What Data a Digital Product Passport Actually Requires
Digital product passport data requirements are defined per product category in delegated acts under ESPR (EU Regulation 2024/1781), but the regulation specifies a core structure that all DPPs share: product identity and traceability, material composition and substances, performance and durability metrics, carbon footprint, repairability and end-of-life information, and certification records. The challenge for manufacturers is not understanding this list conceptually — it is knowing precisely where each data point comes from, how it must be expressed, and who in your supply chain holds the source information.
This guide goes through each data category in technical detail, explains what format the data must take, and outlines the most effective methods for collecting it from suppliers and internal systems. For companies still building their baseline understanding of the DPP framework, the digital product passport overview covers the broader architecture before you get into the data specifics.
Product Identity and Traceability Data
Every digital product passport starts with identity data. This is the layer that makes the DPP uniquely linkable to a specific physical product or batch — it is what turns a general sustainability document into a product-specific regulatory record.
Unique Product Identifier
The regulation requires a unique identifier that connects the physical product to its digital record. The preferred standard under ESPR is the GS1 Digital Link, which encodes a URL directly into a QR code or barcode structure — a single scan resolves to the DPP backend registry and returns data appropriate to the scanning actor's permissions. For batteries above 2 kWh, identifiers must be assigned at the individual unit level, not the batch or model level. For most other product categories under ESPR, batch-level or model-level identifiers are likely to be permitted depending on the delegated act. The identifier must remain associated with the product for its entire useful life plus a minimum post-end-of-life period specified per category.
Where this identifier comes from operationally: for manufacturers using GS1 standards already (Global Trade Item Numbers, Serial Shipping Container Codes), the Digital Link structure extends naturally from existing barcode infrastructure. For manufacturers not already using GS1 systems, a GS1 company prefix registration — which takes one to three weeks and costs roughly €100 to €2,000 per year depending on company size — is the practical starting point. The GS1 Digital Link technical guide covers the encoding structure and resolver architecture in detail.
Manufacturer and Product Information
The DPP must record the manufacturer's legal name and address, the product's trade name and model number, the date of manufacture, and the country of manufacture. For importers acting as the responsible economic operator for non-EU manufacturers, the importer's details replace or supplement the manufacturer's details. This data is typically straightforward to provide — it comes from your product registration and ERP systems — but it needs to be structured in the format the applicable delegated act specifies, not free-text.
Material Composition and Substances
This is the data category where most companies discover their largest supply chain gaps. Material composition requirements go well beyond a high-level bill of materials — they demand specific, verifiable declarations about what materials are present, in what proportions, and whether any are substances of concern under EU regulation.
Material Breakdown
The DPP must list the primary materials used in the product by weight percentage, at a granularity specified in the applicable delegated act. For a textile product, this means fibre content by percentage (e.g., 78% recycled polyester, 22% elastane) at the yarn level, not just the fabric level. For a consumer electronics product, it means the primary structural materials, key component materials, and materials in the product's electrical and electronic components that are relevant to recycling and end-of-life processing.
Where this data comes from: your direct suppliers hold the primary data for their component inputs, but they in turn depend on their own tier-two suppliers for material-level declarations. Getting accurate material composition data requires supplier data collection programs — structured questionnaires, material declarations in standardised formats (IEC 62474, for electronics; IMDS, for automotive components; HIGG MSI, for textiles), and in some cases sample testing to verify declarations.
Substances of Concern
EU regulations — REACH, RoHS, the Battery Regulation, sector-specific delegated acts — define lists of restricted and reportable substances that must be declared in the DPP. REACH currently lists over 240 Substances of Very High Concern (SVHCs) under Annex XIV and Annex XVII. RoHS restricts ten hazardous substances in electrical and electronic equipment. The DPP must declare the presence of any applicable regulated substance above defined threshold concentrations.
This is not the same as stating your product is compliant with REACH. The DPP requires positive declaration of what substances are present at what levels — not just a conformity statement. This is operationally demanding because many manufacturers rely on supplier declarations of RoHS or REACH compliance without receiving substance-specific concentration data. The DPP requirement forces that data to become explicit and machine-readable rather than implied by a compliance letter.
Recycled Content
For most ESPR product categories, the DPP must declare the percentage of recycled content used in the product by material type. For batteries, this is mandatory from the first compliance date — declared percentages for cobalt, lithium, nickel, and lead — and mandatory minimum thresholds apply from 2031. For textiles, recycled content declarations (recycled polyester from post-consumer bottles, recycled cotton from cutting waste, recycled wool) must be verifiable, which typically requires a chain-of-custody certification through standards like the Global Recycled Standard (GRS) or the Recycled Claim Standard (RCS).
Chain-of-custody certification is the mechanism that makes recycled content declarations credible rather than self-serving marketing claims. Without it, declared percentages cannot be verified. Building recycled content declarations that meet the DPP's third-party verification requirements means ensuring your recycled input suppliers hold valid certifications and that transaction certificates flow through your procurement process alongside material invoices.
Carbon Footprint Data
Carbon footprint is the data field that drives the most SME anxiety and the most consulting fees, and with some justification — lifecycle carbon accounting done properly is technically demanding. But done to the level required for a DPP, rather than a full ISO 14044 LCA, it is considerably more manageable than a full environmental product declaration.
What the Regulation Requires
The DPP must express the product's carbon footprint as kg CO2 equivalent per functional unit (per kWh for batteries, per kilogram for textiles, or per product unit for discrete goods, depending on the delegated act methodology). The calculation scope must cover, at minimum, cradle-to-gate emissions — raw material extraction, processing, and manufacturing through to the point the product leaves the factory gate. Some product categories will require cradle-to-grave or cradle-to-cradle accounting depending on the delegated act.
For batteries, Article 7 of EU Regulation 2023/1542 requires a specific carbon footprint calculation methodology specified in implementing acts — manufacturers cannot choose their own methodology. The scope covers raw material extraction and processing, manufacturing (cell production, pack assembly), and end-of-life treatment. For other product categories under ESPR, the methodology implementing act is published alongside or after the relevant delegated act.
Data Sources for Carbon Calculation
Primary data — actual energy consumption, actual material inputs, actual logistics data — produces the most defensible carbon footprint figure and is required for some high-impact lifecycle stages. Specifically, for the manufacturing stage within the manufacturer's own facilities, primary energy and material consumption data is expected. For upstream stages — raw material extraction and primary processing — primary data from suppliers is ideal but background database data (ecoinvent, the European Life Cycle Database, GaBi databases) is generally permissible where primary data is unavailable.
The practical data collection task for carbon footprint involves: pulling energy consumption records for your production facility (kWh electricity, natural gas m³, etc.) by product line; requesting material-specific carbon intensity data from key suppliers or using database proxies; calculating transport emissions from logistics records; and inputting this into lifecycle assessment software or an LCA calculation tool. Purpose-built DPP platforms that include simplified LCA modules can reduce this process to a structured data entry workflow rather than a full LCA consultancy exercise for products where supply chains are relatively simple.
Third-Party Verification
For batteries, carbon footprint declarations require third-party verification by an accredited conformity assessment body from the date of the first mandatory deadline. For other ESPR product categories, verification requirements will be specified per delegated act — some categories will require independent verification from day one; others may permit self-declaration initially. Check the requirements checklist using the DPP requirements checklist to understand which fields require external verification for your specific product type.
Performance, Durability, and Repairability Data
The ESPR regulation was designed specifically to shift product design incentives toward durability and repairability. The DPP is the vehicle for publishing the data that makes those design choices visible and verifiable.
Performance and Durability Metrics
Each product category delegated act specifies which performance parameters must be declared. For textiles, this includes colour fastness ratings, tensile strength, and dimensional stability after washing — all tested to EN ISO standards. For electronics, energy efficiency class (A to G under EU energy labelling regulations) and durability ratings based on standardised tests are required. For batteries, rated energy capacity, cycle life at defined discharge conditions, and state of health measurement methodology must be declared.
These data points typically come from your existing product testing and certification processes — if your product already carries CE marking or EU energy labels, much of this data exists in your technical file. The DPP requirement is primarily about exposing this data in machine-readable, standardised format rather than generating new testing.
Repairability Score
Several ESPR product categories will require a repairability score — a standardised index reflecting how repairable a product is. France's repairability index, launched in 2021 for consumer electronics and household appliances, is the prototype from which the EU-level equivalent is being designed. The score assesses: availability of spare parts, duration of spare part availability commitment, documentation accessibility (repair manuals, wiring diagrams), disassembly requirements (tools needed, ease of access to repairable components), and software update support duration.
Manufacturers who have not previously documented spare part availability commitments or published repair manuals will need to create this information. It is not data you can collect from suppliers — it is policy decisions about your own product support that need to be documented and published in a standardised format.
End-of-Life and Circular Economy Data
This data category is where the digital product passport's circular economy ambition is most directly expressed. The regulation wants recyclers, disassemblers, and second-life operators to be able to act on the DPP data — which means it needs to be specific enough to actually guide end-of-life processing, not just satisfy a compliance checkbox.
Disassembly Instructions
Step-by-step disassembly instructions, with tool specifications and sequence guidance, must be included in the DPP — though this data layer is typically restricted to professional economic operators (recyclers, repair shops, authorised treatment facilities) rather than publicly accessible. The format must be machine-readable and processable by automated disassembly systems where these exist in industrial recycling facilities. PDFs are insufficient for products where automated processing is expected; structured data schemas are required.
Recyclability Classification
The product's recyclability classification — typically a percentage figure or a categorical rating — must be included where specified by the delegated act. This figure is derived from lifecycle assessment data combined with information about material separability, contamination levels, and the existence of functioning collection and recycling infrastructure for the materials used. For some material combinations, recyclability is limited by technical and infrastructure constraints that need to be acknowledged in the declaration rather than overstated.
Take-Back and Collection Information
Where extended producer responsibility obligations apply — as they do for WEEE (electronics), batteries, packaging, and other categories — the DPP must contain information about where consumers and operators can return the product for authorised end-of-life processing. This typically links to your EPR compliance scheme's network of collection points.
How to Collect DPP Data From Your Supply Chain
The single most underestimated DPP implementation challenge is supply chain data collection — not the technology, not the platform, not even the carbon calculation. Getting your suppliers to provide accurate, standardised, machine-readable data in reasonable timeframes is where most programs stall.
Three approaches work in practice. The first is structured supplier questionnaires aligned to the specific data fields your DPP requires, distributed through your existing procurement workflows. The questionnaire format should match the data schema your DPP platform expects, so responses can be imported directly rather than re-entered. The second approach is requiring suppliers to provide data in recognised industry formats — IEC 62474 declarations for electronics, IMDS data for automotive components, material data sheets in HIGG MSI format for textiles — and then mapping those formats to your DPP schema. This reduces supplier burden by leveraging work they may already be doing for other customers. The third approach, for critical suppliers where primary data is unavailable, is funded supplier audits where you commission a third party to measure and document the data at source. This is more expensive but produces more defensible data than a self-declaration questionnaire.
Building DPP data collection into your standard supplier onboarding process — rather than running a separate retrospective data collection program — is the sustainable long-term approach. New supplier contracts should include data provision obligations with specific field requirements, formats, update frequencies, and penalties for non-provision. The DPP creation guide covers supplier data integration methods in the implementation steps.
Whatever platform you use to manage DPP generation, the data management workflow is a central consideration. The DPP-Tool feature set includes supplier data import templates and API integrations with common ERP and PLM systems — reducing manual re-entry and the error rates that come with it.
Frequently Asked Questions
What are the mandatory data fields for a digital product passport?
Mandatory data fields are defined per product category in delegated acts under ESPR (EU Regulation 2024/1781). The common core across categories includes: unique product identifier, manufacturer identity and address, material composition by weight percentage, substances of concern declarations (per REACH and category-specific lists), recycled content percentages, carbon footprint in kg CO2 equivalent, performance and durability ratings, repairability information including spare part availability, and end-of-life guidance including disassembly instructions. Battery passports under EU Regulation 2023/1542 additionally require state-of-health data, battery chemistry, rated capacity, and supply chain due diligence for critical raw materials. Exact field labels, units, and formats are specified in implementing acts published alongside or after each delegated act.
How is carbon footprint calculated for a digital product passport?
Carbon footprint for a digital product passport must be calculated following the methodology specified in the implementing act for the relevant product category. The minimum required scope is cradle-to-gate — covering raw material extraction, upstream processing, and manufacturing through to factory gate — expressed in kg CO2 equivalent per functional unit. Some categories require full cradle-to-grave or cradle-to-cradle scope. Primary data (actual energy and material consumption records) is required for manufacturing-stage calculations, while upstream stages may use background lifecycle inventory databases such as ecoinvent or the European Life Cycle Database. For batteries, the methodology implementing act under Article 7 of EU Regulation 2023/1542 specifies the exact calculation boundaries and allocation rules, and the resulting declaration requires third-party verification.
What material composition data does a DPP require?
Material composition data in a digital product passport must identify primary materials by weight percentage, list substances of concern present above defined threshold concentrations (under REACH SVHCs, RoHS, or category-specific regulated substances lists), and declare recycled content by material type. For textiles, fibre content declarations at yarn level are expected. For batteries, chemistry-specific material declarations for cobalt, lithium, nickel, natural graphite, and lead are mandatory including recycled content percentages. The data must be machine-readable and structured, not free-text — typically using industry-standard material declaration formats that can be imported into DPP registry systems.
How do I get DPP data from my suppliers?
Three practical approaches work. First, structured supplier questionnaires aligned to your specific DPP field requirements, distributed through procurement workflows, with responses importable directly into your DPP platform. Second, requiring suppliers to provide data in established industry formats — IEC 62474 for electronics, HIGG MSI for textiles, IMDS for automotive — and mapping these to your DPP data schema. Third, funded supplier audits by accredited third parties for critical suppliers where self-declaration data is insufficient or unavailable. Long-term, DPP data provision obligations should be built into standard supplier contracts, with specific field requirements, format specifications, and update frequencies, so data collection becomes part of normal procurement operations rather than a separate remediation program.
Does all DPP data need to be publicly visible?
No. The regulation establishes layered access controls — different data is visible to different actor types. Consumer-accessible data (carbon footprint, recycled content, energy rating, repairability score, end-of-life instructions) must be available without registration or payment. Operator-accessible data (detailed disassembly instructions, hazardous component locations, supplier sourcing declarations) is restricted to verified economic operators — repair shops, recyclers, distributors. Authority-accessible data (full conformity declarations, third-party verification reports, complete technical file references) is available only to market surveillance authorities. The applicable delegated act for each product category specifies which data fields fall into which access tier, and DPP platforms manage these permission layers via API-controlled data endpoints.
What happens if supplier data is unavailable for a required DPP field?
Where primary supplier data is genuinely unavailable, several options exist depending on the field in question. For carbon footprint upstream stages, background lifecycle inventory database proxies (ecoinvent, sector-average factors) are generally permissible with appropriate disclosure that the value is based on estimated rather than primary data. For substance declarations, industry average declarations may be permitted where product category-specific rules allow. For fields requiring primary data that is simply not obtainable from the current supply chain, the compliance-responsible response is to document the data collection attempts made, apply the best available proxy, and flag the limitation — and to address the supplier data gap through alternative sourcing or funded audit support before the mandatory verification deadline. Submitting knowingly inaccurate declarations to avoid gaps is a regulatory risk significantly greater than declaring an estimated value with appropriate caveats.