Within a few years, a buyer, an engineering firm or a recycler will be able to scan a code on your equipment and access, in a few seconds, its composition, its carbon footprint and its repairability data. This mechanism has a name: the Digital Product Passport (DPP). For manufacturers of electrical, electronic (EEE) and HVAC equipment, it is not a communication option, but a regulatory obligation being phased in gradually. This article explains what the DPP is, what data it will have to contain, when it will concern your products, and how to prepare for it today by drawing on your LCAs and your PEPs.
What is the Digital Product Passport (DPP)?
The Digital Product Passport is a structured set of environmental and technical data, attached to a product via a unique identifier. Concretely, a physical data carrier (QR code, NFC tag or RFID chip) affixed to the product, its packaging or its documentation gives access to this information throughout the life cycle.
A point often misunderstood: the DPP is not a central database that would host your information. The European Union is setting up a central registry that works like a directory. From the product's identifier, it points to the location where the data is actually stored, at the manufacturer or its provider.
The objective is clear: to make a product's environmental information verifiable, comparable and accessible to all players in the value chain, from buyers to recyclers.
The DPP, cornerstone of the ESPR regulation
The Digital Product Passport stems from the European regulation on the ecodesign of sustainable products, the ESPR (Regulation (EU) 2024/1781), which came into force on 18 July 2024. The ESPR is a framework regulation: it establishes the principle of the DPP, but the concrete obligations by product category are then defined by delegated acts.
Several milestones structure this rollout: the first ESPR 2025-2030 work plan, adopted on 16 April 2025, identifies the priority categories, among which are electronic products and information technologies. A European digital registry is to be operational by 19 July 2026. The system's technical specifications 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 families of information are already known:
- Identification: product, manufacturer, production site.
- Composition: materials, presence of substances of concern (SVHC above 0.1% m/m), share of recycled materials.
- Environmental performance: Life Cycle Assessment (LCA) results, carbon footprint, circularity indicators.
- Repairability and end of life: availability of parts, ease of disassembly, recycling instructions.
- Certifications and declarations: CE marking, environmental declarations (EPD, PEP), labels.
The heart of the passport therefore rests on data 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 gradual and works category by category, via delegated acts. Here are some markers, to be taken as indicative:
- The battery passport becomes mandatory on 18 February 2027 for electric-vehicle batteries, industrial batteries above 2 kWh and light-means-of-transport batteries (Batteries Regulation (EU) 2023/1542).
- The first ESPR delegated acts concern categories such as steel, expected from 2026.
- Electronic products and information technologies, confirmed as priorities, should see their delegated acts adopted around 2028-2029, for application around 2029-2030.
- Horizontal requirements on recycled content and the recyclability of EEE are expected at an indicative horizon of 2029.
After a delegated act comes into force, manufacturers in principle have at least 18 months to comply. Even if the precise date for your category is not yet set, the trajectory is unambiguous and preparation times are long.
The LCA and the PEP, the foundation of your future DPP
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 or, more broadly, an EPD. In other words, every PEP is an EPD, but not all EPDs are PEPs.
A PEP 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 the DPP will expose. To understand how a PEP is built step by step, see our dedicated article on producing a PEP.
The point of vigilance: producing a certified LCA and a PEP generally takes 12 to 24 months. Anticipating your DPP therefore means, above all, anticipating your LCAs.
How to prepare your Digital Product Passport now
- Map your affected products and audit the data already available.
- Structure data collection from your supplier chain (materials, energy, transport, end of life).
- Carry out the LCAs and certify the PEPs or EPDs of your priority products.
- Organise the management of this data so you can link it tomorrow 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 PEPs to our LCA experts. If you want to in-house, the Qweeko Pro platform integrates the PCR and PSR frameworks of the PEP ecopassport® programme and automates the generation of your declarations.
FAQ
Does the Digital Product Passport replace the PEP?
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 electronic or HVAC equipment concerned?
Electronic products and information technologies are among the priority categories identified in the ESPR work plan. HVAC equipment will gradually enter the scope via the delegated acts.
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 provider, and made accessible via the product's unique identifier.
When should you start preparing?
Right now. The data that will feed your DPP rests on LCAs and PEPs whose production takes 12 to 24 months.
In summary
The Digital Product Passport turns the LCA and the PEP into prerequisites for access to the European market. Rather than enduring the deadline, take the lead by structuring the environmental data of your products today.