TL;DR;

The Digital Product Passport (Digital Product Passport – DPP) will be a key instrument of the new European framework for sustainable products (ESPR).

But not all goods will be required to have a DPP.

Food, animal feed, medicines, veterinary products, live plants and animals, as well as products of human origin are currently outside the scope of the regulation.

This does not mean that these sectors will never be covered – but for now, the focus is on categories such as textiles, batteries, electronics, furniture and construction products.

What is DPP and why is it being introduced

The Digital Product Passport is part of the European Union's vision for a circular economy and product traceability throughout their entire lifecycle.

Every product that falls under the new Ecodesign for Sustainable Products Regulation (ESPR) will need to have a unique digital identifier accessible via a QR code or NFC chip.

The passport will contain data about:

• the product composition and materials used;
• the carbon footprint;
• repair, reuse or recycling options;
• manufacturer, country of origin, certifications, etc.

Which products currently

will not

have DPP

1. Food

Food products are explicitly excluded from the scope of ESPR.

According to Article 2 of Regulation (EC) No 178/2002, "food" means any substance or product intended for human consumption.

Reason: food already has its own strictly regulated framework for safety and traceability (Regulation (EC) No 178/2002 and subsequent).

2. Animal feed

Animal feed also falls under separate legislation.

The food and feed regulation provides a specific traceability system, so ESPR does not duplicate it.

3. Medicinal products

Human medicines, defined under Directive 2001/83/EC, are outside the scope.

This sector already has unique traceability systems (such as the EU Falsified Medicines Directive, eLeaflet, etc.), so DPP does not apply.

4. Veterinary medicinal products

Regulation (EU) 2019/6 governs veterinary medicines.

They have their own rules for safety, labelling and traceability.

5. Live plants, animals and microorganisms

Living organisms are not "products" within the meaning of ESPR and cannot have a DPP.

Reason: lack of standardised sustainability and lifecycle data in this context.

6. Products of human origin

Includes tissues, organs and biomaterials used for medical purposes.

Excluded on ethical and regulatory grounds.

What this means for business

These exclusions should not mislead manufacturers and traders.

ESPR is a "framework" regulation – it will expand gradually through delegated acts that may cover new categories.

Even if your product is not yet covered:

• Construction products, electronics, textiles and batteries are already on the priority list.
• Packaging may be covered through separate European regulations.
• Voluntary DPP adoption can become a competitive advantage – demonstrating transparency and sustainability.

Context for Businesses

All EU member states will apply ESPR in full through national legislation.

Manufacturers and importers will need to:

• monitor when their categories will be included;
• plan the implementation of digital passport systems;
• ensure data exchange with European registries and databases.

Conclusion

DPP will not apply to all products, at least not immediately.

But the trend is clear – towards full digitalisation and market transparency.

Even sectors that are excluded today (such as food or medicines) may be partially covered in the future when the regulator creates an appropriate framework.

Follow the news around ESPR and delegated acts to be prepared for the next steps of the European green transformation.