ESPR & the Digital Product Passport: A Roadmap to Sustainable Competitiveness

The European Commission’s Ecodesign for Sustainable Products Regulation (ESPR) [1] marks a decisive step toward a more circular, transparent, and resource-efficient economy. Central to its implementation is the Digital Product Passport (DPP) - a system designed to embed sustainability data into the very fabric of products circulating on the European market.

More than a regulatory tool, the DPP represents a fundamental information infrastructure for sustainable industry, connecting products, data, and stakeholders across the value chain. It will enable manufacturers, suppliers, consumers, and authorities to access trusted lifecycle information, thus transforming how sustainability is measured, verified, and acted upon.

Purpose and Vision

At its core, the Digital Product Passport serves as a digital identity for each product, carrying verified data on composition, origin, performance, and environmental footprint throughout the entire lifecycle. It operationalizes the European Green Deal’s principle of “sustainability by design,” ensuring that every product placed on the market contributes to a circular and climate-neutral economy.

The DPP’s policy goals - as defined by the European Commission (DG Environment, 2024) [2] - are threefold:

• Sustainability: to make the environmental performance of products measurable and comparable.
• Circularity: to enhance reuse, repair, refurbishment, and recycling through access to structured product data.
• Legal compliance: to simplify market surveillance and regulatory enforcement through standardized digital documentation.

Technically, the DPP follows a decentralized data model where information remains distributed across trusted actors and systems, rather than stored in a single EU database. Access will be granted on a “need-to-know” basis, balancing transparency with protection of business-sensitive data. This approach ensures that every participant - from regulators and recyclers to OEMs and consumers - can access only the information relevant to their role, ensuring both interoperability and confidentiality.

A scannable QR code on the product or packaging links directly to its Digital Product Passport, providing a public summary while gating business-sensitive fields by role. For economic buyers, the public view exposes harmonized, machine-readable indicators that enable apples-to-apples comparison across suppliers: verified product identity, key sustainability KPIs such as product carbon footprint, recycled content, reparability information, and declared substances of concern. This supports sourcing policies, RFP scoring, and compliance checks, and it lets procurement systems ingest the data automatically to benchmark offers and validate claims at audit time. The same QR anchor persists over the lifecycle, so updates to performance or sustainability data remain discoverable and traceable.

Core Design Principles

The technical and governance principles of the DPP are becoming increasingly clear through standardization work (CEN/CENELEC JTC 24) and policy documents such as the BAM 2024 study and the EC FAQ (Sept 2024). The system is being built around the following core design features:

• Unique Identifiers: Each DPP must contain four persistent identifiers - for the product, the economic operator, the facility, and the registry - enabling traceability throughout the lifecycle.
• Persistent Data Carrier: Access to the DPP will typically be enabled through a QR code or digital tag directly on the product, its packaging, or accompanying documentation.
• Interoperability and Open Standards: Data must be machine-readable, searchable, and based on open, interoperable standards to ensure compatibility across EU sectors and digital platforms.
• Granularity Levels: Information can be defined at the level of model, batch, or individual item, depending on the complexity of the value chain.
• Integration with Existing Systems: To avoid duplication, the DPP architecture will interface with established European databases such as SCIP (for substances of concern), EPREL (for energy labelling), and ICSMS (for market surveillance).

Together, these principles define the DPP as an evolutionary step in digital product traceability - one that merges regulatory compliance with industrial innovation.

Horizontal vs. Product-Specific Implementation

The DPP framework will evolve in two complementary dimensions:

• Horizontal DPP Architecture: A common digital and technical framework applicable across all sectors is to be finalized by the end of 2025. This will define the core IT infrastructure, interoperability standards, and governance model for DPP deployment across the single market.
• Product-Specific Delegated Acts: The actual data content (“what information must be provided”) will be set through delegated acts under the ESPR, tailored to each product group. These acts will define specific sustainability parameters, data formats, and obligations for sectors such as textiles, furniture, batteries, and electronics.
• Alignment with the Battery Passport: The Digital Battery Passport, established under Regulation (EU) 2023/1542, serves as a precursor and reference model for the DPP system. Both initiatives share an interoperable data architecture and governance principles to ensure coherence across regulatory domains.

Key Milestones

The implementation of the ESPR and DPP will unfold through a structured series of milestones:

• June 2024: Adoption of the ESPR (Regulation EU 2024/1781), replacing Directive 2009/125/EC and establishing a binding framework for sustainable products.
• Q2 2025: Publication of the ESPR Working Plan 2025-2030, identifying the first wave of product groups to be regulated, including textiles, furniture, tyres, and selected electronics.
• End 2025-2027: Release of the first horizontal DPP system specification through CEN/CENELEC JTC 24, defining core interoperability and data exchange standards.
• February 2027: Digital Battery Passport becomes mandatory under Battery Regulation (EU) 2023/1542 for EV, industrial, and light-transport batteries exceeding 2 kWh.
• 2027-2030: Rollout of the first ESPR product-group delegated acts with 12-18-month transitions, gradually expanding DPP obligations to additional sectors such as construction materials, machinery, and consumer electronics.

Delegated Acts Process

The development of delegated acts follows a transparent, multi-stakeholder approach:

• Industry Consultation: Conducted via the Ecodesign Forum, ensuring input from manufacturers, sector associations (e.g., VDMA), and market surveillance authorities.
• Impact Assessments: Each delegated act undergoes environmental, economic, and social evaluation to ensure proportionality and technical feasibility.
• Transition Periods: Once adopted, delegated acts will include 12-18 months of transition before enforcement, allowing industry time to adapt digital systems, product design, and supply-chain data flows.

Regulation (EU) 2023/1542 - Digital Battery Passport

The Digital Battery Passport represents the first mandatory implementation of a DPP-type system in the European Union.
Under Regulation (EU) 2023/1542 [3], every electric-vehicle, light-transport and industrial battery with a capacity exceeding 2 kWh must carry a QR-code-based passport by February 2027.

The passport ensures end-to-end transparency, enabling regulators, recyclers, and consumers to access verified lifecycle data, while supporting responsible sourcing and circular-economy objectives.

Key Data Categories

Under Regulation (EU) 2023/1542 and accompanying Commission guidance, the battery passport comprises both static and dynamic data sets.

Grounded in the EU Batteries Regulation 2023/1542 and further distilled by several consortia [4], the battery passport is an electronic record that combines model-level facts with per-battery lifecycle data so buyers, operators, and authorities can verify compliance and compare performance over time. The required attributes can typically be grouped into static and dynamic sets and additional details on due diligence and interoperability expectations:

• Static data: product model, chemistry, manufacturer, declared carbon footprint, and material composition.
• Dynamic data: state of health, cycle count, performance indicators, and service history including repurposing and recycling events.
• Due diligence and ethical sourcing: supply-chain transparency for critical raw materials as required by Regulation (EU) 2023/1542, as amended by Regulation (EU) 2025/1561.
• Interoperability: alignment with the EU Digital Product Passport architecture and standardization work (CEN/CENELEC JTC 24) and the emerging Battery Data Space to ensure long-term cross-sector compatibility.

What could your Digital Product Passport look like?

AVL’s Digital Battery Passport is a production-proven platform that captures model-level and unit-level battery data across the full lifecycle and turns it into operational value. 

Built on Microsoft Azure for security, scalability, and global availability, it integrates with existing engineering and enterprise systems to ingest manufacturing, use, and end-of-life data, then exposes it via interoperable APIs for tracking, analytics, and reporting. Automated checks generate audit-ready evidence for the EU 
Batteries Regulation and ESG disclosures, while data notarization safeguards integrity for claims and supplier assurance. Beyond compliance, the platform applies analytics to extend battery life, optimize maintenance, improve recycling yields, and surface KPIs such as CO₂ footprint, material composition, and recovery rates. 

AVL pairs the software with consulting on requirements, data mapping, and OEM ecosystem onboarding, and continuously hardens the solution in its own Battery Innovation Center. The roadmap adds generative AI and intelligent agents for health monitoring, anomaly detection, and closed-loop process optimization - positioning the passport as a strategic data layer for sustainable, data-driven battery business.

AVL’s platform is DPP-native and extends beyond batteries. It supports different Vehicle Passports, like the Environmental, Circular or Digital Vehicle Passport, through the same architecture for unique identifiers, role-based access, and interoperable APIs. Data models are modular, so additional product passports can be configured for other components and products without rework. This enables multi-passport programs across vehicle and supplier fleets on one stack.

Lessons for Other Sectors

The battery passport offers valuable insights for industries preparing for DPP integration:

• The importance of technical readiness and early investment in digital identity infrastructure.
• The need for governance models that clearly assign responsibility for data accuracy and updates.
• The central role of interoperability standards to enable supply-chain-wide data exchange.
• The strategic advantage of establishing a data-management strategy well before compliance deadlines.

Challenges Ahead

The implementation of ESPR and DPP will reshape how industries design, document, and manage products. Key challenges include:

• Data availability and quality: Collecting consistent lifecycle data across complex global supply chains.
• Interoperability and confidentiality: Balancing transparency requirements with protection of intellectual property and trade secrets.
• Regulatory uncertainty: Staggered delegated acts may lead to unclear timelines for some product categories.
• Economic impact: SMEs and Tier-2/3 suppliers may face higher implementation costs and capacity constraints.

Opportunities for Industry Leaders

Forward-looking companies can leverage DPP implementation as a strategic enabler:

• Use DPP data as the foundation for data-driven services such as predictive maintenance, repair, and circular value-recovery.
• Differentiate through transparency and trust, especially in B2B markets where sustainability data is a purchasing criterion.
• Integrate the DPP into digital-twin and product lifecycle management systems, strengthening product intelligence and traceability.
• Develop new business models that monetize sustainability data - e.g., offering digital compliance or sustainability insights as a service.

Recommendations for Action

To prepare effectively, industry leaders should take early, structured action:

1. Conduct a DPP readiness assessment to identify data gaps and technical capabilities.
2. Map existing product and material data to anticipated ESPR and delegated-act requirements.
3. Engage actively in standardization and consultation (CEN/CENELEC JTC 24, Ecodesign Forum) or partner with a competent DPP platform vendor that actively participates.
4. Build cross-functional teams combining product management, IT, compliance, and sustainability expertise.
5. Pilot DPP and digital identity projects now, aligning with emerging EU data standards and upcoming delegated acts.

The ESPR and the Digital Product Passport represent more than new compliance obligations. They are transformational instruments that redefine how industrial value chains operate in a data-driven, sustainable economy.

By integrating regulatory compliance with digital innovation, the DPP enables transparency, traceability, and trust - the cornerstones of a competitive European manufacturing sector.

Between 2025 and 2027, the foundation of this new digital sustainability infrastructure will be laid. Companies that act early will not only meet regulatory expectations but will position themselves as leaders in a circular and connected industrial landscape.

• [1]: EUR-Lex - 02024R1781-20240628 - EN - EUR-Lex
• [2]: Ecodesign for Sustainable Products Regulation - European Commission
• [3]: EUR-Lex - 02023R1542-20250731 - EN - EUR-Lex
• [4]: e.g., thebatterypass.eu Data Attribute Longlist