Digital product passports: Why product data readiness matters more than the deadline

A digital product passport looks like a QR code. The hard work is making sure the record behind it still tells the truth six months after the product ships.

Consider what happens when a supplier substitutes a control board on a connected home appliance. That one change can ripple into the BOM, the firmware test plan, the service procedure, the spare parts list and the recyclability assessment. If those records live in different systems, owned by different teams, with no shared signal that the change happened, the product on the shelf and the product on paper begin to drift apart. A DPP asks you to make the right parts of that record available to the right audiences. The real question is whether the record can keep up with the product.

Even if your category is not first in line for regulation, that question is already worth asking. Can your teams build a complete, current product record without chasing answers across systems and departments?

What a digital product passport means in practice

A digital product passport, or DPP, is a structured digital record linked to a physical product. It carries trusted information about the product’s identity, materials, supply chain, sustainability performance, repair, reuse and end-of-life details. Teams access it through a QR code or similar data carrier on the product, packaging or documentation.

For a consumer product, the information behind a DPP draws from product identifiers, materials, components, supplier inputs, BOMs, configurations, engineering changes, manufacturing information, repair instructions and spare parts details. The point is that the record gives the right audiences access to trusted product information, even when that information comes from several systems.

Consumer interest in this kind of transparency has been rising for years, and retailers are increasingly expected to answer for what they put on their shelves. A 2021 OpenText survey of 27,000 consumers across 12 countries found that 88% prioritize buying from companies with ethical sourcing strategies, and 83% would pay more for goods that are ethically produced. [1] The DPP makes that kind of information machine-readable and verifiable.

Most companies already have parts of this data somewhere. The harder question is whether your teams know which version is current, who owns it and how it changes over time. Those are not regulatory questions. They are everyday product data questions, and the regulatory deadline is just what makes them urgent.

Should my company start preparing for digital product passports?

The DPP comes from the EU’s Ecodesign for Sustainable Products Regulation, or ESPR. ESPR entered into force on July 18, 2024 and sets the framework for future digital product passport requirements. The details roll out by product category through delegated acts, so products will not all follow the same timeline or data requirements.

The first wave does not create one immediate rule for every consumer product. The European Commission adopted the ESPR Working Plan 2025 to 2030 on April 16, 2025, which names priority categories including steel and aluminum, textiles with a focus on apparel, furniture, tires and mattresses, alongside several energy-related products. The plan also introduces horizontal measures on repairability and recyclability of electrical and electronic equipment.

A few dates are worth tracking:

• July 18, 2024: ESPR entered into force
• 2025 to 2030: The current working plan names priority categories including steel and aluminum, textiles, furniture, tires, mattresses and several energy-related products
• February 18, 2027: The first mandatory digital passport, the battery passport, takes effect for specific battery categories placed on the EU market
• Later working plans: Teams working on connected products should continue monitoring future plans

This does not mean every consumer product has the same deadline. It does mean the data work is becoming more urgent.

So the answer is yes, but with context. Do not assume every consumer product has an immediate DPP deadline. That overstates the case. At the same time, product data is becoming more visible, more structured and more tied to market access, repairability, sustainability and trust.

That feels like room to breathe, and partly it is. But consumer product platforms are usually locked in well before launch and stay in market for years afterward. The platform decisions made today are the ones that will be in scope when delegated acts arrive for adjacent product categories. The work of getting product data ready does not compress easily into the final months of a transition period.

Regulatory timing and requirements vary by product category and market, so review the rules that apply to your products.

Are digital product passports required outside the EU?

The EU is leading the broad DPP regulatory push. Outside the EU, requirements vary, but companies can still be affected if they sell into the EU or supply companies that do.

ESPR applies to products placed on the EU market or put into service, regardless of where they are produced. For a consumer products company, the key question is not only where you make the product. It is also where you sell it.

This pattern is familiar from earlier EU regulations. GDPR began as a privacy law, and its extraterritorial reach means companies outside Europe still have obligations when they offer goods or services to people in the EU or monitor their behavior. RoHS is closer to the product side. It restricts hazardous substances in electrical and electronic equipment placed on the EU market, which pushed many non-EU manufacturers to understand what materials sit inside their products and components.

DPPs are operationally different from both. GDPR is governed by consent records and access controls, which can sit in a dedicated platform. RoHS is more bounded because it focuses on restricted substances in electrical and electronic equipment. A DPP is broader because the product record has to stay accurate as suppliers change, components are substituted and software is updated.

For consumer products teams, the takeaway is simple:

• EU rules can affect companies outside Europe
• DPP timing will vary by product category
• Product data work should start before a deadline appears
• The hardest part is keeping the product record current as products change

Why is DPP readiness really a product data issue?

A DPP depends on the quality of the data behind it. That is where many consumer products teams run into trouble.

Product identity sits in one system. BOMs and configurations sit in another. Supplier information arrives through portals, emails or spreadsheets. Service instructions get created later by a different team. Sustainability data has its own owners and tools. The hard part is rarely about storing more information. It is about deciding which system owns which record, who can access it and how teams avoid creating parallel copies that drift over time.

In daily work, teams find ways around this. They ask someone in another department. They check an old spreadsheet. They look for the person who usually knows where the answer lives. That works for a while, then breaks down when the product record needs to be structured, current and reliable for someone outside the company.

The weak spots usually show up in three places:

• Ownership: No one agrees which team owns the record
• Version control: Teams cannot quickly confirm the current version
• Change flow: Updates do not move cleanly from engineering to manufacturing, service and sustainability

A few direct questions can show where the gaps are:

• Can you trace a product model from requirements to BOM, manufacturing and service?
• Can you identify which materials and components are used in each product variant?
• If a supplier changes a component, who updates repair and service information?
• Can you trace a change across mechanical, electrical and software work without manual cleanup?
• Who owns the master record for each type of product information?
• Can you tie a serial number back to its specific configuration at manufacture?

The tell, in most companies, is that nobody can confidently answer “which version is the current one” without checking with two or three other people first. If that pattern looks familiar, the issue is bigger than DPP readiness. You have a product data problem, and a future DPP deadline will  make that problem harder to ignore.

Why do connected consumer products make DPP readiness harder?

Consumer products cover a broad range, and a connected home appliance is a useful example because it shows how quickly product data spreads across teams.

A washing machine or oven looks familiar from the outside. Inside, it brings together mechanical systems, electronics, software, sensors and connected services. Add regional variants, supplier substitutions, energy requirements and repair needs, and the data picture gets crowded fast.

The European Commission has noted that up to 80% of products’ environmental impacts are determined at the design phase. [2] That matters for product teams because decisions made early about materials, components and how a product can be repaired or recycled are the ones a DPP will eventually have to reflect. The further upstream the data work happens, the easier the downstream record becomes.

The cross-domain piece is where this becomes difficult in practice. A change to firmware that moves a tolerance even slightly has to register against the mechanical drawing, the test plan, the service procedure and the recyclability assessment. Ideally without any of those teams having to chase the change down. That is a real coordination problem before any regulator gets involved.

The pain usually shows up in three places:

• System reality: Where product data lives, who can access it and which record is trusted
• Change: How a design update affects mechanical fit, electronics, firmware, testing and certification
• Timing: How missing data slows handoffs, delays release work and creates problems for manufacturing or service later

Return to the supplier control board example from earlier. That one substitution affects the BOM, firmware, testing, repair instructions and spare parts plan. If those teams work from different records, the issue does not stay small. Supply chains do not stand still while teams figure out how to coordinate. Suppliers get swapped out. Components are substituted. Software gets updated.

The passport may be the visible part, but the work behind it reaches engineering, IT, sourcing, manufacturing, quality and service. Which is why the question of where to put product data control is worth thinking about now, not later.

How can PLM support DPP readiness?

Product lifecycle management should not be treated as a shortcut to DPP compliance. Requirements depend on product category, regulation, data standards and your company’s role in the value chain. But if DPP readiness starts with the product record, PLM is one place to look first.

In practical terms, PLM is most relevant where teams need to control:

• BOMs
• Configurations
• Requirements
• Approved product data
• Engineering changes

That is where mechanical, electrical and software work needs to stay aligned before information moves downstream to manufacturing, service, compliance and sustainability teams.

PLM will not hold every piece of DPP-related data on its own. Supplier, manufacturing, compliance, service and sustainability information often live in other systems. The practical value is in connecting the controlled product definition to the wider product data environment, so teams across engineering, manufacturing and service work from one trusted view as products grow more complex.

What consumer products teams can do now

You do not need to wait for every DPP detail to be final before checking your product data. Start with one product that is complex enough to expose weak spots, such as a connected product with software, supplier substitutions, regional variants or service requirements.

Use that product to check four things:

• Where does the product information live today?
• Which team owns each major data type?
• Where do teams rely on spreadsheets, emails or informal updates?
• Can you connect identity, BOM, supplier data, manufacturing, repair and end-of-life information without chasing answers?

The goal is not to build a full DPP now. The goal is to see whether your product data can support the level of traceability future requirements may demand.

If one product record is hard to assemble, the issue is already visible.

The takeaway

Digital product passports are often discussed as regulation. Regulation matters, but the harder question for consumer products teams is more practical. Can your product record keep up with the product?

Start with one product record. See where the information breaks. Then decide what needs to change in the way your teams manage product data across the lifecycle. The product platforms making those records possible are being chosen now, and the practical work to support them can start this quarter.

See how consumer products teams use PLM to keep product records current across engineering, service and sustainability, while supporting faster product development and stronger IT resilience before digital product passport requirements arrive. To learn more, read the ebook “Discover the power of cloud-based product lifecycle management for the consumer products industry“.

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Frequently asked questions

What is a digital product passport?

A digital product passport (DPP) is a structured digital record linked to a physical product that provides trusted, current information about its lifecycle. This includes materials, components, supply chain details, sustainability performance, repair instructions and end-of-life guidance. For consumer products manufacturers, it usually sits behind a QR code or data carrier on the product or packaging, connecting to product data that teams across the organization maintain and update as the product evolves. A DPP is not a static document. It is a record that needs to keep up with the product as suppliers change, components are substituted and software is updated.

When does the first digital product passport requirement take effect?

The first mandatory digital product passport, the battery passport, takes effect on February 2027 under the EU Battery Regulation. It applies to electric vehicle, industrial and light-means-of-transport batteries above 2 kWh placed on the EU market. For other consumer product categories, timing depends on when the European Commission adopts category-specific delegated acts under ESPR. The 2025 to 2030 Working Plan names priority categories including textiles (with a focus on apparel), furniture, tires and mattresses, with delegated acts expected between 2026 and 2029 and compliance dates typically following 18 to 24 months after adoption.

Do DPP regulations apply to companies outside the EU?

Yes, if you sell products into the EU. ESPR applies to products placed on the EU market or put into service, regardless of where they are produced. The pattern is familiar from earlier EU regulations like GDPR and RoHS. The key question is not only where you make your products. It is also where you sell them. If EU market access matters to your business, DPP readiness should be on your radar even if your manufacturing operations sit outside Europe. Companies that supply EU-based manufacturers or retailers may also see DPP requirements flow down through contractual obligations in the supply chain.

How can my team assess whether we are ready for DPP requirements?

Start with a few direct questions about your current product data. Can you trace a product model from requirements through BOM, manufacturing and service? Can you identify which materials and components are used in each product variant? If a supplier changes a component, who updates repair and service information? Can you trace a change across mechanical, electrical and software work without manual cleanup? Can you tie a serial number back to its specific configuration at manufacture? The tell, in most companies, is that nobody can confidently answer “which version is the current one” without checking with two or three other people first. If that pattern looks familiar, you have a product data readiness issue that extends beyond DPP compliance, and addressing it now can reduce rework, improve handoffs and strengthen collaboration across teams.

Could DPP-aligned work improve our operations even if regulations do not apply to us yet?

Yes. The work that prepares a product record for a future DPP is the same work that improves day-to-day operations. Clearer ownership of product data reduces the time engineers and IT teams spend reconciling versions. Structured change management means manufacturing and service teams work from current information rather than chasing it. Connected mechanical, electrical and software records reduce late-stage surprises during launch. Companies that start now tend to find the operational benefits land well ahead of any regulatory deadline, and consumer interest in product transparency is rising regardless of where the regulation lands first.

What role does PLM play in DPP readiness?

PLM helps manage the controlled product information that sits behind a DPP, including product definitions, BOMs, configurations, requirements, engineering changes and approved product data. For consumer products with mechanical, electrical and software components, PLM provides a foundation for keeping teams aligned as designs evolve and suppliers change. PLM does not hold every piece of DPP-related data on its own. Supplier, manufacturing, compliance and sustainability information often live in other systems. The practical value is in connecting controlled product definitions to the wider product data environment, so the information a DPP requires is easier to find, trust and update.

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[1] OpenText, “OpenText Survey Shows Increase in Demand for Ethically Sourced Goods,” Sept. 29, 2021. Survey of 27,000 consumers across 12 countries. https://investors.opentext.com/press-releases/press-releases-details/2021/OpenText-Survey-Shows-Increase-in-Demand-for-Ethically-Sourced-Goods/default.aspx

[2] European Commission, “Circular economy,” accessed May 2026. https://environment.ec.europa.eu/strategy/circular-economy_en