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April 2, 2024

The EU's Digital Product Passport Regulation: A Guide for Businesses

Open questions and opportunities around the EU's Digital Product Passport (DPP) regulation. Why is early adoption important?

The EU's Digital Product Passport Regulation: A Guide for Businesses

The EU's Digital Product Passport (DPP) regulation stands as an unprecedented tool for fostering circularity, yet many critical questions around it are still unanswered. In the face of pressing circularity challenges, it's vital to accelerate the pace of adoption and motivate businesses to take steps towards early implementation. The DPP regulation is poised to affect a vast array of product groups and industries, presenting an unique opportunity for companies to reap early benefits. 

This article ventures into several pivotal areas:

  • The open  questions surrounding the Digital Product Passport regulation, including its scope, technological requirements , and data protocols.
  • The intrinsic value and return on investment (ROI) that early adopters stand to gain.
  • Planning considerations

What is the Digital Product Passport regulation? Its origins, purpose, and significance

The Digital Product Passport (DPP) is a requirement of the European Commission's Ecodesign for Sustainable Products Regulation (ESPR) aimed at enhancing product sustainability and fostering a circular economy. It acts as a comprehensive database of product-related information, spanning from manufacturing (and sometimes design) to the disposal of a product.

Aligned with the European Green Deal, the DPP initiative supports EU objectives to reduce CO2 emissions, promote sustainable development, and achieve climate neutrality. Operating within the framework of the Ecodesign Sustainable Products Regulation (ESPR), DPPs will contribute significantly to meeting Europe's commitments to international agreements such as the Paris Agreement and the UN Sustainable Development Goals.

The implementation of DPPs will extend beyond EU borders, impacting imported products and global value chains. This regulation will compel suppliers and producers worldwide to collect and report necessary data. While voluntary DPP initiatives exist, the EU regulation seeks to standardize and mandate their adoption across industries (batteries, textiles, electronics, construction products to start with), driving sustainability and accountability throughout the supply chain.

Challenges and Uncertainties: Tailoring the DPP Rollout

Starting with batteries in 2026 and expanding to around 30 product categories by 2030, the DPP's phased rollout  raises important considerations:

Product Group Prioritization

The EC could prioritize DPP rollout based on either a product's environmental impact or by targeting specific industries. Prioritizing by impact could face delays if a clear framework for ranking impact is not established. An industry-focused approach may expedite the process, but risks overlooking initially less-polluting products within those industries.

Company Size

Enforcing DPPs across all company sizes promises clarity and transparency, but could burden SMEs and hinder adoption. Alternatively, starting with large corporations might simplify initial implementation but could concentrate complexity and compromise overall supply chain transparency.

Application Scope

Should DPPs track individual items, batches, or entire product models? Item-level tracking offers the most granularity for repair and end-of-life data but might be too complex for some companies to build in-house. Additionally, current end-of-life processes often deal in bulk, making item-level scanning impractical. Product model-level DPPs simplify implementation but sacrifice some transparency. A batch-level approach could be a middle ground but might offer limited environmental benefits and few fringe benefits.

Data Requirements

Broad data categories like "repair ease" are helpful but need detailed data points for each product group. However, tailoring data requirements this way increases complexity and costs. Standardized requirements across industries could speed up adoption but may miss product-specific environmental concerns. A balanced approach, blending standard data with some targeted details, could be the optimal path.

These open questions highlight the delicate balance the EU faces in making DPPs successful. Addressing these complexities will be crucial in ensuring the Digital Product Passport achieves its goals of greater sustainability and a thriving circular economy.

Early Adoption of DPPs: Why It Pays Off (Despite the Challenges)

Challenges such as data transparency, security, and system interoperability will undoubtedly accompany the rollout of Digital Product Passports (DPPs). However, companies that begin addressing these issues now can position themselves for a smoother transition and realize significant benefits. While waiting for full regulatory certainty is tempting, the advantages of early action are compelling.

Where to Focus: Four Key Areas for Preparation

1. Influence the Regulatory Framework

With details of the DPP still being shaped, companies have a crucial opportunity to provide input and ensure the regulations are practical and effective. Actively participating in stakeholder consultations allows businesses to share expertise and advocate for solutions that work within their industries. Collaboration on issues like application scope (item, batch, or product model level) and data management can help establish industry standards and fill in regulatory gaps.

2. Assess and Address Product Data Gaps

Start by evaluating the product data you currently collect. Identify any gaps and begin the process of acquiring missing information. This is a great time to align efforts with standards already utilized for ESG reports, Life Cycle Assessments, and other regulatory compliance efforts. Proactively mapping likely DPP data requirements helps you streamline collection processes, particularly in the upstream phases where data can be harder to gather.

3. Build Internal Awareness and Coordination

Implementing DPPs will have impacts across your organization. Designating a DPP expert from a relevant team (like Sustainability, Compliance or Public Affairs) helps break down internal silos. This person can champion the effort, ensuring all departments understand the implications. Company-wide awareness positions the DPP as a tool for multiple teams:

  • Marketing and sales can use DPP data for customer engagement and sustainability messaging.
  • Product design can leverage end-of-life data to improve future product iterations.
  • Service & support can benefit from on-product services that expand an overall value proposition.

4. Prepare Your Technology Infrastructure

The European Commission will likely focus - and rightfully so - on broad DPP technology principles rather than mandating specific solutions. Nonetheless, companies should begin evaluating how to adapt systems for data storage, access, and the use of data carriers suitable for their products. For most, this will involve enhancing existing systems rather than a complete overhaul. Consider DPP implications with all current technology decisions to prevent costly future rework. Emphasize interoperability – both within your company and throughout your value chain. Early discussions with technology solution providers can pave the way for a smoother implementation.

With DPPs becoming mandatory across many industries, companies that start preparing now gain a distinct advantage. Proactive engagement mitigates risks, prevents rushed decisions, and positions your business to fully leverage the transparency and sustainability benefits that DPPs will bring.

Planning the Road to DPP Implementation

Implementing Digital Product Passports will take time and careful planning. Here's a breakdown of what a typical rollout might look like. Keep in mind, factors like your company's complexity and existing systems will influence the exact timeframe.

Assessment and Planning

  • Dive into the Details: Analyze how you make products, their lifecycle, and their environmental impacts.
  • Spot Opportunities: Where can DPPs make your products last longer, be easier to repair, or become more recyclable?
  • The Master Plan: Outline goals, specific steps, and a detailed schedule for bringing DPPs into your production processes.

Training and Capacity Building

  • Everyone on Board: Train people at all levels of the company on DPP concepts.
  • Build Expertise: Give teams the knowledge and tools they need to implement DPPs in their day-to-day work.
  • Fostering a Culture Shift: Create a company-wide focus on sustainability and innovation – this makes DPP adoption much smoother.

Pilot Projects and Prototyping

  • Test Drive: Start small by applying DPPs to select product lines or categories.
  • Build and Improve: Develop DPP-enhanced prototypes and rigorously test them for durability and customer acceptance.
  • Feedback Loop: Gather input from customers, suppliers, and your own teams. Use this to refine your approach and make design changes.

Full-Scale Implementation

  • Going Big: Expand DPPs across your entire production process. Aim to weave sustainability into every stage of a product's life.
  • Tracking Progress: Set up ways to measure how DPPs impact product lifespans, resource use, and your environmental footprint.
  • Adapt and Iterate: Use real-world data and evolving regulations to continuously fine-tune your DPP strategy.

Continuous Improvement and Innovation (Ongoing)

  • Staying Ahead of the Curve: Build a culture that constantly seeks new ways to improve sustainability through better design and processes.
  • The Competitive Edge: Keep an eye on emerging technologies and best practices. This keeps you adaptable and resilient in a changing market.

The Reality Check

The entirety of this transformation will likely take several years, and it won't come without its share of challenges. Investing in technology may mean initial setbacks. Yet, companies that begin preparing now gain an edge as they will have learned by the time DPPs become mandatory. Staying informed and flexible is key. Manufacturers, especially, should prioritize streamlining product data across their supply chains. In a world of DPPs, organized data is a competitive advantage, and it is becoming increasingly clear that there simply may not be enough time to conduct this transformation in the “traditional” way. But good business practices and new technology can help by offering evolutionary, rather than “big bang” approaches to the implementation of the DPP agenda.

How Twintag Can Help

Companies getting ready for the DPP rollout should ensure their product data is top-notch, simplify how they collect and store data, add data carriers to their products, and make it easy to share data throughout their supply chains. Advanced tech solutions like Twintag offer simple and quick deployment options that relieve pressure on IT teams while setting the stage for a connected product strategy, using a "twin-tag", most often in the shape of a QR code acting as a true virtual chip in the cloud.

  • Unique Digital Identities & DPP Compliance: a twintag connects any physical product with unique, dynamic digital experiences accessible through scanning by end-users or other personas. This evolving digital identity can store and manage DPP-mandated data elements. It ensures compliance and builds a foundation for future value-added services. 
  • Data Management and Distribution & Ecosystem integration: Twintag lets you easily gather, store, access and manage product data in a centralized - and often evolving - system of your choice. Smooth, secure synchronization with your existing systems (ERP, PLM,..) facilitates secure data sharing across the value chain, making it accessible to relevant stakeholders.
  • Product Authentication, Traceability and Anti-counterfeit: Tamper-proof twintags can be instrumental in verifying the authenticity of products and track them throughout their lifecycle, ensuring visibility, transparency and accountability within the supply chain, and supporting  product recalls - all increasingly important under DPP regulations.
  • Personalized Customer Experience, Service & Sustainability Insights: Twintag empowers direct-to-consumer interactions and collects valuable first-party data on product usage and end-of-life behaviors. This builds brand loyalty, supports circular economy initiatives, and fuels product design enhancements.


The DPP regulation represents a significant shift towards a more sustainable and circular economy. While uncertainties remain, companies can take proactive steps to prepare. Early adoption not only ensures compliance but also offers competitive advantages and helps businesses become leaders in sustainability. By leveraging technologies like Twintag, companies can streamline their DPP implementation process and unlock the full potential of this transformative regulation. The good news is that there are clear and present opportunities to kill two birds with one stone by literally starting today:

  • Lay the necessary foundation for DPP compliance while getting your organization up to speed  in terms of requirements and digital twin technology
  • Reap the low-hanging fruit that the digital twins can offer from day one in terms of a better customer experience, more efficient services and product usage feedback.

During its experience in many use cases across industries, Twintag has witnessed tangible results from initial steps in just a few weeks or a couple months. Chances are that those use cases were very comparable to yours!

Paul Carpentier

Father and grandfather, serial entrepreneur, founder of Twintag and lifelong data tech enthusiast. The relentless pursuit of simplicity guides me while mapping Twintag technology to digital solutions

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