Rights and obligations of companies under the ESPR regulation – what does the DPP actually mean?
The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) entered into force on 18 July 2024 and introduced a radically broader approach compared to the previous Ecodesign Directive. It extends its application to almost all physical products placed on the EU market, except for food, medical and veterinary products. The fundamental tool of its implementation is the Digital Product Passport (DPP) – a digital record of key product information, available via QR code or similar data carrier.
Where are we now?
On 16 April 2025, the European Commission adopted the first Working Plan 2025–2030, which defined the priority categories for introducing ecodesign and DPP obligations.
According to the plan, the DPP will first be introduced for:
Batteries (already defined by Regulation 2023/1542)
Electrical and electronic devices (ICT, household appliances)
Textiles and footwear
Construction products
Furniture
Tyres
Toys
Detergents and chemicals
Packaging (according to Regulation 2025/40, also with a DPP component)
What does ESPR prescribe?
In essence, ESPR defines rules for:
Product design: obligation to reduce negative environmental impact throughout the product life cycle (durability, reparability, energy efficiency, recyclability).
Digital Product Passport (DPP): a tool for transparent presentation of key information relevant to product sustainability and compliance.
Market surveillance and compliance: national authorities use the DPP system to verify whether products comply with the rules.
Who is obliged to implement the DPP and what must they do?
Obligations are defined depending on the role in the supply chain, but most often include:
Manufacturers and authorised representatives: responsible for creating and publishing the DPP before placing the product on the market.
Importers: must ensure that the products they import have a valid DPP.
Distributors and retailers: responsible for making DPP data available to end users.
Digital solution providers: develop infrastructure for storing, accessing and connecting DPP data.
When do the obligations start?
18 February 2027 – Mandatory DPP implementation for batteries (industrial and electric vehicle), in line with Regulation 2023/1542.
From 2028 onwards – Gradual mandatory implementation of the DPP for packaging (Regulation 2025/40).
From 2027–2030 – ESPR delegated acts for other product groups (electronics, textiles, etc.) will be adopted successively.
Due to the complexity of adopting delegated acts, it is recommended to actively monitor the EU legislative database (e.g. via the EUR-Lex portal or the official European Commission website).
What must the DPP contain?
The minimum content of the DPP includes:
Product identification
Information on material composition
Instructions for use, maintenance, repair and recycling
Information on sustainability, efficiency and certifications
Access for all relevant stakeholders – via QR code or similar data carrier
Data must be stored in a decentralised, interoperable and secure way, in accordance with upcoming technical standards and EU guidelines for semantic interoperability.
Conclusion: The time to prepare is now
The ESPR regulation is no longer in draft form – it is already in force. Although not all delegated acts have been adopted yet, it is clear that companies must start preparing:
Assess how ESPR and DPP affect their products
Map the data and systems (ERP, PIM, PLM) needed to generate the DPP
Choose partners for implementing the digital infrastructure
Join pilot projects to receive timely feedback
If your company is looking for a reliable partner to implement Digital Product Passports, our team can support you throughout the entire process – from requirement analysis to technical execution.
Contact us at: info@nos.hr