Digital Product Passport (DPP) & ESPR: Product-Level Carbon Data as a Regulatory Requirement

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The Digital Product Passport (DPP) and the Ecodesign for Sustainable Products Regulation (ESPR) together represent one of the most far-reaching shifts in EU product regulation: the move from voluntary sustainability communication to mandatory, verifiable, product-level environmental data. For manufacturers and their supply chains, this means that carbon footprint information — previously a competitive differentiator or voluntary disclosure — is becoming a legal requirement attached to the product itself.

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What is the ESPR?

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The Ecodesign for Sustainable Products Regulation (ESPR), adopted in July 2024, replaces and expands the earlier Ecodesign Directive (which covered only energy-related products). It establishes a framework for setting ecodesign requirements across a wide range of product categories, covering dimensions such as:

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• Durability and repairability
• Recyclability and recycled content
• Carbon footprint across the product lifecycle
• Presence of hazardous substances
• Resource efficiency

ESPR is a framework regulation — specific requirements are set through delegated acts per product category. The European Commission publishes a rolling Working Plan that specifies which product categories will be regulated and in what order. Sectors currently prioritized include textiles, electronics, furniture, iron and steel, aluminium, chemicals, and tyres.

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What is the Digital Product Passport?

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The Digital Product Passport (DPP) is the data carrier mandated by ESPR. It is a standardized, machine-readable record attached to a product (via QR code, RFID, or similar) that makes key product information accessible to consumers, businesses, and authorities throughout the product's lifecycle.

Depending on the product category, a DPP may include:

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• Materials composition and origin
• Carbon footprint (PCF) across defined lifecycle stages
• Recycled content percentages
• Disassembly and repair instructions
• Substance of concern disclosures
• End-of-life treatment guidance

The DPP is not a static document — it is a living data object that can be updated as the product moves through the supply chain and changes hands. It is stored in a decentralized registry system that the EU is currently developing.

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ESPR, DPP and carbon footprints

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For manufacturers, the carbon footprint dimension of the DPP is particularly significant. ESPR explicitly includes Product Carbon Footprint (PCF) as one of the performance parameters that can be regulated under delegated acts — meaning that for in-scope product categories, a verified PCF calculation may become a legal requirement, not just a voluntary declaration.

This connects directly to ISO 14067 and GHG Protocol Product Standard methodology: the PCF embedded in a DPP must be calculated according to a recognized standard and backed by verified CO₂e data at material and process level. The system boundary — typically cradle-to-gate or cradle-to-grave — will be specified in the relevant delegated act.

The EU Battery Regulation is already the most prominent real-world example of DPP logic in practice: batteries above certain thresholds require a digital battery passport including a verified PCF declaration aligned with ISO 14067 — with this obligation in force and expanding progressively through 2026 and beyond.

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ESPR timeline and DPP rollout

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ESPR entered into force in July 2024. The DPP system is being rolled out product category by product category through delegated acts:

• Batteries: Digital Battery Passport requirements already in force under the EU Battery Regulation (separate from ESPR, but aligned in concept)
• Textiles: DPP requirements expected among the first ESPR delegated acts
• Electronics and ICT products: High priority in the ESPR Working Plan
• Iron, steel, aluminium: Priority sectors given overlap with CBAM
• Furniture, tyres, chemicals: Further in the pipeline

Manufacturers should monitor the ESPR Working Plan closely, as the timing of delegated acts directly determines when their products come into scope.

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DPP, ESPR and supply chain implications

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The DPP fundamentally changes the information flow in supply chains. A manufacturer producing a product with a DPP cannot fill in the carbon footprint data without receiving cradle-to-gate CO₂e data from their material and component suppliers. This creates a cascading data requirement up the supply chain — and a direct business reason for suppliers at every tier to have their own PCF calculations ready.

For procurement teams, this shifts carbon data from a reporting exercise to a procurement prerequisite: suppliers who cannot provide verified CO₂e data risk losing their position in DPP-obligated supply chains. For procurement strategy and Scope 3 management, the DPP therefore represents both a compliance requirement and a structural incentive for supply chain decarbonization.

The DPP also reinforces the connection between LCA methodology, PCF calculation, and CSRD reporting: the same underlying CO₂e data, calculated systematically at the product level, feeds all three. For a deeper look at how LCA and PCF relate in this context, see our LCA vs. PCF comparison.

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Want to prepare verified PCF data for Digital Product Passport compliance?

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Explore our CO₂e database and PCF calculation tools, or contact our team to access the sustamizer® and build ISO 14067-aligned product carbon footprints ready for DPP integration.