TL;DR

In 2024, the EU's new regulation on sustainable products (ESPR) entered into force, making the Digital Product Passport (DPP) mandatory for many product categories. The first work plan for 2025–2030 has been adopted and defines the priority products: textiles and clothing, furniture and mattresses, consumer electronics and ICT, plastics and intermediate materials, construction products and other high-risk groups.

In 2026, the first delegated acts for specific product groups (e.g. textiles) are expected, and the EU central registry for DPP is due to be operational by July 2026. The actual deadlines for mandatory application for the first products will be mainly in 2027–2028, with a transitional period of approximately 18 months after each delegated act.

This means that 2026 is the year when manufacturers and importers need to prepare their processes – to know which products will fall within scope, what data is required, how to collect it from suppliers and how to choose a platform for managing Digital Product Passports.

The key practical steps are:

• Mapping your products and checking whether they fall among the priority groups.
• Determining the full set of data needed for DPP and where it currently resides.
• Creating internal roles and processes for data collection, verification and maintenance.
• Building a structure for working with suppliers, as a large portion of data comes from them.
• Choosing a technology solution for DPP that can integrate with your ERP/PLM systems.
• Creating pilot passports for 1–2 priority product lines to be ready for mandatory deadlines.

1. Context: What is happening with ESPR and DPP by 2026

The Ecodesign for Sustainable Products Regulation (ESPR) has been in force since 18 July 2024, replacing the old ecodesign directive legislation. It introduces a common framework for product sustainability in the EU and for the first time introduces the concept of a Digital Product Passport – DPP.

In April 2025, the European Commission adopted the first work plan for 2025–2030, defining the priority product groups and approximate timelines for preparing and adopting delegated acts.

Several key facts:

• DPP will be applied progressively for different product groups between approximately 2026 and 2030, with requirements for each group determined in a separate delegated act.
• By 19 July 2026, a central EU registry must be operational, storing the unique identifiers of passports.
• For textiles and clothing, the DPP delegated act is expected to be finalised around the end of 2026 / beginning of 2027, with mandatory application around 2028 after a transitional period of approximately 18 months.
• In parallel, the Batteries Regulation introduces the first sector-specific DPP – the so-called "battery passport", with requirements starting in 2027.

The takeaway for business is that 2026 is not the moment when all products must suddenly have a passport, but the year when you need to do the preliminary work: this way you'll enter 2027–2028 with prepared processes, rather than in firefighting mode.

2. Which product categories are a priority

The work plan and analyses by the Commission and various expert groups clearly outline the first wave of product categories. Priority products for the first phase are:

• Textiles and clothing (including footwear and accessories).
• Furniture and mattresses.
• Consumer electronics and ICT products.
• Plastics and intermediate materials.
• Construction products and building materials.
• Iron and steel, aluminium, tyres, detergents, paints, lubricants and other chemicals with a high environmental footprint.

If your company manufactures or imports products in any of these categories, the chances of falling into the first wave of DPP are very high.

A practical first step is to conduct an internal "mapping":

• A list of all product lines sold in the EU.
• Classification by type (textiles, furniture, electronics, etc.).
• Assessment of the probability of falling within scope of the first delegated acts.

3. What DPP looks like in practice

DPP is a digital record linked to a specific product via a data carrier – most commonly a QR code, barcode or RFID/NFC tag.

The passport contains standardised information about the product throughout its entire lifecycle: materials, production, use, servicing, end-of-life, environmental indicators and regulatory compliance.

A typical DPP will include:

• Product identifiers – trade name, model, SKU, GTIN/EAN, customs classification codes.
• Composition information – materials and components, percentage content, presence of hazardous substances, critical raw materials, recycled content.
• Production data – manufacturing locations, suppliers, certifications (ISO, FSC, OEKO-TEX, etc.).
• Environmental profile – lifecycle assessment (LCA) results, carbon footprint, energy efficiency.
• Use and service information – instructions, repairability, available spare parts, warranty terms.
• End of lifecycle – disassembly instructions, recycling and safe disposal.

An important feature is that DPP will not be a static PDF, but structured data in digital format (e.g. JSON-LD) that must be machine-readable by other systems.

4. What data do we need to collect and where to get it

One of the biggest practical challenges for manufacturers is data. In many companies, it is scattered across ERP, PLM systems, Excel spreadsheets, emails with suppliers, PDF certificates, etc.

Good practice is to structure DPP data into four blocks.

Data you already have in structured form:

• item numbers, descriptions, barcodes;
• basic characteristics and specifications;
• some of the materials data.

Data you have but is not structured:

• certificates in PDF;
• declarations from suppliers (REACH, RoHS, etc.);
• LCA reports or carbon calculations.

Data that needs to come from suppliers:

• detailed material composition;
• origin of raw materials;
• content of hazardous substances;
• information about included semi-products/components.

Data you probably don't have at all and need to start generating:

• systematic lifecycle assessments (LCA) for key products;
• standardised KPIs for durability, repairability and recyclability.

For 2026, the realistic goal is:

• to know for each priority product which DPP fields can be filled immediately;
• which fields require additional work with suppliers or internal analyses;
• to have a plan for closing the gaps by 2027–2028.

5. Organising an internal process for DPP

DPP will not be a one-off project, but an ongoing process, similar to quality management or REACH/RoHS compliance systems.

The main elements of the internal process are:

Appointing a process owner

Typically this is someone from the quality, sustainability or product management team. In larger companies, a cross-functional team may be formed.

Defining the workflow:

• data collection;
• verification and validation;
• creating and publishing the DPP;
• periodic updates when design, supplier or regulation changes;
• archiving and version control.

Defining a "source of truth" for product data

Whether this will be ERP, PLM or a specialised DPP platform, it is important that everyone knows where the "true" version of data is maintained.

Internal policies and instructions:

• who can modify data;
• how new passports are approved;
• how to respond to regulatory inspections or complaints related to DPP.

Training and awareness

Sales, product management, logistics and marketing need to understand DPP basics to communicate correctly with customers and partners.

6. Working with suppliers – the critical success factor

A large portion of information in DPP comes from the supply chain. Without structured data from suppliers, the passport cannot be completed.

A good approach for 2026 is:

Classifying suppliers:

• critical (supplying core components and materials);
• non-critical (packaging, auxiliary materials, etc.);
• high-risk (complex products, limited supply chain transparency).

Developing standard data templates:

• tables or formats for suppliers to fill in;
• clear description of what is required and why.

Introducing contractual requirements

New and renewed contracts can include a clause that the supplier is obliged to provide the necessary DPP data and keep it up to date.

Gradually digitalising the exchange

Initially this can be done with templates and emails, but in the long term more automated solutions will be needed – supplier portals or API integrations.

7. Choosing a DPP platform

Many solutions for managing Digital Product Passports are already appearing on the market. When choosing in 2026, it is reasonable to look for at least the following:

• Support for formats compatible with ESPR requirements and related standards (JSON structures, future schemas per delegated acts, GS1, etc.).
• Ability to link each passport to a unique identifier and generate a QR code or other data carrier.
• Data versioning and clear change tracking – who updated what and when.
• API integrations with ERP, PLM, CRM and other core systems.
• Role-based access – different information levels for regulators, business customers, service partners and end consumers.
• Ability to manage passports for different product groups, not just one niche (e.g. textiles or electronics).

8. A realistic action plan for 2026

To be in a good position before the first mandatory deadlines take effect (2027–2028), you can structure 2026 as follows.

First three months:

• Product mapping and risk assessment by category.
• Analysis of where product data resides and where the "gaps" are.
• Appointing responsible persons and defining the core process.

Next three to six months:

• Building first data templates and communicating with key suppliers.
• Choosing a technology solution/platform for a pilot.
• Collecting data for 1–2 pilot product lines.

End of 2026:

• Created and tested real DPPs for pilot products (even before they are formally mandatory).
• Initial internal training and documentation.
• Planning expansion to remaining product lines for 2027–2028.

9. Common mistakes and how to avoid them

Observations from companies already preparing for DPP reveal several recurring mistakes:

• Underestimating the time needed for data collection, especially from suppliers.
• Trying to manage all data manually in spreadsheets, which quickly leads to chaos.
• Lack of a clear process owner and distributed responsibilities.
• Focusing only on regulatory requirements without considering the business benefits – a more transparent supply chain, better quality management, stronger position with customers and investors.

10. How WIARA supports passport implementation

WIARA is entirely focused on Digital Product Passports and the regulations around them, and can shorten the path from "we don't know where to start" to fully operational DPP processes. Support includes several key areas.

First, strategic consulting and readiness assessment – evaluating which product lines fall within scope of the first delegated acts, what data already exists in your systems and where critical gaps are. Based on this, a roadmap for the next 12–24 months is prepared.

Second, data and process structuring – creating a common DPP data model, templates for supplier communication, internal procedures for data collection and approval. This enables "translating" regulatory requirements into the language of your ERP/PLM systems and actual production processes.

Third, selecting and implementing a technology solution – WIARA develops and maintains a platform for Digital Product Passports that integrates with existing systems, generates passports according to ESPR requirements and provides secure access for regulators, partners and end consumers via QR codes. The team can also assist with integration of other already chosen solutions.

Finally, pilot projects and training – together with your team, a limited set of products is selected for which the first passports are built "end to end". This serves as real practice upon which internal knowledge is built, and employees undergo targeted training according to their role – data management, platform operation, communication with customers and regulators.

11. Conclusion

DPP is one of the most significant changes for manufacturers and importers selling on the European market in the coming years. Although the actual mandatory deadlines for the first product categories will mainly be in 2027–2028, 2026 is the year to build the foundations: data, processes, technologies and work with suppliers.

Companies that use 2026 to create pilot passports and organise their data will enter the period of mandatory regulatory compliance much better prepared, with lower costs and a clear competitive edge. WIARA can be a partner in this process – from initial orientation in the regulations to fully implemented Digital Product Passports at scale.