The latest from the EU when it comes to DPP
Apr 29, 2026
Digital product passports are coming but what do you need to put in yours, when do you need to have them ready and what other details do you need to know? Here’s the latest from the EU on DPP to keep you briefed.
The latest on digital product passports - April 2026 Please read way down for the background to DPP. We will keep adding new information to this post as the EU comes out with updates. April 2026
The EU has now published a ‘methodology’ for defining data requirements for digital product passports. What does this mean?
They have basically come up with a way, or method, to decide what should and shouldn’t be in digital product passports. See it as a kind of roadmap to help you understand how they are thinking and how they will come up with ‘delegated acts.’ The ‘delegated acts’ will be definitive (hopefully) requirements for a digital product passport, but for now, we have the method to get us there.
The EU document is 120 pages. It’s unentertaining text. I mean, they’re not trying to win a Booker prize with this. But despite the dryness, there’s a lot of good information there. Here’s our take.
Pragmatism rules the day To boil it down into one sentence, the EU is saying that we need to be pragmatic about this. For example, should have DPP’s on a model, batch or item level? The view is that it will depend on the product and on what’s feasible. If the cost for itemisation is too high, then we shouldn’t do it. If there’s no real benefit in going to item-level, then we shouldn’t do that either. Common sense should prevail. This is the same for all other parts of digital product passports. How much detail do we need about suppliers in a digital product passport? The answer for them is to look at what will give the most benefit to consumers or recyclers or other stakeholders. If more detail won’t help, then don’t go there. If more detail is not worth the effort, then don’t do it.
Find a common language
The EU realises also that we need to agree upon some definitions so that a consumer can easily compare one product with another for example. Let’s find a common language.
Include user manuals, safety instructions etc
This is now clearer than previously. If you’ve got a user manual or installation instructions etc, then you need to put this into a DPP. Anything that can extend the lifetime of a product should be there and these kinds of documents can do that. There’s a commercial benefit here too as it could mean that you don’t have to print out user manuals in 20 languages anymore if all that information can be available digitally on a DPP. We do this today at Kolla and we’re saving companies a lot of time, headache and money with this.
How to go about it The crux of the document is the methodology itself. How should you go about figuring out what’s needed for a DPP.It’s broken down into four key areas A: Scope & context The point is that you should clearly define what you believe all your various stakeholders would need from a DPP and work from there. What will a consumer need to access? How much information is the right information? What would a recycler need when the product has come to the end of its life? But also add in there what information do we already have to disclose by law and what are current industry practises etc. Scope it and set objectives.
B: Identifying use cases and data needs – and then prioritising and classifying those needs. So, if we’ve set the scope, then look at the use-case. Go through the various ‘What happens if?’ scenarios. ‘What happens if a person wants to sell their leather jacket?’ And start working it out from there. What needs to be possible on the digital product passport for that to succeed? What sort of granularity will be required etc?
C: Design & development – This is where you actually set the level of granularity, look at the common languages being used, specify exactly what data will be in there, who can access what. The EU is pretty pragmatic here also. Is this information easy enough to collect? Is it worth spending a lot of time and money going into deeper levels of detail regarding your suppliers? Will it help consumers, recyclers? Or will it cost more than it’s worth? Is there data that is too sensitive to share?
D: Validation & consultation – Validate your design and get feedback from your stakeholders. For example, you’ve gone through a use-case about helping a person learn how to repair their own clothes using an AI-tool. This stage is where you actually check if this is possible and if not, then you need re-design your digital prpodut passport.
Summary
The report summarises everything nicely by saying that they are looking at this with the ‘broader legislative logic’ in mind. In other words, not at the nitty gritty details but understanding what we’re trying to achieve with DPP and going from there. They also talk about a progressive ‘evidence-gathering’ process. In other words, digital product passports will evolve as time goes on. See this as the EU’s blueprint for how they are going to create delegated acts. With that in mind, this gives us several useful insights. DPP is coming!
THIS SECTION BELOW IS THE BACKGROUND TO DPP AND THE EU'S THOUGHTS PRIOR TO MARCH 2026 Background to DPP – how did we get here The short background is that in 2019, the EU came up with the ‘European Green Deal’ with the aim of making the EU a net-zero emissions territory. They also wanted to ensure a fully circular economy (where everything gets used again and again and again), eliminate pollution, boost competitiveness and ensure the green transition happens in a fair way for everyone. No pressure then!
Let’s focus on one of those lofty goals – making the EU fully circular. To achieve this, they came up with the CEAP (circular economy action plan). Within CEAP are a series of laws and regulations and one of those is called ESPR (the Ecodesign for Sustainable Product Regulation). And within ESPR, we’ve got DPP, the Digital Product Passport requirement. The ESPR legislation describes a digital product passport as a way to ‘electronically register, process and share product-related information amongst supply chain businesses, authorities and consumers.”
Here’s what we know so far about DPP The latest information came in April 2025. The EU published their ‘Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030’.The plan shows that the EU wants to replicate the success of the Energy Labelling Framework. You know those signs on the side of the cookers and other kitchen appliances in the electronics store that give you an indication as to how energy efficient the product is? The goal with ESPR is to do the same but to cover a range of sustainability factors.
The Energy Labelling has, according to the EU, led to a 12% reduction in final energy consumption in 2023*, more than the combined final energy consumption of Belgium and the Czech Republic. *https://environment.ec.europa.eu/document/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en - page 4 In the same way, the EU wants digital product passports to give sustainable brands an edge and force other brands to follow suit by making sustainability information clear and transparent. Now, what exactly is in a digital product passport? This is what we don’t know exactly but the EU is promising clarity by the end of 2025 or early 2026, at least for a few industries. It’s a complex one since one industry is going to have different criteria to measure and highlight than others.
What they have said in the April 2025 working plan is they are looking at Product performance categories such as durability, availability of spare parts, minimum recycled content etc, as well as Product information categories such as key features, carbon footprint etc. In previous documents, the EU has included specific information such as
- Product identification number
- Transparent information on the entire product lifecycle. This includes where the raw materials come from, where it was manufactured, how it was transported and what to do with the product at the end of life such as repair or recycling opportunities.
- Care information helping customers know how to extend the lifetime of the product
The EU did a study, released in June 2024 highlighting sixteen possible criteria to be communicated in a digital product passport for the fashion industry. These exact criteria, which we hope to see in late 2025/early 2026, are referred to by the EU as ‘delegated acts.’Watch this space.
What industries are effected by DPP? In the April 2025 working plan, six industries were highlighted as top priorities. There are four ‘final products’ (products that you and me can buy in a store down the road) and two ‘intermediate products’ (products that are used to make those final products).
What is the timeline?
For all the areas above, the EU has stated in the ESPR Regulations (which were set in June 2024) that there would be an 18-month window to get everything in order. So, if the EU say January 2027, then they mean that everything needs to be live and ready by mid 2028. But it also means that you should really be up and running as early as possible in 2027 and ensure you’re compliant and then start seeing how you can refine and improve your digital product passports to make the most of them. These are the dates that they’ve set so far in the April 2025 working plan. The final products:
- Textiles/apparel - 2027
- Furniture - 2028
- Tyres - 2027
- Mattresses - 2029
Intermediate products
- Iron & Steel - 2026
- Aluminium - 2027
What else do I need to know?
When it comes textiles and apparel, footwear is not included but has instead been put into a separate category “due to the distinct use of materials, product functionality and supply chains.” But a study will be commissioned to evaluate the potential to improve the environmental sustainability of footwear under the ESPR and will be completed by the end of 2027.
Chemicals was a highly ranked area before and expected to be one of the early industries to need DPP’s but it’s also very complex and has been given more time as a result. A study is being done at the end of 2025 to define more precisely the potential chemicals in scope and potential focus areas to be included. Stay tuned here. We’ll be keeping a close eye on developments and publish any news as it comes in. Get in touch if you want to start your DPP journey today. We’re working closely with several PIM suppliers to provide a full end to end DPP solution.