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The Digital Product Passport (DPP): Regulatory Overview for Manufacturers

DPP Overview Regulation

The Digital Product Passport (DPP) will become a regulatory requirement for an increasing number of industries starting in 2026. As a result, the demand for reliable, audit-proof DPP software that can map complex requirements in a simple and cost-effective way is growing. This is exactly where tracekey supports manufacturers in the SME sector.

In the following article, you will receive an overview of the DPP and the regulatory requirements in general, relevant deadlines, and the opportunities offered by a SaaS solution.

What Is the Digital Product Passport (DPP) and What Is Its Purpose?

The Digital Product Passport (DPP) is the digital identity of a product. It is an important instrument for increasing sustainability, product transparency, traceability, and promoting a circular economy. Depending on the industry, different objectives may be pursued with the introduction of the Digital Product Passport. In general, the focus is on product transparency, intelligent supply chain management, and targeted, improved risk management.

For many economic operators, a DPP solution must above all be one thing: practical for everyday use while fully complying with all legal requirements.

What Requirements Must Manufacturers Meet with the DPP?

The legal basis is the EU Ecodesign Regulation (ESPR). It forms the foundation for the broad introduction of the DPP and is supplemented by product group-specific requirements. Step by step, the Digital Product Passport will become mandatory for many product groups. Initially, it will be introduced for batteries, followed later by construction products, textiles, vehicles, and electronic equipment, among others. Product-specific regulations, such as those for construction products (Construction Products Regulation, CPR), are regulated separately for the respective products within the ESPR.

The Digital Product Passport (DPP) must be accessible via a machine-readable data carrier, such as a QR code or an RFID tag, which ideally is directly affixed to the product. Access to the DPP must be ensured throughout the entire product lifecycle.

Requirements may vary depending on the product group and are defined in more detail in the respective delegated act. Based on the ESPR, a DPP must, among other things:

  • Include a unique product identifier (product ID), containing a link to the economic operator and the production site to ensure seamless traceability
  • Provide technical data, such as information on service life and functionality
  • Disclose environmental performance, such as resource consumption and CO₂ footprint
  • Safeguard data protection (GDPR) and intellectual property rights (IPR)
  • Include information on substances of concern
  • Demonstrate legal compliance, such as CE marking and adherence to regulations
  • Provide user manuals and safety instructions
  • Contain guidelines for handling the product after its end of life, such as recycling, reparability, and modularity

Timeline: Which Industries Must Meet the DPP Requirements and When?

The introduction of the DPP will take place in stages for different product groups:

  • August 2025: Declaration of the CO₂ footprint becomes mandatory for batteries with a capacity greater than 2 kWh
  • 2026–2030: Delegated acts will be finalized
  • February 2027: Battery Regulation – the full battery passport becomes mandatory for certain batteries (>2 kWh) sold in the EU
  • Expected from 2026: Iron and steel
  • Expected from 2027: Textiles/apparel, tires, aluminum
  • Expected from 2028: Furniture
  • Expected from 2029: Mattresses and additional electronic and energy-related products
  • From 2030: Full market penetration is expected to be achieved

mytracekey DPP – For Verifiable Compliance and Regulatory Certainty

For many product groups, the exact requirements and timelines for the DPP are still under development. That is why we understand the DPP as an iterative process. With mytracekey, you start with a basic concept that enables you to achieve regulatory compliance quickly and easily. At the same time, we continuously develop our software: user feedback is incorporated, legal changes are implemented, and technological developments are leveraged. In this way, both the requirements and your organization can grow together with tracekey.

With the mytracekey DPP SaaS solution, you can easily, securely, legally compliant, and sustainably manage and provide the mandatory DPP data.

  • Legally compliant: Achieve full compliance
  • Audit-proof: Always work within a validated environment
  • Practical: Get started easily with our proven, SME-friendly solution

Proven SaaS Expertise for Regulatory Systems: Over 10 Years Supporting SMEs in Healthcare

For more than a decade, we have been developing software for highly regulated industries. We built our DPP solution in the same way we developed our UDI and serialization solutions: cleanly designed, consistently structured, and regulatory-safe. Our software solutions are designed for small and medium-sized enterprises that do not want to turn compliance into a major project.

Your Next Steps Toward DPP Compliance with tracekey

Get in touch and learn how tracekey can support you in preparing and implementing your Digital Product Passport.

[Disclaimer]

The information provided here is only one possible interpretation of the regulations. These are also subject to constant change, so the information in this article may be incomplete or no longer up to date. The above article is expressly not intended as legal advice. Please consult the official documents before making any business decisions. (Information status: April 2026)

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