Preparing for the Digital Product Passport (DPP): What Retailers Need to Know

This article is provided by BRC Associate Member, UL Solutions.

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The European Union (EU) is introducing the Digital Product Passport (DPP) as part of the Ecodesign for Sustainable Products Regulation (ESPR), with parallel requirements emerging under sector-specific legislation such as the Battery Regulation and the Toy Safety Regulation. Together, these initiatives mark a significant shift in how product information is generated, shared and verified across value chains. For retailers, understanding the implications — and preparing early — will be essential.

Why is the DPP Being Introduced?

The DPP is a cornerstone of the EU’s Circular Economy Action Plan and Green Deal. Its objective is to improve product transparency, enabling better decision-making by consumers, regulators and economic operators. By providing structured, accessible data on sustainability, safety and compliance, the DPP aims to extend product life cycles, facilitate repair and recycling, and support traceability throughout the supply chain.

Sector-specific legislation reinforces this objective. For example, the Toy Safety Regulation revision is expected to expand digital information requirements for product safety and conformity.

What is a DPP?

The EU DPP is a structured, machine-readable record that follows a product through its life cycle from raw materials to end of life, accessible through a data carrier (typically a QR code) printed on or embedded in the product.

DPP and Data Carriers — An Important Relationship

A key concept for retailers is the distinction between the DPP and the data carrier. The DPP refers to the structured set of digital information associated with a product. The data carrier, by contrast, is the physical or digital means used to access that information.

In practice, the data carrier could take the form of a QR code, barcode, radio-frequency identification (RFID) tag or similar technology applied to the product, packaging or accompanying documentation. The specific data carrier requirements will be clarified in the EU Commission acts and technical standards. Scanning or reading this carrier provides access to the DPP stored in a digital system.

Importantly, the data carrier is not the passport itself; it is simply the gateway. This distinction matters because while retailers may not manage all underlying data, they will often be responsible for verifying that the data carrier is present, functional and accessible at the point of sale and throughout the product life cycle.

What Information Will the DPP Include?

While delegated acts for each product group will define detailed requirements, the DPP is expected to include several categories of data differentiated by access rights, e.g., consumers, market surveillance, etc.

• Product and operator identification – Unique identifiers (unique product/facility/operator identifier); model, batch or item references; and commodity codes
• Information on chemical composition, including information on substances of concern that will need to be tracked throughout the products’ life cycle
• Environmental performance and information – Carbon and water footprint, durability, repairability, recycled content, recyclability
• Compliance documentation – Conformity certificates, declarations of conformity, technical documentation
• Life cycle information – Maintenance, repair, reuse and recycling instructions; expected generation of waste

DPP registry and the role of DPP service providers

An important emerging element of the DPP ecosystem is the DPP registry. This is expected to function as a system (or network of systems) that indexes and enables access to DPP via their unique identifiers. The registry will be established and maintained by the Commission and is expected to be set up by July 19, 2026.

A public consultation on the registry implementing act has recently been closed, and the final text is expected soon.

Along with the DPP registry, a new role as DPP service provider has also been established — an independent third party authorised by the economic operator that places the product on the market or puts it into service and that processes the DPP data for that product for the purpose of making such data available to economic operators and other relevant actors with a right to access those data under the applicable legislations.

In this case, a public consultation was also carried out in August 2025, and the adoption of the final delegated act is expected at the end of 2026.

In this regard, testing, inspection and certification (TIC) providers will play a critical role in enabling the DPP ecosystem.

Their functions may include verification of data accuracy, e.g., ensuring that product claims and technical data are reliable and compliant; certification and conformity assessment (linking verified compliance documentation to digital passports); supply chain assurance (supporting traceability and transparency across multiple tiers of suppliers); and serving as a DPP service provider.

As trusted third parties, TIC companies can help retailers and manufacturers navigate complex regulatory requirements while maintaining credibility with regulators and consumers.

What Is Still To be Defined?

Despite the clear regulatory framework, important elements are still under development, including the publication of standards and legislation related to data structures, IT architecture, access systems, and the specific requirements that will apply to individual product categories.

However, we know that toy and battery requirements are already available and will enter into force 1 August 2030 and 18 February 2027 (for certain batteries) respectively, and the draft delegated act for textiles is expected in the first quarter of 2027.

What Retailers Can Do Now

Although full implementation details are pending, there are concrete steps retailers can take to prepare:

• Map product portfolios – Identify categories likely to be prioritized under ESPR, e.g., textiles, electronics, batteries.
• Engage suppliers – Assess current data availability and establish expectations for transparency and data sharing.
• Collaborate with partners – Ensure alignment on testing, certification and digital compliance requirements.

Early action will not only help reduce compliance risks but also position retailers to leverage the DPP as a tool for differentiation, enhancing consumer trust and supporting sustainability claims.

In summary, the DPP represents a transformative regulatory development.

UL Solutions can help

For more details and to know more on how UL Solutions can support your business, please contact katie.ellen.moore@ul.com