Regulation
·
January 21, 2026

Understanding the Regulation: What Does the Digital Product Passport (ESPR) Require?

Martina Sattanino
Content Writer
Sara Ongaro
Head of Product and Implementation

The Digital Product Passport (DPP) is no longer a future concept. It is a legal requirement that will reshape how fashion brands design products, manage data, and communicate with customers and regulators, and 2026 is the operational year for implementation. 

For brands, manufacturers, and retailers, the key question is no longer if preparation is needed, but how. This guide is written for non-technical teams looking for clarity: which regulations are coming, what they require, and what to watch closely to stay compliant.

The following sections focus on the essentials in a clear, practical way with only what matters.

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Why the Digital Product Passport matters now

Across Europe, regulators are moving from voluntary transparency to mandatory product-level information. The DPP is the tool enabling this shift.

In simple terms, a Digital Product Passport is a digital record linked to a physical product. It stores and shares information about materials, origin, durability, repair, and end-of-life: accessible to authorities, business partners, and consumers. It also vehicles digitalized information required for other regulations - it was born from ESPR but other norms already nominate it as a tool. 

According to the European Commission, products placed on the EU market are responsible for over 80% of environmental impacts, largely determined at the design stage. This is why regulation is focusing on product data from the start.
Source: European Commission, Ecodesign Impact Accounting

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The core regulation behind DPP: ESPR

Ecodesign for Sustainable Products Regulation (ESPR)

The main regulation introducing the Digital Product Passport is the Ecodesign for Sustainable Products Regulation (ESPR).

What it is:
A new EU regulation that sets requirements for how products are designed, produced, and documented.

The DPP will be introduced progressively for specific product groups through product-specific rules. These delegated acts will determine when a DPP is required and define requirements such as the information to be included, the applicable level of granularity and access rights.

What it means for brands:
If you sell products in the EU, you will need to provide standardized, digital information about each product.

Key points to prepare for:‍

  • Products must carry a Digital Product Passport (via QR code, NFC, or similar)
  • Information must be accurate, structured, and machine-readable
  • Data must be accessible throughout the product lifecycle

What to be careful about:
The ESPR does not define one single DPP format. Instead, it sets the framework. Specific requirements will be introduced gradually by product category: fashion and textiles are among the priority sectors.

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The EU Digital Product Passport Registry is now operational

Since July 2026, the EU Digital Product Passport Registry has been operational as a central component of the DPP infrastructure. For products subject to DPP requirements, the relevant economic operator will need to register the required information in the Registry before placing the product on the EU market.

The Registry does not centrally store the full Digital Product Passport. It acts as an EU-level indexing system, storing unique identifiers, registration data and relevant metadata, while detailed product information remains decentralised. Registration can be managed through the Registry interface or via API integration.

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Textile-specific rules are coming fast

EU strategy for sustainable and circular textiles

Textile-specific DPP requirements are currently being developed under the ESPR. The European Commission currently indicates Q4 2027 for the planned adoption of the delegated act for textile apparel, although this timeline remains indicative. The delegated act will establish the product-specific requirements, including which information must be included in the DPP.

What it introduces:

  • Mandatory product-level data for textile products sold in the EU
  • Strong focus on traceability and material composition
  • Alignment across supply chain actors

What brands need to do now:

  • Start mapping materials and suppliers
  • Understand what data you already have and what is missing
  • Prepare internal teams for product-level reporting, not just brand-level claims

What to be careful about:

Data must be consistent across systems. Marketing claims that are not aligned with DPP data may raise red flags during audits or checks.

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Corporate reporting still matters: CSRD

Corporate Sustainability Reporting Directive (CSRD)

While DPP focuses on products, CSRD focuses on companies. The two are closely connected.

What it is:

A regulation requiring large companies (and gradually SMEs) to disclose standardized non-financial information.

Why it matters for DPP:

  • Product data feeds corporate reporting
  • Inconsistencies between CSRD reports and DPP data can create compliance risks

What to be careful about:

Even if CSRD applies at the company level, weak product data can undermine your reporting credibility.

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Consumer-facing information rules are tightening: Empowering Consumers Directive 

While CSRD focuses on company-level reporting, the EU is also tightening the rules that govern how brands communicate product information to consumers.

Directive on Empowering Consumers for the Green Transition (EU) 2024/825

What it is:

An update to EU consumer protection law that strengthens requirements around consumer-facing product information and restricts misleading commercial practices.

Why it is relevant for DPP:

This directive is more imminent and broader in scope than claim-specific measures. It covers a wider range of product communication topics, including durability and reparability information, guarantee transparency, and limits on vague or unreliable product claims and labels. This makes product-level data increasingly important as a source of consistent, verifiable information.

When will it apply:

The rules implementing the Empowering Consumers for the Green Transition Directive apply from 27 September 2026, strengthening requirements around environmental information and consumer-facing sustainability claims.

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Claims under scrutiny: Green Claims Directive

On this topic, the proposed Green Claims Directive focuses specifically on how environmental claims are made and substantiated.

Green Claims Directive (proposal)

EU rules on environmental claims are becoming stricter, particularly through the Empowering Consumers for the Green Transition Directive. Companies need to ensure that environmental information communicated to consumers is clear, substantiated and not misleading.

A separate Green Claims Directive was proposed to introduce more specific requirements for explicit environmental claims, but it should not be treated as an adopted requirement when assessing current compliance obligations.

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DPP is increasingly being mentioned in more and more regulations as a digitalization tool for product data, as part of the EU Single Market strategy.

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What information could a Digital Product Passport require?

There is no single mandatory dataset that applies to every Digital Product Passport. The exact information required will depend on the applicable product-specific legislation. Under the ESPR, delegated acts will determine which information must be included for each product group. Depending on the product group, this may include information such as:

  • Material composition
  • Country of manufacturing
  • Supplier and process information (at defined levels)
  • Care, repair, and durability guidance
  • End-of-life instructions
  • Chemical compositions and environmental impact 

The key shift is from PDFs and internal files to structured, digital data.

The ESPR also requires the economic operator placing the product on the market to make a back-up copy of the Digital Product Passport available through a Digital Product Passport service provider. This is part of the infrastructure designed to ensure that DPP data remains available throughout the required period.

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Common mistakes brands should avoid

  1. Waiting for every product-specific requirement to be finalised before starting
    The core DPP architecture is already taking shape through the ESPR, the EU Registry and European standards. Product-specific requirements will continue to be defined through delegated acts, but companies can already work on product data, identifiers, data governance and system readiness.‍
  2. Treating DPP as an IT-only project
    DPP requires collaboration across design, sourcing, compliance, and communication teams.‍
  3. Collecting data without validation
    Incorrect or inconsistent data can create more risk than missing data.‍
  4. Seeing compliance as a burden, not a system
    Well-structured product data reduces friction across reporting, claims, and partner requests.

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How Renoon supports brands navigating DPP

Renoon supports companies across the full DPP implementation process, from regulatory readiness and data mapping to supplier data collection, system integrations, DPP creation, Registry connection and ongoing management.

This includes defining the appropriate data model and governance, connecting existing ERP, PLM, PIM, CRM or e-commerce systems, involving suppliers where information is missing, and managing the infrastructure required to keep Digital Product Passports accurate and up to date.

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What you can do next

Companies can already start by:

  • Mapping the product data they currently hold and identifying gaps
  • Identifying where relevant data sits across internal systems and suppliers
  • Defining responsibilities for collecting, maintaining and updating product information
  • Assessing how existing systems will connect to the DPP infrastructure
  • Following the delegated acts applicable to their product categories

Book a demo with Renoon to explore how Digital Product Passports can be implemented in a clear, structured, and future-ready way.

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Where would you like to start?