The EU's Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, Chapter III, establishes Digital Product Passports. DPPs are structured, machine-readable data records linked to each packaging item via QR code — containing material composition, recyclability, recycled content, and recycling instructions. Packgine helps brands build the data infrastructure they need to be DPP-ready.
By Kevin Kai Wong, Managing Partner, gCurv Technologies
A Digital Product Passport (DPP) is a structured, machine-readable data record linked to a product via QR code or digital identifier. DPPs are established by the EU's Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, Chapter III, Articles 9 to 11, not by the PPWR. They will carry packaging composition, recyclability, recycled content, and environmental impact data accessible to consumers, recyclers, and regulators.
The DPP framework is set by the ESPR, Regulation (EU) 2024/1781, with product-group requirements delivered through delegated acts. Separately, the PPWR requires harmonised material-composition labels from August 2028 at the earliest.
Where an ESPR delegated act covers a packaged product, its DPP may carry material composition, weight, recyclability, recycled content percentage, producer identification, and end-of-life instructions. Brands need to collect and structure this data at SKU level.
DPP data overlaps significantly with EPR reporting data. Brands that maintain structured packaging data for EPR compliance are already building the foundation for DPP readiness.
The European Commission is developing standardized DPP data formats. Early adopters should structure their packaging data using existing frameworks like GS1 and RecyClass to ensure compatibility.
Building the data infrastructure takes time. Brands that start structuring packaging data now will be compliance-ready when requirements take effect.
Captures all DPP-required data points — material composition, recyclability grades, recycled content — at SKU level
Structures packaging data in formats compatible with emerging EU DPP standards
Links DPP data to existing EPR compliance workflows for maximum efficiency
Tracks applicable ESPR product DPP requirements and the PPWR's separate digital-carrier milestones
Generates DPP-ready data exports for integration with QR code and labelling systems
Maintains version-controlled packaging data history for regulatory audit purposes
A digital product passport is a structured digital record attached to a product or packaging unit, reachable through a data carrier such as a QR code that a consumer, recycler, or regulator can scan. The record holds composition, recyclability, recycled content, and related attributes so that information travels with the product across its lifecycle. For packaging producers this is less a new rule than a new way of having to expose data you should already hold, in a standardized and queryable form.
The hard part is not printing the carrier. It is having accurate, current data behind it at the right granularity. A passport pointing at incomplete or stale information is worse than none, because it publishes your data gaps. Producers with mature component-level packaging records adopt passports easily; those holding only SKU-level summaries have to decompose their data first, because one packaging unit routinely combines materials with different recyclability and recycled-content profiles.
Exact requirements follow delegated acts and product category, but packaging-relevant data generally covers material composition by component, recyclability classification, recycled content, presence of substances of concern, and instructions for sorting, reuse, or disposal. Each has to be a standardized field rather than free text, because the record is expected to conform to interoperability standards so different actors read it consistently. That means packaging data should live in a structured system designed to emit standardized records, not be assembled ad hoc whenever a passport is requested.
Passports arrive in phases across product categories under the ESPR, with packaging-relevant data duties landing alongside broader PPWR implementation rather than through a packaging passport. Because the timeline is staged, the efficient move is to build passport-ready architecture once and switch categories on as they come into scope rather than running each phase as a separate project. Passports, PPWR conformity, and national EPR declarations all draw on the same underlying attributes, so a single authoritative component-level dataset serves all three; maintaining separate datasets per regime is the common failure mode.
The PPWR does not require a packaging DPP; digital product passports come from the ESPR and packaging is not a product group in the 2025-2030 working plan. The PPWR uses digital data carriers for specific information (a QR code on reusable packaging from 12 Feb 2029 under Art 12(2), and digital-only EPR marking under Art 12(9)); where a packaged product has its own DPP, that passport carries the PPWR information.
The same structured data set also feeds fee modelling and the current EU PRO fee rates by member state and material, so a DPP-ready inventory is also the foundation for accurate cost projections.
Building the underlying dataset once means the same records answer passport queries and PPWR conformity documentation, rather than maintaining two parallel sources of truth.
There is no packaging DPP today. Under the ESPR, a DPP is a machine-readable data record linked to a product via QR code or digital identifier. Where a delegated act covers a packaged product, the record may carry packaging-related data such as material composition, recycled content, and recycling instructions.
The PPWR does not require a packaging DPP; digital product passports come from the ESPR and packaging is not a product group in the 2025-2030 working plan. Brands should begin building DPP-ready data infrastructure now.
Where a DPP applies to a packaged product, it can require material composition, weight, recyclability, recycled content percentage, producer identification, and end-of-life recycling or disposal instructions — all at the individual item level.
DPP data requirements overlap heavily with EPR reporting requirements. Brands already managing structured packaging data for EPR compliance have a significant head start on DPP readiness.
Yes. Packgine's packaging data platform captures all the data points required for DPPs — material composition, recyclability grades, recycled content, and producer information — and structures them for DPP compatibility.
Content reviewed by Kevin Kai Wong, Managing Partner at gCurv Technologies
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