As we continue to look into the EU Ecodesign for Sustainable Products Regulation (ESPR) requirements, one question that remains on top of many's minds is, "What are the data requirements for the Digital Product Passport (DPP)?"
While we wait for the details to be finalized, the working group from the Trace4Value DPP prototype project, which included TrusTrace, GS1 Sweden, Kappahl and Marimekko among others, have strong indications of what they will be. This chapter provides an overview of the DPP data requirements. For a deep dive on DPP, get the playbook.
background
Introduced under the EU Ecodesign for Sustainable Products Regulation (ESPR), the Digital Product Passport (DPP) is a critical enabler for ensuring that the most relevant product data for circular value creation across value chains is readily available. While the Ecodesign framework sets the scope and motivation for product design, the DPP answers what data is stored and how to make data accessible to continue its longevity in the value chain. The access to this data is typically delivery via a QR code or barcode on the product. Its implementation will be mandatory for all products covered by Delegated Acts:
The Requirements
The DPP must:
- Be linked to a unique product ID and meet ISO standards
- Have a physical data carrier on the product, packaging, or documentation
- Use a machine-readable, searchable format
- Follow defined detail levels (model, batch, item)
- Ensure interoperability, security, and privacy
Your DPP program will have to cover the three primary components:
- DPP data: data about the product, which must fit the scope, definitions and standards set for DPP
- A unique identifier for each product (its digital fingerprint) that can be accessed via a data carrier
- Built IT systems with architecture to facilitate data interoperability
DPP Data
DPPs serve as the digital identity of each product, encompassing details about the brand responsible for its creation, the manufacturing process, the materials used, care instructions, and its potential for circularity - from repair and reuse to disassembly for recycling. Additionally, the DPP will contain information on environmental impact and compliance with chemical regulations.
The Delegated Act will specify:
- Required information (e.g., product ID, compliance docs, manuals)
- Data carrier type and placement (e.g., QR code)
- Level of detail (model, batch, item)
- Access permissions and update rights
- How long the DPP must remain available
125 Data points predicted
During the Trave4Value project where TrusTrace was part of a DPP pilot, the project team determined 125 different data points. Not every single data point is new, meaning that brands are already collecting some them as part of existing requirements or standards like the EU REACH list and Ecodesign parameters. These are simply being integrated into the DPP, therefore many of the likely data points have been identified with high confidence. Others points will be legislated through the anticipated Delegated Acts.
Experts from the working group confirmed during a live panel on the DPP that the main discourse is not on the data points at this point. Instead, the ongoing debate is now around the DPP system and technical requirements.
See the list of 125 datapoints in the Data Protocol: Download the report with the data protocol.
Unique Identifier
According to ESPR guidelines, each product must possess a distinct identifier known as a persistent unique product identifier. This unique identifier must also be permanently attached to the garment as it will contain the data needed to activate its circularity. It is typically a serialized Global Trade Identification Number (GTIN) in accordance with the GS1 Standard, and ensuring comprehensive traceability. Irregardless of the carrier, it must be machine readable and in the Unlocking DPP playbook we have shared several formats, although there is high confidence that a QR Code could be defined as the main carrier.
DPP Registry
The European Commission will maintain a registry of all DPPs, but the inputs are submitted and updated by companies selling products in the EU.
What about Blockchain?
The DPP framework states that data can be made available via a data carrier but there is no mention of blockchain as a requirement for managing the data integrity. Instead, when it comes to data availability, the ongoing discussions are around whether there is need for a centralized backup solution, an EU registry, to ensure availability.
Labelling
Delegated acts may require a label with specific information, layout, and electronic options for generating labels. If no label is required, products cannot display misleading labels similar to EU-mandated ones.
it Systems
ESPR outlines the access privileges for each stakeholder when it comes to data accessibility. While consumers are limited to accessing public data, regulatory authorities have the ability to delve deeper into the Digital Product Passport information. These access rights are anticipated to be further elaborated in the upcoming Delegated Acts, scheduled to be finalized by the conclusion of 2025.
In contrast to the clear direction for DPP data requirements, the technical DPP system requirements (comprising the system architecture and the unique identifier) are not as well defined. There are also a lot of questions yet to be answered about data security and management once implemented.
How to get involved
At a local level, companies are collaborating together in local working groups like the Trace4Value project. This allows for field testing of what works or does not work when it comes to data requirements for Digital Product Passports. The active experimenting helps the parties involved in shaping policy understand the reality and obstacles for data gathering and management, for example determining the feasibility of the 125 data points implemented in the project's DPP prototypes.
NEXT CHAPTER: Destruction of Unsold Consumer Products
The next section of requirements under ESPR is the discard of unsold consumer Products. This addition to Ecodesign addresses the waste of valuable resources and environmental impact caused by the surplus of unsold consumer goods in the EU marketplace. Continue to the next chapter.
Or return to the previous chapter on ESPR Requirements: Ecodesign Framework
