on the revised EU toy safety regulation that is under negotiation by the EU institutes.  **Based on the revised EU Construction Products Regulation. 

 The DPP forms a new instrument from the EU government that links to different regulations where communication about products is required mandated by law. Already a few additional  specific regulations under negotiation stipulate that in the future DPPs will need to be used to communicate specific product requirements through certificates, product characteristics information, or other documentation. This makes DPPs an overarching instrument to prove product regulatory compliance in the EU market.  

Three existing examples of regulations that will impact future DPP information declaration needs include:  

• The EU Green claims directive, still under negotiation, requiring substantiation of environmental claims and new labelling requirements. 
• The EU Critical Raw materials Act, requiring publication on whether a product contains a battery and if so what material type. 
• The EU Directive on the Repair of Goods, requiring manufacturers to make available information on the obligation to repair and repair services.