Digital Product Passports: Turning data into circular business value

The circular economy is moving from ambition to implementation, with Digital Product Passports (DPP) emerging as a key enabler of that shift.

At its core, a DPP can be understood as a digital representation of a product, linked to the physical item — for example via a QR code — making key information accessible, structured and usable throughout its lifecycle. Introduced under the Ecodesign for Sustainable Products Regulation (ESPR), DPP requirements will apply to products placed on the EU market, whether sold physically or online.

With a DPP, different actors can access and contribute relevant data at different stages. A manufacturer manages technical specifications and material data, a repair provider accesses instructions and spare parts information, and a consumer gains insight into how to use, repair and care for the product, as well as its origin and sustainability aspects.

This is not just about compliance, but about retaining value. DPP enables organisations to extend product lifetimes and activate circular business models such as repair, reuse and take-back. In this context, product data becomes a strategic business asset. Organisations that can structure and use it effectively will be better positioned to create new revenue streams and operate in emerging data-driven markets.

Moreover, the DPP concept is also reflected in other EU legislation, indicating that it forms part of a broader regulatory direction that will shape product compliance and circularity in the years ahead.

From data to capability

Most SMEs already manage product data across spreadsheets, ERP systems and supplier inputs. The starting point is rarely zero. The real shift lies in turning fragmented data into structured, reliable and scalable information over time.

The DPP is not about collecting more data, but about building the capability to manage it consistently — through clear ownership, defined processes, system integration and alignment with business operations. It is not a reporting exercise, it is an operational capability.

It also requires the ability to reproduce, trust and share information across systems and organisational boundaries. Organisations that recognise this early can turn compliance into a strategic advantage. 

The challenge is not to start from scratch, but to use the right data and build the digital maturity needed to make DPP work in practice. The biggest constraint is not data availability, but the ability to turn it into reliable, scalable and business-relevant product information — across systems, functions and value chains. It is also organisational. Responsibility is often fragmented across functions, without clear ownership or accountability.

Policy sets the direction – standards make it real

The development of DPP is driven by both legislation and standardisation. The ESPR defines what a DPP should achieve and what information is required. It also provides the framework for which data is critical from both a business and regulatory perspective, such as product composition, performance and lifecycle information.

The European standards from CEN/CENELEC on the other hand, define how that information is structured, shared and made interoperable in practice. This includes, for example, how products are uniquely identified, how data is linked to the physical product, and how information is accessed and exchanged across systems. 

The landscape is still evolving, but the overall framework is already in place. 

What about timing?

Digital Product Passports will not be introduced all at once. Under the ESPR, requirements will be defined through delegated acts for specific product groups.

The first ESPR Working Plan identifies priority groups such as iron and steel (expected 2026), followed by textiles, tyres and other materials (expected 2027), furniture (expected 2028) and mattresses and ICT products expected later (expected 2029). These timelines are indicative and may evolve as delegated acts are adopted. Batteries are regulated separately under the Batteries Regulation, with similar passport requirements (expected 2027). By 2030, most products in scope under ESPR are expected to be covered, with some exceptions such as food and feed products. 

At the same time, the European standards defining how DPPs work in practice are steadily maturing, providing increasing clarity on the technical approach to implementation.
While compliance timelines will vary, implementation periods are typically expected to include a transition phase, often in the range of up to around 18 months once requirements are defined. 

Preparing for DPP: Opportunities and the Cost of Delay

The need to prepare is immediate. Organisations benefit from starting early by understanding how product data flows across the lifecycle, where it is created and maintained, and how it aligns with existing systems and processes.

Building the digital maturity and operational capability required for DPP takes time — especially since many SMEs are still reliant on manual, fragmented processes.

Organisations that begin to structure and manage their product data can improve internal efficiency, reduce duplication and gain better control over their value chains. More importantly, DPP enables new forms of value creation — from enhanced transparency and customer trust to new circular business models. It also strengthens collaboration across the value chain, as shared and interoperable data becomes a foundation for innovation.

Those who delay face increasing risks: restricted access to the EU market, lost business opportunities, delayed transition towards circular, value-retaining business models and potential sanctions.

A practical starting point for DPP

Rather than waiting for the delegated acts, organisations benefit from starting with the fundamentals:

1. Map product information flows in the value chain
   Understand the scope of product data in relation to ESPR, and how it is created, stored and updated across the product lifecycle.
2. Identify gaps, risks and dependencies
   Where is data missing, inconsistent or dependent on suppliers and external actors? What information may be sensitive or at risk of exposure? DPP introduces new considerations around trade secrets, requiring clear rules for access, control and data governance in the organisation.
3. Align data with business processes
   Ensure product information supports real operational and business model needs — not just compliance.
4. Assess technical readiness and define a starting technical architecture
   Evaluate what is feasible based on current systems, data maturity and governance structures. This includes identifying where product data should be managed, how systems need to connect, and how a first minimum viable DPP can be generated, linked to a product identifier and maintained over time.

How we support organisations

At Hållbarhetsboost AB, we closely follow how the legislation evolves and are actively engaged in the national standardisation work on Digital Product Passports at the Swedish Institute for Standards.

We support organisations in mapping and structuring their product information flows for DPP — aligned with business objectives, cost-efficient and grounded in what is technically feasible given their digital maturity.
Because successful implementation is not about doing everything at once. It is about building the right capability, in the right way, at the right time.

Blagica Bodén
Senior Sustainability & Circular Business Strategist
Founder, Hållbarhetsboost AB