Digital Product Passport (DPP): The State of Play

Waiting for the Digital Product Passport (DPP) rules to land? You’re not alone.

But here’s the truth: this is one of those times where waiting quietly is the riskiest move you can make.

Because even if the final details aren’t out, the direction is crystal clear, and the runway to get ready is shorter than it looks.

So let’s cut through the fog.

Here’s where things actually stand, what’s coming next, and how you can prepare with confidence, not guesswork.

The law — the ESPR — is already passed. That’s your building permit.
But the floor plan (the DPP) is still being finalised room by room, through something called delegated acts.
That doesn’t mean you can’t start laying the foundation.
It just means you need to build in stages, starting with what’s known.

The Ecodesign for Sustainable Products Regulation (ESPR) entered into force in July 2024. This creates the legal basis for requiring digital product passports across the EU.
It’s big. It’s strategic. And it’s here to stay.
But the regulation doesn’t cover everything just yet. That’s where the delegated acts come in.

1. DPP Governance Rules – late 2025

These will set the foundation for how the DPP system works. Expect them to cover:

• Product identifiers and data carriers (like QR codes)
• How digital records link to physical products
• Interoperability between systems (so your data can “talk”)
• Access rights, security, and update protocols
• Searchability and APIs for lifecycle management

Much of this will be based on EU-wide standards under development at CEN/CENELEC.

2. Textile-Specific DPP Rules – early 2027

According to the European Commission’s work plan, the delegated act for textiles will be published in early 2027.

That means compliance is likely required by mid-to-late 2028.
This upcoming act will define:

• What ecodesign rules apply to textile products
• Which data fields are mandatory (vs. optional)
• What formats and systems must be used
• Whether specific labels (like EU Ecolabel) need to be included

Even if the rules aren’t final, the direction is clear. The DPP won’t just ask for sustainability data, it’s a digital profile of your product’s full lifecycle.
Here’s what’s likely to be included:

• Product and batch identifiers
• Material composition and origin
• Facility and supplier IDs
• Compliance documents and certificates
• Safety instructions and user manuals
• Optional labels like EU Ecolabels or third-party standards
• Information about manufacturers, importers, and service providers
• A reference to the platform hosting the DPP record

All of this must be structured, shareable, updatable, and interoperable.

If you’re running an SME in the textile sector, here’s the uncomfortable truth:
Most of this information already exists, but it lives in emails, PDFs, and spreadsheets that don’t talk to each other.
That’s the real DPP challenge. Not collecting the data, but connecting it.
You don’t need to wait for 2027 to:

• Audit where your product data lives
• Map out what’s missing
• Ask suppliers about their data readiness
• Start reducing manual workflows
• Explore simple tools to centralise your product information

Because once the rules hit, it’ll be too late for a calm response.

You wouldn’t wait until a week before opening to start building a house, and the DPP is no different.
Yes, some of the walls are still being drawn.
But the foundation, and the direction, are already here.
Start with structure. Start with visibility. Start with one product, one folder, one system.
Smart businesses won’t scramble later. They’ll lead quietly now.

And when the rules arrive, they won’t be starting — they’ll be standing.

Need help mapping your DPP foundation? We’re here to help.

For additional information on the DPP, check also our dedicated info page.