The Digital Product Passport (DPP) is no longer a future topic for industrial R&D. It is now a regulatory reality and will gradually apply to more product categories. For companies in materials development, the question is whether their existing data infrastructure can meet the requirements.
In most cases, the honest answer is: not yet. The data foundation required for the DPP does not exist in many laboratories in a form that enables structured data exchange.
This article explains what the DPP means in practice, when it applies to which industries, and why it is not simply an IT question for R&D departments.
What is the Digital Product Passport?
The Digital Product Passport is a standardised digital document that records and provides access to product-related information across the entire lifecycle. Its aim is to create transparency for manufacturers, authorities, customers, and recycling companies across the full value chain.
Typical information in a DPP includes:
- Material composition and raw material origin
- Carbon footprint and environmental impact
- Information on recyclability and end-of-life
- Testing and conformity documentation
- Maintenance and repairability guidance
The regulatory basis is the Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781), which entered into force on 18 July 2024. It replaces the previous Ecodesign Directive and extends its scope to cover virtually all physical goods placed on the EU market.
Timeline: Who is affected, and when?
On 16 April 2025, the European Commission adopted the ESPR Work Plan 2025–2030, setting out the first product categories for which product-specific ecodesign requirements will be developed. These requirements may also include the DPP. The first mandatory requirements, however, come from the Battery Regulation (EU 2023/1542): from 18 February 2027, DPP requirements become mandatory for industrial and traction batteries, as well as batteries for electric vehicles.
The ESPR Work Plan 2025–2030 also covers further product categories:
- 2026–2027: Iron & steel, displays, washing machines
- 2027–2029: Textiles, tyres, furniture, mattresses
- Mid-term review 2028: The Commission will assess whether additional product groups should be included, among them chemicals.
Paints and coatings are not included as a priority product group in the first ESPR Working Plan for 2025–2030. Coatings and adhesives are not explicitly addressed as separate product groups; depending on the product, they could be classified under paints and coatings, specialty chemicals or other sector-specific legislation in the future.
For the broadly defined “chemicals” product group, including potential overlaps with polymers, plastics and specialty chemicals, the European Commission announced that a scoping study would be launched by the end of 2025.The study is intended to identify potential product groups and areas for improvement that could be addressed through future ESPR measures and considered during the 2028 review of the Working Plan or in a subsequent Working Plan.
As of August 2026, neither a final report from this specific study nor an official timetable for its publication is publicly available. The next scheduled review point is the review of the Working Plan in 2028. In the meantime, companies in the affected sectors can use this period tos ystematically develop their product and supply-chain data infrastructure.
Technical infrastructure: The foundations for the Digital Product Passport are largely in place. The key standards have been adopted, and the central EU registry went live on 20 July 2026. For companies, this means the focus is shifting to making the required product and materials data available.
Why the DPP is not simply an IT question for R&D
Treating the Digital Product Passport as a software problem means underestimating where the real challenge lies.
Creating a DPP is not technically complicated when the data exists. Where data is missing or not centrally available, the process becomes difficult to scale. In most industrial R&D departments, a structured, connected data foundation does not yet exist.
The reality in many laboratories today:
- Formulation data lives in spreadsheets whose version history no one fully tracks.
- Testing and analytical results are scattered across shared drives, local databases, and in some cases still on paper.
- Process knowledge, such as why formulation B replaced formulation A, which raw material batch produced which result, often exists only in the minds of experienced staff.
In practice, three gaps most frequently block DPP implementation:
- Missing traceability: No documentation of which raw material batch was used in which formulation.
- No audit trail: Changes to formulations or processes are not systematically recorded.
- Isolated data silos: Material, process, and test data exist in separate systems with no structural connection.
These problems already hamper development teams today. They also make creating a Digital Product Passport almost impossible to do reliably.
The difference between compliance and data infrastructure
The strategic question is how companies choose to respond. Treating the DPP as a compliance project means building a one-off system that populates mandatory fields, exports documentation, and satisfies regulatory requirements. That is a legitimate approach, but it is resource-intensive, fragile, and difficult to maintain, because the underlying data structure has not developed alongside it.
Treating the DPP instead as an opportunity to rethink data infrastructure delivers two benefits:
- Short-term: Development teams find information faster. Experiments are not repeated because results are readily accessible. Decisions are based on data, not on memory.
- Medium-term: DPP compliance becomes a structured output of existing data processes. New regulatory requirements can be met with less additional effort.
This is the idea behind what we call Material Intelligence: the systematic connection of formulation data, process data, and analytical results within a coherent, usable structure. AI plays a central role but only once the data foundation is sound. An AI operating on fragmented data does not produce better decisions. It produces faster answers on a poor basis.
Building DPP readiness: Four steps
The most common mistake when starting out is attempting to achieve too much at once. DPP preparation becomes manageable when the scope is clearly defined from the outset.
- Inventory. Not as an IT audit, but as a content question: what information do I need for a DPP, and where can I find it today? Relevant data categories include: raw material information, formulations and recipes with version history, test and measurement results, process parameters, and decision documentation.
- Prioritisation. Not all data carries equal weight. For the DPP, the priority is likely to include material composition, raw material origin, and conformity documentation. These mandatory fields can be identified without restructuring the entire data landscape.
- Creating structure. Formulations, process data, and test results must be linked. A test result that is not connected to the corresponding formulation and raw material batch is difficult to use reliably for the DPP. This is not a platform question, it is a data model question.
- Ensuring traceability. A DPP is only credible if the underlying data are verifiable: audit trails, versioning and clear accountability.
Organisations that address these four steps systematically will be in a position within twelve months where the DPP is no longer a project; it is a function.
Conclusion: The DPP is a trigger, not an end point
The Digital Product Passport is coming: earlier for some industries, later for others. With the DPP registry live since 20 July 2026 and the Battery Passport for certain products mandatory from February 2027, the implementation phase is already underway.
Organisations that treat the DPP as a bureaucratic burden will experience it as one. Those that use it as an opportunity to rethink their data strategy will create something more durable: a data infrastructure that meets DPP requirements and enables development teams to work more effectively every day.
The real value lies in making experimental data directly usable. The Digital Product Passport is the trigger for building that foundation.
Frequently Asked Questions
When does the Digital Product Passport become mandatory?
The first binding DPP obligations apply to certain industrial and traction batteries from 18 February 2027 (EU Battery Regulation 2023/1542). The EU's central DPP registry became operational on 20 July 2026. Further product categories will be addressed through ESPR delegated acts under the ESPR Work Plan 2025–2030; after those acts are adopted, companies generally have a transition period of at least 18 months before obligations apply.
Which products does the Digital Product Passport cover?
The ESPR Work Plan 2025–2030 identifies as first priorities: iron & steel, displays, textiles, tyres, furniture, and mattresses. Paints, coatings, and adhesives are not among the priority product groups in the first work plan; adhesives are not listed as a separate priority category.
What is the difference between ESPR and DPP?
The ESPR (EU 2024/1781) is the regulation, the legislative framework. The Digital Product Passport is an instrument introduced through this framework: a standardised digital document that makes legally required product information available in a structured format.
What data do R&D teams need for the DPP?
The exact data requirements depend on the product group and applicable legislation. For R&D teams, the most relevant data will typically include material composition, raw material origin (with batch reference), testing and conformity documentation, and recyclability information. This data must be linked, versioned, and traceable.
Regulatory information is based on EU legislation as of August 2026. For current information: data.europa.eu