DPP and Extended Producer Responsibility: What EU Manufacturers Need to Know

If you manufacture for the EU market, extended producer responsibility is not new to you. Producers already pay into schemes for packaging, batteries and electrical equipment. For many companies it still feels like a tax: a fee to a producer responsibility organisation, calculated from the tonnes placed on the market, with little connection to how the product was designed.

That connection is now being made. EPR fees are increasingly modulated by the characteristics of the product, and the Digital Product Passport is where those characteristics are recorded. Your responsibility as a manufacturer no longer ends at the loading bay. It follows the product through use and repair to the point where it becomes raw material again.

What is changing in EPR

EPR was built to pay for collection and recycling at the end of a product's life. The EU framework now pushes the question upstream, to design.

The Ecodesign for Sustainable Products Regulation (ESPR) sets requirements for how products are made: durability, repairability, recycled content, substances of concern. The DPP is how a manufacturer shows that its product meets them, and the same data is what an EPR scheme needs to set a fair fee.

Textiles are the next EPR obligation

The revised Waste Framework Directive, (EU) 2025/1892, makes EPR for textiles mandatory across the EU. Member States must transpose it by 17 June 2027, textile EPR schemes must be in place by April 2028, and micro-enterprises get one more year, until 17 April 2029. The obligation is European. Fee levels, registration and the ways of meeting it are national, so a brand selling into several Member States will deal with several schemes.

Packaging is a separate obligation under the Packaging and Packaging Waste Regulation (EU) 2025/40, which applies from 12 August 2026. A clothing brand will usually pay for the garment and for its packaging under different schemes.

From flat fees to eco-modulation

Eco-modulation means the fee depends on the product. Schemes adjust it for characteristics such as recyclability, recycled content, durability, repairability and the presence of hazardous substances.

• A product that is easy to take apart and recycle pays less.
• A product made of materials that cannot be separated, or containing substances of concern, pays more.

To qualify for a lower rate you need evidence: composition, recycled content and end-of-life information, which is exactly what a passport holds. Without it, a product is unlikely to get the lower fee.

How the DPP helps

Reporting from one source

EPR reporting is still largely manual: weights and material shares compiled from spreadsheets every quarter or year. When composition, weight and origin already sit in structured passports, the declaration can be generated from the same data, with fewer errors to explain at an inspection.

Answering your customers

Many manufacturers supply larger brands and retailers, and those customers need product data for their own EPR declarations and sustainability reporting. A supplier that cannot deliver it in a usable digital form becomes a risk in the supply chain, however good the product.

Supporting repair and reuse

Longer product life is one of the aims of EPR. A passport can carry:

• Disassembly instructions and repair guides.
• A spare-parts catalogue and where to order from it.
• Software and firmware information for products with electronics.

Published openly, this information helps meet the legal requirements and supports the reputation of a brand that builds products to last.

Which sectors feel it first

The passport reaches product groups in stages, and its dates are not the same as the EPR dates. As things stand:

• Batteries: the battery passport is required from 18 February 2027 under the Batteries Regulation, a separate law from the ESPR.
• Iron and steel: the first product group in the Commission's ESPR working plan.
• Textiles and apparel: EPR schemes by April 2028, while the ESPR delegated act for textiles is expected in 2027 and will apply only after a transition period.
• Furniture: a priority group in the working plan, with requirements expected to cover materials, repairability and recyclability.

Practical challenges

Implementing a passport takes work. For small and medium-sized manufacturers, three points tend to hurt most:

1. No digital record. Many companies still keep product data on paper or in scattered spreadsheets. Moving it into one structured source is the first and hardest step.
2. Supplier data. A passport is only as complete as the data on its components. If a raw-material supplier outside the EU will not share composition data, the gap is yours to close.
3. Confidentiality. Some passport data is public and some is for professionals or authorities only. The platform has to keep those levels apart so that trade secrets stay protected.

Where to start

• Audit your data. Do you know the exact material composition of the product and of its packaging? Can you document where each raw material comes from?
• Talk to your PRO. Ask your producer responsibility organisation how and when it plans to modulate fees, and what evidence it will accept.
• Choose the system. Look at product-data platforms or DPP providers that integrate with your ERP rather than duplicating it.
• Brief the team. Design, engineering and purchasing make the decisions that set the fee, so they need to know how it is calculated.

A fee you can influence

The passport turns extended producer responsibility from a flat charge into a fee that reflects how a product is made. For manufacturers that compete on quality rather than on price, that is an opportunity to prove it with data, and to be seen as a transparent and reliable partner by customers across the single market.