What is a Digital Product Passport and How Does It Affect Me?
Learn about the European Union's Digital Product Passport initiative and where RAIN RFID fits in the big picture.
There's a sustainability revolution underway in Europe, and its impact will soon ripple across the globe. The European Commission is driving a first-of-its-kind regulatory framework called the Digital Product Passport (DPP) to create transparency around product information and accelerate the transition to a circular economy.
In upcoming years, most products sold in the EU — from tires and building supplies to clothing and laundry detergent — will require an attached identifier that includes detailed information about materials used, manufacturing processes, and recyclability.
By revealing a product’s journey and environmental impact, Digital Product Passports will empower consumers to make informed purchasing decisions and pave the way for a greener, more ethical future. This foundational framework is expected to become the information backbone of the global circular economy.
While mandates directly impacting manufacturers and retailers are still a few years out, it’s not too soon to start learning about the DPP initiative. Here is everything you need to know to stay ahead of the regulatory curve.
What is a Digital Product Passport?
At its core, a Digital Product Passport is a digital record containing key information about a product’s composition, origin, and lifecycle. Think of it like an item’s official "papers” that follow it from production to purchase to eventual disposal. Under this forthcoming legislation, companies selling products in Europe will need to collect and share detailed data on an item’s verified sustainability attributes.
European manufacturers, retailers, and those exporting products to the EU can provide this Digital Product Passport by attaching a physical ‘data carrier’ to their products. While the DPP's framers have not yet identified a specific type — or types — of data carrier required, it could take the form of a QR code, RAIN RFID tag, or another digital identifier. These tags link the physical product to its digital twin in the cloud, allowing a complete set of verified product data to travel seamlessly with the item throughout its lifecycle.
For example, by simply scanning a QR code embedded on the label of a sweatshirt with a smartphone camera, a consumer will be immediately redirected to the product’s associated Digital Product Passport to view data on materials used, ownership history, and even instructions on recycling or proper disposal.
Breakdown of the Digital Product Passport’s legislation
To fully understand the DPP framework, it is important to understand the waterfall of legislation to which it is attached. At the top is the EU Green Deal, which is a package of policy initiatives aimed at reducing emissions by 55% by 2050. To support this, the European Commission introduced the Eco-design for Sustainable Products Regulation (ESPR) to reshape how products are manufactured, distributed, and reintegrated into a circular economy.
The ESPR serves as a broad, overarching framework, rather than detailing specific requirements. It delegates the responsibility for establishing those granular rules to future regulation, known as delegated acts. Some delegated acts will be focused on specific product categories, such as textiles, while others will expand on specific technical and operational elements left out of the ESPR framework, such as rules for DPP service providers. This tiered approach sets the stage for the next steps, which will involve drafting these delegated acts.
Which industries will be impacted by the Digital Product Passport?
The European Commission has identified several prioritized product categories, both for finished end-use products as well as intermediate materials and components. This means sellers of items in these listed sectors will be among the first required to start creating Digital Product Passports for the goods they produce:
- Batteries
- Textiles (garments and footwear)
- Iron and steel
- Aluminum
- Furniture (including mattresses)
- Tires
- Detergents
- Paints
- Lubricants
- Chemicals
- Electronics
While these categories have been explicitly mentioned in legislative documents, the European Commission retains the flexibility to update and expand this list. Products such as toys, cars, and construction-related materials are likely candidates for inclusion in the DPP framework in the future.
Among the nine identified categories, a framework for battery Digital Product Passports is already in motion and is soon to be followed by delegated acts covering textiles as well as iron and steel products.
What information will the Digital Product Passport require?
Companies bringing products to the EU market will need to ensure their DPPs meet data and compliance requirements as mandated by legislation. While the specific data the DPP will require will likely vary by product category, most sellers will be required to report:
- Potential for repair, maintenance, refurbishment, and upgrades
- Presence of harmful substances
- Resource consumption or efficiency
- Recycled materials content
- Reusability, remanufacturing, and recycling potential
- Environmental impacts, including carbon footprint
- Anticipated waste generation
Beyond information requirements, the DPP framework also sets out technical standards for how that data is presented and managed. This includes having a scannable tag like a QR code or RAIN RFID tag chip on each product, which links the physical item to its unique digital profile. This profile contains detailed information about the specific model, batch, or individual unit, all in a machine-readable format that can be easily maintained and updated. Companies are also responsible for setting up secure decentralized databases to store this DPP data and control access for everyone involved throughout the product’s lifetime.
Meeting Digital Product Passport requirements with RAIN RFID
RAIN RFID is a passive, battery-free, wireless technology that uses radio frequency identification to connect billions of everyday items to the internet. While the DPP regulatory landscape continues taking shape, the tens of billions of RAIN RFID tags already deployed every year could serve a larger purpose as a key enabler of Digital Product Passports – both as a potential data carrier and solution for companies to meet demanding information requirements.
As a data carrier, RAIN RFID will likely be used in combination with more easily scannable QR codes to meet the need for consumer-friendly access. This will be confirmed in upcoming years by European standardization bodies and future delegated acts.
At the heart of Digital Product Passports lies a need for collecting comprehensive, granular data across the entire product lifecycle — from sourcing to disposal. This is where RAIN RFID technology truly shines, offering item-level tracking throughout the supply chain and beyond. RAIN RFID's robust lifecycle tracking capabilities not only satisfy compliance requirements but also solve other business challenges — helping companies automate their supply chains, combat counterfeiting, and support circular business models. Companies integrating RAIN RFID into their DPP readiness plans can stay ahead of mandates while modernizing their operations and unlocking more sustainable fulfillment models for their future.
What is the timeline for the Digital Product Passport?
The DPP rollout will be gradual, progressively encompassing more product categories, but there are several critical milestones ahead:
- July 2024: The Ecodesign for Sustainable Products (ESPR) legislation, which creates a framework for DPPs, is planned to be ratified into EU law after the final Parliament vote.
- December 2025: European standards organizations CEN/CLC/JTC24 will deliver harmonized standards for the DPP system.
- January 2026: The delegated act for textiles will be published, likely giving companies 18 months to comply (July 2027).
- April 2026: The delegated act for iron and steel products will follow, also with an 18-month compliance window (October 2027).
- February 2027: The Battery Passport regulation takes effect, requiring DPPs for all transport, industrial, and electric vehicle batteries placed on the EU market.
- Mid-2027: The textile and iron/steel rules enter into force, mandating all products in those categories carry a compliant Digital Product Passport.
While this roadmap aims to have key sectors like textiles, metals, and batteries adopting DPPs by 2027, the implementation timeline remains ambitious and subject to change. Companies should closely monitor the development of delegated acts for their specific product categories and be prepared to integrate DPP compliance into their operations within the 18-month window.
[ Want to stay up to date on the latest DPP advancements? Subscribe to the Impinj blog.]
Beyond the EU: Who else needs to comply with the Digital Product Passport?
In this new regulatory landscape, the responsibility for ensuring compliant Digital Product Passports extends beyond the borders of the European Union. Not only will finished products sold in the EU need to adhere to DPP regulations, but also any components, materials, or semi-finished goods involved in their production, regardless of their origin. This will dramatically reshape global value chains, necessitating suppliers and manufacturers worldwide to gather and submit the DPP data for their products destined for the European market.
As the first big-mover legislation of its kind, the European Commission’s Digital Product Passport is already setting a precedent that is inspiring similar initiatives globally. In the United States, for example, the American Apparel and Footwear Association (AAFA) is pushing Congress to revise labeling regulations to incorporate the use of digital labels. This signals the EU's model may become the global standard, requiring companies worldwide to make DPP compliance a strategic priority.
How will Digital Product Passports impact the retail industry?
With the responsibility for Digital Product Passport creation and compliance falling on the shoulders of the ‘economic operator’ placing the products on the market, it is likely that retailers bear the heaviest compliance burden. For those placing goods on EU shelves or websites, creating comprehensive DPPs with authentic underlying data won’t be optional — it’ll be the law.
However, rather than viewing Digital Product Passports as another compliance headache, forward-thinking retailers should embrace them as a catalyst for positive change. Consumers are increasingly conscious of their purchasing decisions’ environmental impact, and they’re demanding real transparency from the companies they buy from. By embracing DPPs, retailers proactively position themselves as champions of the sustainability revolution.
Digital Product Passports and a more sustainable future
The EU’s Digital Product Passport represents a paradigm shift in the modern marketplace. By fostering transparency, accountability, and circularity, DPPs are positioned to redefine industry standards and pave the way for a more sustainable global economy.
[ Learn more about RAIN RFID and how the Impinj platform enables retailers to drive efficiencies, minimize their environmental impact, and protect from counterfeit products. ]
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Thursday, April 25, 2024
ABOUT THE AUTHOR
Jeff Dossett
Chief Revenue Officer
Jeff Dossett oversees the Impinj go-to-market department, including sales, partner development, and marketing.
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