Essential requirements for the Digital Product Passport (DPP)
Practical. Uniform. SME-friendly.
26 November 2025
Initial situation
Digital Product Passports (DPP) enable the digital recording and provision of product-related information along the entire value chain. This makes them a strategic tool for the desired transition to a circular, digital and resilient economy at both European and national level. At the same time, they open up new opportunities for companies to develop sustainable business models, strengthen their innovative power and competitiveness, and offer solutions for the availability and transfer of harmonised digital data.
In order to fully exploit this potential, the requirements of the economy must be taken into account. Practical and business-compatible solutions are needed that are particularly feasible for small and medium-sized enterprises (SMEs).
From the industry's point of view, the following basic requirements must be taken into account for the successful implementation of digital product passports:
1. Interoperability and technology neutrality – DPPs must be set up in an iterative process to be horizontally interoperable, adaptable to specific sectors and technology-neutral so that they are internationally compatible.
2. Added value and industry integration – the information contained in DPPs must offer clear added value (e.g. optimisation of the circular economy, support for lead markets) and ensure compatibility with Industry 4.0 requirements
3. User acceptance – DPPs must build trust among end users so that they promote differentiated and sustainable purchasing decisions in line with the Green Deal. Data that is no longer required should be able to be deleted from the DPP
4. Regulatory consistency and standardisation – existing legal requirements must be taken into account to avoid incompatibilities, and all regulations requiring DPPs should refer to the technical structure of the ESPR's DPP system.
5. Reducing bureaucracy and increasing efficiency – Simple and unbureaucratic enforcement of the legal requirements for DPP is essential for effective market surveillance and reducing administrative burdens.
6. Data scope and support for SMEs – The scope of mandatory data in the DPP must remain economical and commercially viable. Companies that can prove that they do not receive data from suppliers in third countries – and are therefore unable to meet their obligations – should not be penalised
7. Data protection and access rights – Data security in accordance with EU requirements must be guaranteed. Intellectual property rights (IPR) must be taken into account
In 2027, the first mandatory DPP in the EU will come into force under the Battery Regulation However, the central legal basis for the widespread introduction of digital product passports will be the EU Ecodesign Regulation (ESPR), which came into force in 2024 and provides for the mandatory introduction of DPPs for a wide range of product groups
The specific product-related requirements for the design of the DPP will be laid down in delegated acts under the ESPR. These are intended to ensure that the specific characteristics of individual product groups or categories are taken into account appropriately.
In addition, a mandatory DPP is included in the Commission's proposal for the new EU Toy Safety Regulation (TSR). Outside the ESPR and TSR, the DPP is also increasingly being incorporated into proposals for European legislation, reports and dossiers in the context of the twin green and digital transitions, such as:
▪ the EU's Critical Raw Materials Act;
▪ the evaluation report on the New Legislative Framework (NLF);
▪ the European Union's customs reform;
▪ EU regulations on batteries;
▪ the H2 Global & Hydrogen Europe Policy Brief;
▪ the reform of the EU Textile Labelling Regulation;
▪ the EU Detergents Regulation.
Currently, many DPP activities are running in parallel and are not sufficiently coordinated, even at international level. This inefficient approach jeopardises the actual goal of the DPP, which is to enable a circular economy, and threatens to cause high costs and effort for companies during implementation, as well as consuming large amounts of resources for enforcement authorities and users. The current status of the ESPR and its implementation roadmap should be communicated transparently and taken into account in the design of the DPP to ensure consistency with ongoing regulatory processes at EU level
Furthermore, there are concerns about inconsistencies in legislation and regulatory overlaps, which could lead to barriers to the free movement of goods in the European single market and in international trade, as well as distortions of competition. Effective coordination of the various regulatory approaches
is therefore urgently needed to ensure the effective and uniform implementation of the DPP and the IT infrastructure for exchanging the data contained in the DPP.
It is therefore to be welcomed that the DPP is being standardised at European level. At the same time, care must be taken to ensure that the requirements of various regulations do not place a disproportionate additional burden on companies. Such unilateral obstacles would undermine the international competitiveness of European companies and call into question the objectives of the DPP. The economic actors concerned should therefore be closely involved in the further regulatory processes for implementing the DPP. In addition, the amount and type of data to be disclosed in a product passport must be clearly and concisely defined. It is imperative to ensure that company secrets are protected and that no company- or product-related information can be leaked to unauthorised third parties through a DPP.
Liability issues must also be clearly regulated. For example, economic operators in the downstream value chain should not be held liable for missing, incomplete or incorrect mandatory information from upstream production stages. Rather, those subject to the information obligation must ensure the accuracy of the data transmitted.
Key requirements for the DPP
By taking a leading role in shaping the EU DPP, German industry has the opportunity to strengthen its competitiveness in the medium and long term
To ensure that the DPP is perceived as an advantage rather than a burden, manufacturers – as the central source of information – must be involved and supported at an early stage. The DPP should meet the following horizontal requirements, which can be supplemented by sector-specific regulations:
1. Interoperability and technology neutrality
▪ The DPP must be horizontally interoperable, adaptable to specific sectors and technologyneutral. Existing, well-established standards should be used.
▪ The implementation of a DPP is an iterative process that should be continuously developed in order to take into account customer and user experiences, as well as technological developments and regulatory requirements.
▪ A technology-neutral approach is particularly necessary within the framework of the New Legislative Framework (NLF)1 in order to ensure semantic and technical interoperability between the various regulatory areas and to guarantee connectivity to international digital systems.
1 On the one hand, essential requirements are specified in the text of the law in the form of "protection objectives"; on the other hand, technical measures are specified to fulfil these protection objectives through the application of harmonised European standards (hENs).
2. Added value and industry integration
▪ The information contained in the DPP must offer clear added value – e.g. for optimising the circular economy, determining the carbon footprint or increasing efficiency in product data management. This added value must be the subject of discussion between standardisers and affected economic actors, whose criteria should be adapted to new technical conditions, for example.
▪ The DPP must be able to incorporate voluntary and additional information from manufacturers in a structured and standardised manner in order to offer added value beyond EU regulatory requirements.
▪ With "DPP 4.0 – the Digital Product Passport for Industry 4.0", industry associations and companies have presented a highly advanced implementation of the DPP concept and are currently working on the content of the DPP in publicly funded Manufacturing X consortia. This concept is based on international digital industry standards (e.g. Asset Administration Shell according to IEC 63278 series and Digital Nameplate / ID-Link according to IEC 61406-S series) and can be a model or at least a permissible option for the implementation of the DPP in the relevant legislation in the EU.
3. User acceptance
▪ The acceptance of the DPP by end consumers depends largely on its form and content. A standardised proposal, harmonised at least across the EU, is necessary to build trust and promote differentiated and sustainable purchasing decisions in line with the Green Deal.
▪ In order to limit the costs of the DPP service provider system, a large number of DPP service providers should be allowed to operate in the EU market in order to promote competition. Therefore, qualified service providers from all regions should be approved and third-party certification should be avoided.
4. Regulatory consistency and standardisation
▪ The technical structure of the DPP system is being developed as part of the standardisation mandate of the Ecodesign Regulation. In doing so, the ESPR guidelines should be followed and issues that are to be regulated in a delegated act and are not yet legally required should be kept out of the standardisation process. All regulations that require a DPP should refer to the technical structure of the ESPR's DPP system.
▪ The regulated content, i.e. the DPP data, may vary between product groups and legal acts. Nevertheless, it is fundamentally important that cross-sector vocabularies and sets of rules are defined, e.g. when it comes to calculation methods for CO2footprints, criteria for recyclability or data relationships This is to ensure that not every (partial) regulation or use case follows its own definition or calculation method and that the necessary comparability of data is guaranteed
▪ Existing legal requirements must be taken into account in order to avoid incompatibilities. This applies in particular if these occur during a transition phase, even if a subsequent adjustment of other legal regulations is planned
▪ Existing data sources and processes, such as safety data sheets or REACH requirements in the chemical industry, should be used as a basis for implementing the information transfer required by the DPP. The use of such standards facilitates compliance with the requirements, reduces effort and ensures consistency – a principle that can also be applied to other industries.
5. Reducing bureaucracy and increasing efficiency
▪ The mandatory information requirements in the DPP are intended to limit the effort involved and be accepted by authorities and industry in order to avoid parallel requirements and bureaucracy and enable a standardised and harmonised DPP approach.
▪ Paper-based product documentation should be reduced to a minimum as part of the introduction of the DPP. Future regulations should focus on paperless, machine-readable formats that can be converted into human-readable form if necessary.
▪ Simple and unbureaucratic enforcement of the legal requirements for the DPP is essential for effective market surveillance.
6. Data scope and support for SMEs
▪ The scope of mandatory data in the DPP must remain economical and commercially viable, especially for SMEs and small-batch production (e.g. batch size 1).
▪ SMEs should be supported through financial incentives, technical assistance and open-source tools to facilitate entry and minimise administrative burdens.
▪ Data must be better bundled to enable data integrity. Duplicate data storage with regard to existing databases such as SCIP and EPREL should be avoided. Instead, interoperability and suitable interfaces are needed to enable automatic and machine-readable verification of existing databases with the Digital Product Passport ( ).
7. Data protection and access rights
▪ Data security must be guaranteed in accordance with EU requirements. Intellectual property rights (IPR) must be taken into account.
▪ In line with decentralised data storage, product-related information is not stored centrally but remains with the manufacturer. A unique identifier on the product (e.g. QR code) refers to the corresponding DPP in the respective data source.
▪ The "need-to-know" principle should be defined along the value chain in order to ensure transparency, copy protection and sustainability in the market. At the same time, recycling companies need sufficient information about ingredients and composition to ensure efficiency and quality for the collection, separation and production of circular raw materials in the circular economy. In order to meet all legitimate interests here, clear digital processes for access authorisation are required.
Imprint
Federation of German Industries (BDI)
Breite Straße 29, 10178 Berlin www.bdi.eu
T: +49 30 2028-0
German Lobbying Register number R000534
EU Transparency Register: 1771817758-48
Editorial Office
Franz-Josef von Kempis
Environmental Technology and Sustainability Officer v kempis@bdi.eu
Annika Stuckenhoff
BDI Circular Economy Initiative Advisor a.stuckenhoff@ice.bdi.eu
BDI document number: D 2202