Preparing for ESPR: A Practical DPP Roadmap for Manufacturers

Digital Product Passport requirements are developing product group by product group. Start by checking whether your products are covered and which dates are legally fixed. This roadmap gives you practical preparation steps.

Step 1: Understand which rules apply to you

ESPR provides the framework for product-specific delegated acts. Separately, the EU Battery Regulation requires passports from 18 February 2027 for EV batteries, light means of transport batteries and industrial batteries with a capacity greater than 2 kWh. ESPR priorities include textile apparel, steel, aluminium, furniture, tyres and mattresses.

Map your portfolio against these categories and follow the progress of the delegated acts that concern you.

Step 2: Audit the data you already have

Start by checking the information already available in your ERP and PLM systems, compliance files, test reports and supplier declarations. Then identify gaps. Useful areas to review include:

• product identifiers and model data
• material composition and substances of concern
• environmental data such as carbon footprint and recycled content
• certificates, declarations of conformity and safety information
• repair, disassembly and end-of-life instructions

Step 3: Involve your suppliers early

Passport data often depends on information from several tiers of the supply chain. Tell suppliers what you will need, agree on formats, and build data requests into contracts. Suppliers who hear about the requirements early have time to prepare, and that makes your own compliance far easier.

Step 4: Choose your identifiers and data carriers

Each passport is linked to a unique product identifier and a data carrier on the product, packaging or documentation, typically a QR code. Decide whether you will issue passports per model, per batch or per individual item, as the delegated act for your product group requires, and plan how codes will be applied in production.

Step 5: Select a DPP platform

When assessing a future platform, check supported formats, integrations, access controls and how it will meet the required availability period. Ask which standards it actually supports and what evidence backs those claims. Requirements still under development may require later changes.

Step 6: Start with a pilot

Choose one product line and prepare a pilot dataset. Test how you collect, structure and review the information. Label assumptions and sample data clearly, especially where final requirements are pending.

Preparation pays off

Starting with a manageable data review can reduce last-minute work. DPPVIEW helps with product passport preparation: mapping information, collecting supplier data and identifying gaps. Our hosting platform is in development.