What is Digital Product Passport (DPP)?

Comprehensive Guide for Companies in the EU ESPR Era

The European Union is redefining products not only in terms of "energy efficiency" but also in terms of sustainability and traceability throughout their entire life cycle through the Ecodesign for Sustainable Products Regulation – ESPR. One of the most critical tools of this framework is the Digital Product Passport (DPP).

In the coming years, DPP will effectively become an "entry ticket" for many product groups placed on the EU market. This will directly affect not only companies manufacturing in the EU, but also all companies exporting from Turkey to the EU.

In this article, we examine DPP in detail in terms of:

• what it is,
• what legal basis it is based on,
• which products it will cover,
• what information it will contain,
• and how companies should prepare today.

What is Digital Product Passport (DPP)?

In short, the Digital Product Passport is a standardized digital dataset containing essential information that may be needed throughout the product's entire life cycle.

This passport collects and makes digitally accessible data such as:

• Product origin (where and by whom it was manufactured),
• Material composition,
• Environmental performance (carbon footprint, energy use, etc.),
• Regulatory compliance (e.g., ESPR, REACH, sectoral regulations),
• Maintenance, repair, reuse and recycling instructions.

It is typically associated with a QR code, barcode or RFID/NFC tag placed on the product. All stakeholders, from consumers to recycling facilities, can scan this code to access current information about the product.

In summary, DPP is a dynamic and updatable "product identity card" that goes beyond paper labels.

Legal Basis of DPP: ESPR and Sectoral Regulations

The legal basis of DPP is the Ecodesign for Sustainable Products Regulation (ESPR) – (EU) 2024/1781, which entered into force on July 18, 2024.

ESPR:

• Replaced the old Ecodesign Directive (2009/125/EC),
• Expanded its scope from energy-related products to almost all physical products (with some exceptions such as food, feed and medicines),
• Regulated that detailed sustainability requirements for products will be determined by "delegated acts" (secondary legislation adopted by delegation) to be published by the Commission.

In this context, the Digital Product Passport is defined as the official tool for managing information requirements under ESPR.

In addition, in some sectors, DPP-like digital passports are also made mandatory within sectoral regulations (e.g., Batteries, Toy Regulation draft, Detergent Regulation and other upcoming regulations).

Which Products Will Digital Product Passport Be Mandatory For?

ESPR does not introduce DPP obligation for all products at once. First, priority product groups are selected, then detailed rules are published for them.

The main product groups currently considered priority and expected to have DPP:

• Textiles and ready-made clothing,
• Electrical and electronic equipment,
• Batteries (battery passport is already mandatory under a separate regulation),
• Furniture,
• Construction and building products (e.g., glass, concrete, insulation materials),
• Medium term: toys, detergents, some chemical products and other consumer products.

The DPP entry point for the first product groups is planned to come into effect from 2027 onwards; however, this timeline will be clarified according to the special regulations (delegated acts) to be published for each product group.

What Information Will Be in DPP?

The content of DPP will vary by product group. However, the common data categories highlighted in EU institutions and various guides are:

1. Product identity and traceability

• Product name, trade name, model/version,
• Manufacturer name, address, contact information,
• Date of first placing on the EU market,
• Unique product identifier (e.g., GS1-based ID, serial number),
• Production batch/lot number, production facility information.

2. Material composition and chemical content

• Basic materials and composition ratios,
• Recycled content share (pre-/post-consumer),
• Presence of SVHC (substances of very high concern) under REACH and related notifications,
• Critical raw materials (under CRMA) if applicable.

3. Environmental performance

• Carbon footprint per product (e.g., kg CO₂-eq),
• Energy and water use indicators,
• EPD (Environmental Product Declaration) reference if available,
• Indicators for durability, repairability, reuse, recyclability.

4. Regulatory and compliance information

• Compliance with ecodesign requirements under ESPR,
• Relevant sectoral regulations (e.g., Construction Products Regulation – CPR, Battery Regulation, Toy Regulation, etc.),
• Conformity assessment procedure and declarations (CE, DoP, etc.),
• References to test reports and certificates.

5. Use, maintenance and repair

• Usage instructions,
• Guidelines for maintenance, cleaning, repair, parts replacement,
• Recommendations to extend product life.

6. End of life and recycling

• Disassembly and parts separation instructions,
• Applicable waste codes and disposal options,
• Technical information for recovery/recycling,
• Additional data fields for recycling facilities.

Who Will Benefit from DPP and How?

The Digital Product Passport offers different advantages for all actors in the value chain:

Manufacturers and importers:

• A standard tool to prove legal compliance,
• Transparency and trust in the supply chain,
• Competitive advantage for green public procurement and sustainability-focused customers.

Retailers and brands:

• Providing reliable sustainability information to consumers,
• Managing product portfolio according to sustainability criteria.

Consumers:

• Making informed decisions in product selection,
• Knowing where the product comes from, how it was produced, how it should be disposed of.

Recycling and waste management sector:

• Planning more efficient recycling by knowing material composition,
• Producing high-quality secondary raw materials.

Supervisory authorities:

• Fast and standardized data access in compliance audits,
• Effectiveness in market surveillance processes.

What Does DPP Mean for Companies Exporting from Turkey to the EU?

ESPR and DPP rules legally treat EU-internal production and imports to the EU in the same framework. That is, if a product you manufacture in Turkey is placed on the EU market, it will fall within the scope of DPP.

This situation requires updating not only your production processes, but also your supply chain, data management and IT infrastructure.

For exporters who prepare for DPP in time, this process will also mean:

• A more transparent and reliable profile compared to competitors,
• Being preferred in green deal and sustainability-focused projects,
• A positive signal in financing and investment decisions in the long term.

What Should Companies Do Today?

Step-by-Step DPP Preparation Roadmap

While waiting for the detailed additional requirements of the regulation, companies can make significant progress today by taking these steps:

1. Product portfolio and risk analysis

List the products you export to the EU.

Identify which of these products may fall into priority DPP groups such as textiles, electronics, construction products, batteries, etc.

2. Create a data inventory

Collect the data you already have for each product:

• Material composition and chemical content,
• Supplier information and certificates,
• Technical performance data, test reports,
• LCA studies, carbon footprint calculations, EPDs,
• Usage, maintenance, recycling instructions.

Identify missing data and perform a "data gap analysis."

3. Establish responsibility and governance model

Identify the team or function that will be responsible for DPP data (e.g., Compliance/Regulation + Environment/LCA + IT triangle).

Assign a "data owner" for each data field (who collects, who approves, who updates).

4. Plan IT and coding infrastructure

• Determine the unique identity structure to be used for products (GS1, etc.).
• Plan the use of QR codes, barcodes or RFID on your product labels.
• Choose the infrastructure where you will store DPP data:
  • Your own developed database + web interface, or
  • A DPP-compliant SaaS platform (traceability / product passport solutions).

5. Involve your suppliers in the process

• Share DPP requirements with your suppliers.
• Add provisions on data sharing and transparency to contracts if necessary.
• Establish a traceability chain for critical raw materials and sub-components.

6. Conduct pilot DPP projects

Select one or two priority products and test the full DPP cycle as a pilot:

• Data collection,
• Creation of DPP,
• Field testing with QR code (customer, dealer, service, recycling, etc.).

Pilot projects are the best learning area to avoid shock when the obligation comes in the future.

7. Training and internal communication

• Inform sales, marketing, quality, production and logistics teams about ESPR and DPP.
• It is important that teams working with EU customers know how DPP can be turned into a sales argument.

Special Note on Construction and Glass Sector

For construction products, DPP has special importance under the revised Construction Products Regulation (CPR). The EU is working on the CPR DPP system for the digitalization of product information in the construction sector and its association with the CE mark.

For products such as flat glass, window systems, facade panels:

• Technical performance values of the product (thermal conductivity, light transmittance, solar control, etc.),
• Coatings and interlayers used,
• Carbon footprint and recyclability potential,

such data will be shared with designers, contractors and recyclers through DPP. This creates great opportunities both for being preferred in green building projects and for the formation of high-quality glass cullet flows.

Frequently Asked Questions (FAQ)

When will DPP become mandatory?

DPP becomes mandatory for selected product groups under ESPR after a certain period (usually around 18 months transition period) after the relevant delegated act is published. The application is expected to start from 2027 for the first product groups.

Do manufacturers in Turkey have to prepare DPP?

If your product is placed on the EU market (export, sales within the EU, etc.), yes, you will be required to prepare DPP when it becomes mandatory for your product group. The fact that the product was manufactured in Turkey does not change this obligation.

Is DPP the same as "material passport"?

Material passport is a concept used especially for buildings and the construction sector and identifies materials within the structure. Digital Product Passport, on the other hand, is a product-based, broader legal tool under ESPR. The two concepts are closely related, and in many cases material passport data can be considered a sub-component of DPP.

Does DPP consist only of environmental data?

No. Although environmental data is very important in DPP, it also includes:

• Product identity and traceability,
• Regulatory compliance, conformity assessment,
• Technical performance values,
• Usage, maintenance, repair and recycling information

all together. So DPP is both a sustainability and a compliance and traceability tool.

Conclusion: DPP is Not a Burden, But a Strategic Investment

The Digital Product Passport may seem like a "new data burden" at first glance. However, when properly structured, it provides companies with:

• A stronger EU compliance profile,
• Transparency and trust throughout the value chain,
• Better product and supply chain management,
• Concrete and measurable advantages in sustainability and circularity.

For companies exporting from Turkey to the EU in particular, staying ahead of the ESPR and DPP agenda will be the smartest way to make a controlled and strategic transition without panic when it becomes mandatory in the future.