Digital Product Passport (DPP): What EEE and HVAC Manufacturers Should Anticipate

Within a few years, a buyer, a design office or a recycler will be able to scan a code on your equipment and access, in seconds, its composition, carbon footprint and repairability data. This mechanism has a name: the Digital Product Passport (DPP). For manufacturers of electrical and electronic equipment (EEE) and HVAC systems, it is not a communication option but a regulatory requirement that is being rolled out progressively. This article explains what the DPP is, what data it will contain, when it will affect your products, and how to prepare today by building on your LCAs and PEP declarations.

What is the Digital Product Passport (DPP)?

The Digital Product Passport is a structured set of environmental and technical data, linked to a product through a unique identifier. In practice, a physical data carrier (QR code, NFC tag or RFID chip) placed on the product, its packaging or its documentation gives access to this information throughout the life cycle.

One point is often misunderstood: the DPP is not a central database that hosts your information. The European Union is setting up a central registry that works as a directory. From the product identifier, it points to the location where the data is actually stored, with the manufacturer or its service provider. Each passport relies on unique identifiers for the product, the economic operator and the production facility.

The goal is clear: to make a product’s environmental information verifiable, comparable and accessible to all actors in the value chain, from buyers to recyclers.

The DPP, the cornerstone of the ESPR

The Digital Product Passport stems from the European Ecodesign for Sustainable Products Regulation, the ESPR (Regulation (EU) 2024/1781), which entered into force on 18 July 2024. The ESPR is a framework regulation: it establishes the principle of the DPP, while the concrete obligations for each product category are then defined through delegated acts.

Several milestones shape this rollout: the first ESPR Working Plan 2025-2030, adopted on 16 April 2025, identifies the priority product groups, which include electronics and ICT products. A European digital registry is due to be operational on 19 July 2026 to securely store passport identifiers. The technical specifications of the system are being developed by the CEN-CENELEC JTC 24 standardisation committee, with harmonised standards expected during 2026.

What data will a DPP contain?

The exact content will be specified category by category, but the main data families are already known:

• Identification: product, manufacturer, production facility.
• Composition: materials, presence of substances of concern (SVHC above 0.1% w/w), recycled material content.
• Environmental performance: Life Cycle Assessment (LCA) results, carbon footprint, circularity indicators.
• Repairability and end of life: spare parts availability, ease of disassembly, recycling instructions.
• Certifications and declarations: CE marking, environmental declarations (EPD, PEP), labels.

The heart of the passport therefore relies on data derived from the LCA. Without a robust life cycle assessment, it is impossible to report the carbon footprint or the required environmental indicators.

When will the DPP become mandatory for EEE and HVAC?

The rollout is progressive and works category by category, through delegated acts. Here are a few reference points, to be treated as indicative since the schedule may still evolve:

• The battery passport is the first mechanism of this kind with a fixed legal date: it becomes mandatory on 18 February 2027 for electric vehicle batteries, industrial batteries above 2 kWh and light means of transport batteries, under the Batteries Regulation (EU) 2023/1542.
• The first ESPR delegated acts concern categories such as steel, expected from 2026.
• Electronics and ICT products, confirmed as priorities, are expected to see their delegated acts adopted around 2028-2029, for application around 2029-2030.
• Horizontal requirements on recycled content and recyclability of EEE are expected on an indicative 2029 horizon.

Once a delegated act enters into force, manufacturers usually have at least 18 months to comply. The message is simple: even if the precise date for your category is not yet fixed, the direction is unambiguous and lead times are long.

LCA and the PEP declaration, the foundation of your future DPP

This is where the essential point lies for manufacturers in the sector. The DPP does not create new data: it makes visible and enforceable environmental information that must already exist and be verified. For EEE and HVAC equipment, this information takes the form of a PEP declaration (Product Environmental Profile) or, more broadly, an EPD (Environmental Product Declaration). In other words, every PEP is an EPD, but not all EPDs are PEPs.

A PEP declaration is a standardised declaration (ISO 14025, EN 15804+A2, EN 50693), based on an LCA and verified by a third party, under the PEP ecopassport® programme. This is precisely the type of verified data that the DPP will expose. To understand how a PEP declaration is built step by step, you can read our dedicated article on producing a PEP.

The key point of attention: producing a certified LCA and a PEP declaration usually takes 12 to 24 months. Anticipating your DPP therefore means, above all, anticipating your LCAs.

How to prepare your Digital Product Passport today

Four steps make it possible to approach the deadline with confidence:

1. Map the products concerned and audit the data already available.
2. Structure data collection across your supplier chain (materials, energy, transport, end of life).
3. Conduct the LCAs and certify the PEP or EPD declarations for your priority products.
4. Organise the management of this data so it can later be linked to a unique identifier.

Depending on your internal resources, two approaches are possible. If you prefer to delegate, the Qweeko Start offer entrusts the production of your PEP declarations to our LCA experts, from A to Z. If you want to internalise and deploy LCA across your entire catalogue, the Qweeko Pro platform integrates the PCR and PSR methodological frameworks of the PEP ecopassport® programme and automates the generation of your declarations.

FAQ

Does the Digital Product Passport replace the PEP declaration?
No. The PEP, or the EPD, remains the reference environmental declaration, based on the LCA and verified by a third party. The DPP does not replace it: it exposes it, alongside other information such as composition, repairability or end of life.

Are my electronics or HVAC products concerned?
Electronics and ICT products are among the priority categories identified in the ESPR Working Plan. HVAC systems will gradually enter the scope through delegated acts.

What is the difference between the DPP and the energy label?
The energy label communicates a few summary indicators to the consumer. The DPP goes much further: it gives access to a structured set of data covering the entire life cycle, intended for all actors in the value chain.

Where will my DPP data be stored?
The data is not hosted in the European registry, which acts as a directory. It is stored by the manufacturer or its service provider, and made accessible through the product’s unique identifier.

When should I start preparing?
Now. The data that will feed your DPP relies on LCAs and PEP declarations that take 12 to 24 months to produce. Waiting for the delegated act covering your category to be published creates a real risk of non-compliance.

In summary

The Digital Product Passport turns the LCA and the PEP declaration into prerequisites for access to the European market. Rather than waiting for the deadline, take the lead by structuring your products’ environmental data today. Whether you choose to delegate with Qweeko Start or internalise with Qweeko Pro, our teams help you produce reliable, compliant PEP declarations, ready to feed your future digital passports.