Digital Product Passport - Is my product affected?
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“Our industry is affected by the Digital Product Passport” is not yet a sufficient statement for companies. A machinery manufacturer can include batteries, electronics, steel components, and products in the same portfolio even if there is currently no specific DPP requirement for them. For company management, therefore, it is not the industry that is the decisive factor, but rather each individual product and the applicable legal framework.
Affected industries are just the starting point
The ESPR (Regulation (EU) 2024/1781) establishes the framework for ecodesign requirements for numerous physical products. The 2025–2030 work plan prioritizes, among other things, textiles and apparel, furniture, tires, mattresses, iron and steel, and aluminum.
However, this does not automatically mean that every company in these sectors must already provide a Digital Product Passport today. Under the ESPR, specific requirements for each product group will be established through further legislative acts.
For companies, therefore, a different question is more relevant:
Which regulatory path applies to which product in our portfolio?
1. Which product is actually being placed on the market?
A general industry label such as “automotive,” “mechanical engineering,” or “retail” is not sufficient. A company may market products from multiple regulatory categories simultaneously.
Therefore, end products, components, and relevant intermediate products should first be systematically classified. Iron, steel, and aluminum, for example, demonstrate that the DPP applies not only to traditional consumer goods.
2. Which regulatory framework applies?
This is followed by legal classification. Many product groups are specified in detail by the ESPR. In addition, separate regulatory frameworks exist.
For certain LMT, electric vehicle, and industrial batteries exceeding 2 kWh, the EU Battery Regulation mandates a battery passport effective February 18, 2027. Construction products, in turn, will have their own DPP system under the Construction Products Regulation, which is intended to be interoperable with the ESPR system.
“Subject to the DPP” can therefore mean slightly different things depending on the product.
3. How concrete is the requirement already?
For corporate planning purposes, at least three statuses must be distinguished:
Binding: A regulation already contains a specific DPP requirement and a deadline.
Prioritized: The product group is included in the ESPR work plan, but the final requirements have not yet been fully defined.
Still under observation: The product may fall within the regulatory scope, but no specific DPP requirement exists yet.
This distinction prevents planning years from being confused with statutory deadlines.
4. What is the company’s role?
A company’s position in the value chain also matters. Manufacturers, importers, and other economic actors may have different obligations. Suppliers, on the other hand, may be required to provide data even though they do not publish the final product passport themselves.
DPP impact should be tracked using a portfolio matrix that includes product, regulations, legal status, and company role.
he question of which industries are affected by the Digital Product Passport cannot be seriously answered with a single list of industries. The decisive factors are the product group, the relevant regulatory framework, the current legal status, and the company’s own role in the supply chain.
Companies should therefore first classify their portfolio and only then decide on systems or DPP solutions. This will reveal which product lines require immediate priority and where data structures in PIM, MDM, ERP, and supplier processes should be prepared first.
FAQ
Is my industry automatically subject to DPP requirements if it is listed in the ESPR work plan?
No. The work plan prioritizes regulatory tasks. Specific obligations are set forth in the respective legal acts.
Can different products from the same company have different DPP deadlines?
Yes. A mixed portfolio may be subject to multiple sets of regulations and timelines simultaneously.
Are suppliers also relevant?
Yes. They may be needed to provide material, origin, substance, or environmental data, even if they do not submit a final DPP.
What is the first step for companies?
A product matrix listing the product group, legal basis, regulatory status, and responsible economic operator.
