EU’s Digital Product Passport: What It Is, Which Products It Affects, and How to Prepare

The DPP does not only apply to companies based in the EU. All products in the relevant categories that enter the EU market, regardless of their country of manufacture, must have a corresponding DPP. Swiss companies that export to the EU should therefore familiarize themselves with the DPP requirements as soon as possible to ensure their presence on the EU market.

What is the DPP, and what are its objectives?

The DPP is a digital record containing essential product information (e.g. health, safety, sustainability, composition and lifecycle) established by the Regulation on Ecodesign for Sustainable Products (ESPR) dated 13 June 2024.

It will be accessible via a data carrier that shall be “physically present on the product, its packaging, or [its] accompanying documentation”.

The DPP shall notably include information related to:

• performance of the product (e.g. repairability score, durability score, carbon footprint, etc.);
• user manuals, instructions, etc;
• information for treatment facilities on disassembly, reuse, refurbishment, recycling, etc.

Which products and sectors are affected?

As a reminder, the DPP is intended to apply to “any physical product that is placed on the market or put into service,” with the exception of a limited list of products (i.e. foodstuffs; animal feed; medicines; veterinary medicines; living plants, animals, or microorganisms; products of human origin; products of plants and animals directly related to their future reproduction; vehicles).

Batteries should be covered by the DPP as of February 18, 2027 (in accordance with Article 77 of Regulation (EU) 2023/1542, which covers all industrial batteries with a capacity greater than 2 kWh and all electric vehicle batteries placed on the market or put into service, see also our article on the EU battery passport).

With regard to other products, delegated acts of the European Commission will subsequently have to define the product groups covered by the DPP and the implementing rules.

2025-2030 Work Plan

The 2025-2030 Work Plan adopted on April 15, 2025, by the European Commission lists the priority products for which eco-design requirements—and therefore information via a DPP—will be developed progressively between 2026 and 2030. This plan sets indicative targets and provides estimates of when the delegated acts will be published, distinguishing between:

• End products:
  • Textiles and clothing: 2026
  • Tires: 2027
  • Furniture: 2028
  • Mattresses: 2029
• Intermediate products:
  • Iron and steel: 2026
  • Aluminum: 2027

We are therefore – at this stage – awaiting the Commission's delegated acts.

Parties responsible for implementing the DPP

The obligation to implement the DPP lies with the economic operator who places the product on the market or puts it into service, regardless of where the product is manufactured.

This means that even if the product is manufactured outside the EU (e.g., Switzerland), it may be subject to the obligation to implement the DPP if it is covered by a delegated act of the Commission.

It should be noted that the primary parties responsible for implementing the DPP are manufacturers (i.e. any natural or legal person who manufactures or has a product designed or manufactured and markets it under their own name or brand) – including those not located within the EU.

However, the regulation stipulates that importers, distributors, and resellers are required to verify that the EPD is available before marketing the product. In the event of product non-compliance, importers must contact the supervisory authorities of the Member State concerned.

Unique Identifier

The data carrier must be easily readable and may be freely chosen by the manufacturer (e.g. barcode, QR code).

The aim is not to create a single, central database of product data sheets. On the contrary, the DPP shall be based on a decentralised data system set up and managed by the economic operators.

Moreover, to ensure access to the DPP, the economic operator placing the product on the market should make available a back-up copy through a “digital product passport service provider” (i.e. an independent third party).

How should companies prepare?

• Identify which products in their portfolio are likely to fall within the scope and monitor sector-specific implementing acts.
• Redesign products and packaging for compliance, and coordinate with suppliers, logistics providers, and other partners on data capture and labelling.
• Strengthen data capabilities (governance, quality, interoperability, security) to support DPP generation, maintenance, and access management.

Support for Swiss companies

Switzerland Global Enterprise, the Swiss Business Hubs and their experts are at the disposal of Swiss companies and their subsidiaries to assist them with these issues.