Introduction to the ESPR and Digital Product Passports

Companies will need to prepare by assessing supply chains, meeting Ecodesign requirements and adjusting to new material efficiency standards. With its broad scope, the implementation of ESPR goes beyond energy-related products to a wide product scope and will require early adoption strategies from organizations to remain competitive and compliant in an evolving regulatory environment. 

The main objectives of the ESPR are to:  

• Improve the durability, reusability, upgradeability and repairability of products. 

• Make products more efficient in terms of energy and resources. 

• Manage the use of materials that prevent circularity. 

• Increase recycled content. 

• Make it easier for products to be remanufactured and recycled. 

• Set rules on carbon footprint and environmental impact. 

• Make products easier to remanufacture and recycle.

ESPR Timeline 

As of July 18th, 2024, the ESPR has officially come into force. What comes next? Following the regulation’s publication, the Ecodesign Forum was established to consult stakeholders and begin drafting specific Ecodesign requirements for different product groups. The Forum’s first meetings took place in 2025, focusing on setting priorities and developing initial working plans. Over the coming years, additional product-specific requirements will continue to be developed and adopted. See the figure below for an updated timeline showing the key milestones following the entry into force of the regulation.

Scope of the ESPR 

The Directive creates a broad framework for sustainable product design across a range of industries, promoting environmental protection, resource efficiency and the circular economy.  It has an impact on a number of important industry sectors.  

According to the official regulation documents, the Commission will be expected to prioritize certain product groups. These include: “Iron & steel, aluminum, textiles (garments and footwear), furniture (including mattresses), tires, detergents, paints, lubricants, chemicals, energy-related products (including new measures and revisions of existing ones) and ICT products, as well as other electronics.”  

The framework allows for the progressive inclusion of other product groups as priorities evolve, although not all sectors are explicitly mentioned. This could eventually extend to products such as packaging materials, chemicals, and vehicles, if these are deemed necessary to achieve the goals of the circular economy. 

Products aside, which economic operators are affected along the value chain? 

• Manufacturers (the company marketing the product in their name or trademark) act as the main duty holder, having the most detailed knowledge of the design and production. They have the responsibility of documentation, creating a digital product passport and conformity assessment. If a manufacturer is not located in the EU, it may appoint an EU authorized representative, who then reports to the EU regulators.  

• EU importers then place the product on the Union market, having limited responsibility besides reporting to national authorities.  If, however, a product manufacturer does not operate within the EU, it is the responsibility of EU importers to ensure that the products they place on the EU market comply with the Regulation and to ensure that a digital product passport is available.   

• Distributors and dealers are then the main economical operators, making the product available on the Union market, thus having the responsibility of acting according to requirements and to ensure that the end-customer of the product has access to the product’s lifecycle information.  

What is a Digital Product Passport? 

The Digital Product Passport (DPP) is a key component of the ESPR and is designed to improve the transparency and traceability of a product throughout its entire life cycle. The DPP, with specific requirements set by delegated acts, will be mandatory for several product categories.  

All information included in the DPP should be product group specific and will be determined according to the delegated act procedure. Product information can include relevant information on technical performance, environmental performance, circularity performance (durability, repairability, etc.), regulatory compliance, product-related information (e.g. manuals). On top of information regarding sustainability, the passport requires four unique identifiers: product identifier, economic operator identifier, facility identifier and lastly registration identifier, which is not for the public. 

As said, this information should be uniquely linked to a product and easily accessible through data carriers such as QR codes, leaflets, or URLs that are included with the product. It is possible that the passport is split to three levels of granularity: model, batch and item, some of the assigned data can be public and some restricted.  

One of the main functions of the DPP is to improve resource management and to simplify the sustainable decision making of different actors, such as consumers, repairers, recyclers and waste handlers. By providing a complete view of a product's value chain, DPPs will help companies engage with suppliers, improve sourcing strategies, and mitigate environmental and social risks throughout the supply chain.

Interested in the progress already made on digital product passports? Explore our Digital Battery Passport project with AVL here.

Creating greater product traceability 

The ESPR has a strong emphasis on data transparency and traceability in support of product sustainability and circular economy objectives. By providing a digital record of each product, detailing its lifecycle, composition and environmental impact, the introduction of the Digital Product Passport plays a central role in this effort.  

The DPP will create a system that ensures full traceability of products throughout their lifecycle, from production to end-of-life disposal in order to support end-to-end product sustainability. The passport will trace and record all the key stages in the life cycle of a product - including: 

• Raw materials sourced to ensure ethical sourcing. 

• Manufacturing process, which includes energy consumption and environmental impact. 

• Details of repairability and serviceability. 

• End of life paths, such as disassembly, recycling or potential for re-use. 

• CO2 emissions throughout the product’s lifecycle. 

This list also includes closure of Substances of Concern (SoC) from manufacturers, these substances are defined by the ESPR, and it particularly focuses on substances that affect product recyclability or health. (Source)

The ESPR is aiming to reduce the overall carbon footprint of products sold in the EU and ensure alignment with the Union's 2050 climate neutrality targets by accurately tracking CO2 emissions. Overall, all tracking helps identify and eliminate inefficiency, reduce waste and promote more sustainable operations.  

Digital Product Passport requirements and registry 

The Digital Product Passport will play a critical role in regulatory processes. The planned passport will have a DPP registry, which authorities can rely on when verifying delegated products, a searchable web portal for an accessible way to find the DPP, and all standards related to IT architecture, such as unique identifiers, data processing, data exchange protocols and formats, data storage, archiving and persistence, data authentication, reliability, integrity, APIs for DPP lifecycle management and searchability, unique identifiers, data carriers and links from physical product to digital representation, access rights management, information security, business confidentiality and interoperability (technical, semantic, organizational). 

Integration with existing and future regulations 

Batteries are the first product group for which the use of a Digital Product Passport will be a legal requirement as of 2027, as set out in the EU Battery Regulation. This passport will include raw material sourcing, composition, environmental impact and recycling data, as well as detailed information on the battery's life cycle.  

And while the battery passport is a separate regulation under the Battery Regulation, its implementation has a role for other product categories’ passports that will follow under the broader scope of the ESPR. This shows that, while maintaining a consistent framework under the ESPR, the content of the DPP is tailored to the specific sustainability and transparency needs of different industries. 

Improving re-use and recycling opportunities supported by the Digital Product Passport 

The DPP will be a key tool for improving re-use and recycling opportunities, including information such as: 

• Disassembly instructions: Manufacturers will be obliged to provide detailed instructions on how to disassemble a product. This should make it easier for repairers or recyclers to recover used product materials or components for reuse or recycling.  

• Product health analysis: The analysis could contain data on the wear and tear of certain components, allowing refurbishers to determine whether products can be reused or remanufactured rather than discarded. 

• Repairability assessment: To help consumers and repairers better understand what can be repaired and at what cost, some products will include indicators of their repairability. 

In support of the EU's Circular Economy Action Plan, the ESPR will help ensure that products have longer life cycles and generate less waste by promoting better reusability and recyclability  

Digital Product Passport: Key to competitiveness 

As manufacturers are required to track more and more details throughout the supply chain, ESPR, the Digital Product Passport and its regulatory changes should be seen as something that helps companies stay competitive, not something that slows them down. 

One of the key objectives of the ESPR’s passport is to provide standardized sustainability information across the product lifecycle. This transparency will, as mentioned, enable both consumers and businesses to make more informed decisions based on a product's environmental impact, resource efficiency and sustainability performance. As a result, a competitive advantage in the marketplace is likely to be gained by companies that prioritize sustainability. 

In addition to reducing waste and carbon footprints, staying competitive through sustainability has many long-term benefits for an organization. Once given more buying power with product details, consumers have the option to become more environmentally conscious, offering transparent and sustainable products will be critical for brands to gain market share.  

And as the DPP makes it easier to compare products, consumers may increasingly choose those with a reduced environmental impact, forcing companies to innovate and reduce the carbon footprint of their products. 

Companies that rely on sustainable supply chains will also benefit from standardized sustainability data. Companies with sustainable procurement goals can use the product passport as a verification tool to show the environmental credentials of their suppliers, encouraging a shift towards greener partnerships. 

Additionally, compliance with ESPR and other related environmental regulations will soon be non-negotiable. When failing to comply, companies could suffer not only legal but reputational risks and be overtaken by competitors who choose to adopt sustainability standards. 

The role of data security 

Data security will be a critical part of ensuring compliance and presenting accurate sustainability data, both of which are essential for reporting and market access. The DPP will contain an immense amount of data and securing it will mean that a company is not only compliant with ESPR, but also protected from significant business risks. 

In particular, as the data included in the DPP will need to be calculated and reported throughout the life cycle of the product, companies will need to be confident that this data has not been tampered with throughout the data lifetime. Calculating CO2 emissions, material efficiency, and other sustainability metrics are critical for product certification and market access; companies can comply, but can the collected information be trusted? 

Any compromise in data security could lead to inaccuracies, re-evaluations or even regulatory violations, impacting on a company's ability to sell in the European market. Therefore, having the right data protection solution in place that can prove the integrity of the digital product passport data not only saves the company time and effort, but also protects the company from potential legal consequences associated with reporting inaccurate or false information. 

Ensuring the security of data in the DPP is key to avoiding any potential consequences. This requires implementing data integrity verification, secure data transfer protocols, and maintaining regular audit trails to monitor how information is used and shared throughout the supply chain. These measures prevent data tampering, ensuring the integrity of compliance data is maintained throughout the product's entire lifecycle. 

In an ESPR context, DPP data security is not just about securing information - it is about ensuring compliance, maintaining market access and avoiding costly consequences.

What happens in the event of non-compliance? 

EU Member States are responsible for establishing appropriate penalties. These sanctions may range from fines to exclusion from government procurement. Additional measures may include forced product recalls or even criminal charges, according to the degree of non-compliance.  

At the same time, the ESPR also empowers consumers to bring civil actions against producers (or those responsible for placing the product on the EU market) who fail to comply with the requirements. This could lead to additional financial liabilities and reputational damage, especially in the case of class actions leading to additional financial losses, underlining the importance of ensuring full compliance with the ESPR standards. 

Specific non-compliance measures have yet to be specified. But once defined, EU Member States must adopt a plan for market surveillance to enforce the ESPR, specifying the type and number of inspections planned within their jurisdiction. 

Preparing for ESPR’s Digital Product Passport 

As ESPR approaches, companies need to start preparing for compliance, particularly with the coming Digital Product Passport requirements. Timelines for compliance vary by product type and industry, but early preparation will ensure a smooth transition and avoid disruption. 

As mentioned, some industries, such as the battery sector, already have clear compliance timelines under the Battery Passport regulations. These early applications of the Digital Product Passport pave the way for other product categories when the time comes. Sectors that will be later affected should start preparations early, starting with understanding the requirement details and tailoring their processes accordingly. Preparing now can help secure a competitive advantage, even if your business is not immediately affected by ESPR. Important steps that companies can take include: 

• Product-level data management: The establishment of a strong foundation for product-level data collection and asset management will be critical. This includes the tracking of key metrics such as carbon footprint, material usage, product performance, and life cycle data. 

• Digital twin technology: Companies can store and manage the data required by the DPP by creating a digital twin for each product that mirrors its physical lifecycle. Digital twins provide real-time data that can feed into the DPP and help companies meet evolving sustainability requirements. 

• Interoperable architecture: Companies should design an architecture that ensures interoperability between their internal systems and broader data ecosystem services to streamline the DPP data integration with 3rd party platforms/tools and DPP frameworks. 

• Data security through notarization: To protect the integrity and authenticity of DPP data, companies should implement data security measures such as notarizing data. This ensures that the data remains unaltered, safeguarding it from unauthorized modifications and verifying its authenticity throughout the product’s lifecycle. 

As companies prepare for future regulations and the growing demand for sustainable products, it is critical to have a secure and future-proof foundation for product-level data management and integration. Tributech offers a robust solution for secure data integration from various sources, including IoT, OT, and IT systems. This integrated approach enables the secure collection, verification, and exchange of data, ensuring that businesses can confidently manage product-level information across their entire lifecycle. By leveraging Tributech's technology, companies can build a flexible and reliable infrastructure that supports sustainable innovation and prepares them for the evolving demands of the digital product landscape. 

Get in touch with Tributech to learn how our data notarization and integration technology can help your business create a strong, future-ready data management foundation.