Digital Product Passport
From 12 August 2028 at the earliest, your packaging must carry the Article 12 harmonised label; a QR code or other data carrier stays optional, except for reusable packaging and substances of concern. Here's where the DPP really comes from (the ESPR), how it fits with the PPWR, and how to prepare your data today.
Definition
The DPP is a digital record of standardised product information — composition, performance, recyclability, sorting instructions — accessible by scanning a data carrier. Its overall framework is the ESPR (Regulation (EU) 2024/1781). The PPWR creates no passport: its Article 12 mandates a harmonised label from 12 August 2028 at the earliest, and makes a data carrier mandatory only for reusable packaging and substances of concern — optional otherwise, and shared with any product-side passport.
DPP and PPWR
Two complementary texts. The PPWR mandates the harmonised label and the related compliance information; a QR code is optional, except for reusable packaging and substances of concern. The ESPR defines the content and infrastructure of the digital passport. Where both apply, the same QR serves both — you don't manage two carriers.
Data model
Material composition and substrate (type, grammage)
Recycled content
Recyclability (grade, PPWR Article 6)
Compliance: PFAS, heavy metals, food contact (Article 5)
Sorting and recycling instructions
Primary data
Reliable data already exists where packaging is made: substrate, inks, quantities and coverage are known at print. Rather than re-keying it by hand, PPWR Connect is built to draw on primary data measured at the press (via our production-control solutions) — for compliance, and tomorrow a DPP, grounded in facts, not estimates.
Timeline
11 February 2025
PPWR enters into force.
12 August 2026
General application (compliance, Declaration of Conformity, EPR).
12 August 2028 at the earliest
Article 12 harmonised label mandatory on packaging; data carrier optional, except reusable packaging and substances of concern.
Get ready
Map your SKUs and their packaging composition.
Centralise supplier and printer data (substrate, inks, recycled content).
Update your Declarations of Conformity and EPR registration.
Plan for a data carrier where required or useful: one identifier per item.
PPWR Connect already helps with steps 1–3 — and the DPP module is coming.
Stay informed
We'll email you once, when the Digital Product Passport module is ready. No marketing list, unsubscribe anytime.
FAQ
No. What the PPWR makes mandatory is the Article 12 harmonised label, from 12 August 2028 at the earliest. A data carrier (QR code or equivalent) is mandatory only for reusable packaging and for packaging containing substances of concern; otherwise it is optional. A passport can only come from an ESPR delegated act, which does not exist yet for packaging.
The PPWR mandates the harmonised label on packaging and creates no passport; the ESPR (Regulation (EU) 2024/1781) defines the passport's content and infrastructure. Where both apply, they share the same QR code.
Material composition, substrate, recycled content, recyclability, compliance (PFAS, heavy metals, food contact) and sorting/recycling instructions. No ESPR delegated act covers packaging, so no one can state the content of a packaging passport — but this is the data the Article 12 label and any carrier draw on.
No date exists: no ESPR delegated act covers packaging yet. The PPWR Article 12 harmonised label applies from 12 August 2028 at the earliest.
The economic operator who places the packaging on the market (brand or manufacturer). They answer for the Article 12 harmonised label and for the accuracy of the packaging data behind it — data often supplied by their suppliers and printers. A passport, if one ever applies to packaging, would come from an ESPR delegated act (Regulation (EU) 2024/1781), and none exists today.
Join 45+ companies preparing for Regulation (EU) 2025/40 with PPWR Connect — Declaration of Conformity, recyclability grades and EPR obligations in one workspace. Plans from €29 a month.