Digital Product Passport Guide
What a Digital Product Passport (DPP) is, why EU Regulation 2024/1781 makes it mandatory for many products placed on the European market, and how Winnow Technology helps producers issue independently verified, DPPs for all non-food related FMCG product categories.
What is a Digital Product Passport?
A Digital Product Passport is a structured set of product-specific data that accompanies a product throughout its life cycle. It is accessed electronically — typically via a QR code or data carrier on the product, packaging, or documentation — and linked to a unique product identifier.
Unlike a traditional label, a DPP is not a static PDF. It is a machine-readable record that connects to official registries, supports market surveillance, and lets different actors see the information they are entitled to: consumers, professional operators, value-chain partners, customs authorities, and independent verifiers.
The legal framework: EU Regulation 2024/1781
The Ecodesign for Sustainable Products Regulation (ESPR), formally Regulation (EU) 2024/1781, introduces the legal basis for Digital Product Passports. It expands the old Ecodesign framework beyond energy efficiency to cover product durability, reparability, recycled content, carbon and environmental footprints, and substances of concern.
Under ESPR, product groups can be selected by the Commission through delegated acts. Once a product group is covered, manufacturers, importers, and other economic operators must make a DPP available before placing those products on the EU market or putting them into service.
- Regulation basis: EU Regulation 2024/1781, published in the Official Journal on 28 June 2024.
- Delegated acts: define product-specific DPP requirements for each product group.
- Unique Product Identifier (UPI): every product needs a persistent identifier.
- EU DPP Registry: passports must be registered in the EU DPP Registry.
- Verification: a third party must verify the data in the passport before it is issued.
Who needs a DPP?
The DPP requirement applies to economic operators that place covered products for purchase on the EU market.
Fast-moving consumer goods products fall under the broader category of products with a significant environmental impact, and the Commission has signalled interest in chemicals-related product groups. Even before a delegated act is published, brands preparing for ESPR are treating DPP readiness as a competitive signal.
What data goes inside a DPP?
The exact data set depends on the product group, but Annex III of the ESPR framework requires core product and operator information, and Annex VII requires additional performance and sustainability information.
- Identity: product name, model, version, net content, UPI, GTIN, and TARIC code.
- Operators: manufacturer, unique operator identifier (UOI), responsible EU operator, importer EORI, and contact details.
- Environmental footprint: Product Environmental Footprint (PEF) results under the Commission Recommendation (EU) 2021/2279, EF 3.1 impact categories.
- Materials: product and packaging weights, recycled content, and end-of-life instructions.
- Substances of concern: name, EC/CAS number, concentration, location, and safe-use guidance.
- Documentation: declaration of conformity, safety data sheet, full PEF report, and verification statement.
- Governance: data carrier, registry entry, update triggers, retention period, and responsible party for updates.
PEF methodology and EF 3.2 impact categories
Life Cycle Assessment (LCA) is the only internationally recognised scientific framework for measuring the environmental impact of a product across its entire life cycle. It quantifies inputs, outputs, and potential impacts from raw material extraction through manufacturing, distribution, use, and end-of-life.
The Product Environmental Footprint (PEF) is the European Commission's harmonised, LCA-based methodology for calculating the environmental performance of products. The current version applies EF 3.2, which includes sixteen impact categories. A DPP for a product group covered by ESPR must use the applicable PEF rules and be verified by an independent party.
Tiered access to passport data
ESPR envisions a tiered access model: not every user sees every field. A consumer-facing view might show the product name, footprint highlights, and care instructions, while a market surveillance authority sees exact substance concentrations, manufacturing UFI, and full PEF reports.
- Tier 1 — Public and consumer: basic product identity, footprint summary, safety data, and end-of-life guidance.
- Tier 2 — Professional and treatment operators: declaration of conformity, responsible EU operator, importer details, and detergents ingredient list.
- Tier 3 — Value chain operators: full PEF report, aggregated datasets, manufacturing identifiers, and detailed material composition.
- Tier 4 — Market surveillance and customs: exact substance concentrations, manufacturing UFI, and full audit trail.
How Winnow Technology helps producers issue DPPs
Winnow Technology is developing PEF compliant LCA methodologies for the FMCG sector. Our platform converts supplier direct data into audit-grade Product Environmental Footprint assessments, connects producers to independent, qualified third-party validation partners, and generates a compliant Digital Product Passport in the ESPR format. Our platform includes:
- Supplier onboarding: a structured, step-by-step form for formulation, packaging, manufacturing, and distribution data.
- CSV portfolio import: bulk upload product ranges, categories, and identifiers.
- PEF calculation: EF 3.1 impact categories and the Commission Recommendation methodology.
- Independent verification: a dedicated validator workspace reviews the assessment and issues the verification statement.
- DPP issuance: the passport is generated with a unique passport ID, version, and valid-until date, ready for registry upload and QR-code linking.
- Tiered public view: the public passport view shows only the fields the viewer is authorised to see.
Timeline and preparation steps
ESPR entered into force in July 2024. The first product-specific delegated acts are expected in the coming years. Producers can prepare now by collecting product data, identifying substances of concern, mapping supply chains, and aligning with a verified PEF provider.
Frequently asked questions
Is a DPP the same as an EPD?
No. An Environmental Product Declaration (EPD) is typically a type-III lifecycle label under ISO 14025. A DPP is a regulatory instrument under ESPR with structured data, registry integration, and tiered access. They can complement each other, but they serve different purposes.
Does a DPP need to be verified?
Yes. The ESPR framework requires verification of the sustainability information before the passport is issued, and the verification statement must be included in the DPP.
What happens if a product changes?
A DPP is versioned. Reformulation, packaging changes, new manufacturing sites, or annual recalculation cycles trigger updates. Winnow Technology maintains a change log and automatically bumps the passport version.
Which products need a DPP first?
The Commission prioritises products with high environmental impact and potential for improvement. Initial groups are expected to include textiles, iron and steel, aluminium, furniture, tyres, detergents, lubricants, and ICT products. Surface cleaning products sit within the broader chemicals and detergents scope.
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