Digital Product Passport: An Overview of Affected Industries

Many companies know that the Digital Product Passport is coming—but they don’t know whether their own products are already specifically affected. For management and compliance teams, this distinction is crucial: The ESPR generally covers a very broad product market. However, a binding DPP requirement usually arises only through a product-specific legal act.

Which industries does the Digital Product Passport affect?

The Ecodesign for Sustainable Products Regulation (ESPR) establishes the framework for ecodesign requirements and Digital Product Passports. Its scope generally covers nearly all physical goods. Exceptions include, among others, food, animal feed, pharmaceuticals, and certain other product categories.

This does not mean that all companies must provide a DPP at the same time. Specific data fields, transition periods, and obligations are established for individual product groups through delegated acts.

These DPP product groups are prioritized

The ESPR Work Plan 2025–2030 specifically lists:

Textiles and clothing
Furniture and mattresses
Tires
Iron and steel
Aluminum

In addition, there are energy-related products such as selected household appliances, displays, chargers, servers, and welding equipment. Iron, steel, and aluminum demonstrate that it is not only end products that are affected: Manufacturers and processors of industrial intermediate products must also assess their data readiness.

The annual dates in the work plan describe planned timeframes for drafting regulations. They are not yet general DPP deadlines. The obligation becomes legally binding only through the respective legislative act and after the transition period specified therein.

Special Rules for Batteries and Construction Products

Batteries are governed by the standalone EU Battery Regulation. Starting February 18, 2027, electric vehicle batteries, batteries for light-duty vehicles, and industrial batteries with a capacity exceeding 2 kWh will require a battery passport.

Construction products are primarily regulated by the new Construction Products Regulation. It also provides for a digital product passport system, the introduction of which depends on further legislative acts and technical requirements. Companies should therefore not confuse the ESPR, the Battery Regulation, and the Construction Products Regulation.

Who Needs to Take Action Within the Company

The extent to which a company is affected does not depend solely on the industry. What matters is the specific product and the company’s role as a manufacturer, importer, authorized representative, or, where applicable, distributor. For example, a machinery manufacturer may simultaneously sell metal products, electronic components, and batteries subject to regulation.

Management should therefore initiate three decisions:

Map the product portfolio to the relevant regulations.
Evaluate existing product, material, and supplier data.
Plan a common data architecture for PIM, ERP, MDM, and other source systems.

This prevents the creation of isolated solutions for each regulation. asioso can help companies translate regulatory requirements into a robust product data and integration strategy.

In the long term, the Digital Product Passport will affect a large portion of the industry, but not all product groups at the same time. The current priorities are textiles, furniture, tires, metals, and numerous energy-related products. Batteries and construction products are subject to their own regulations. Companies should therefore not look for a general DPP deadline, but rather examine their portfolio on a case-by-case basis and close data gaps early on.

 FAQ

1    Which industries are affected by the DPP first?

Priority is given to, among others, textiles, furniture, tires, iron, steel, aluminum, and selected energy-related products.

2    Does the DPP already apply to all physical products?

No. The ESPR provides a broad legal framework. Specific obligations arise on a product-group-by-product-group basis through additional legal acts.

3    Are small businesses exempt?

Not necessarily. The decisive factors are the product group and the company’s role in the supply chain, not just revenue or the number of employees.

4    Are batteries part of the ESPR roadmap?

The Battery Passport is based on a separate regulation and will be mandatory for certain batteries starting February 18, 2027.

Which product lines need reliable DPP data first? A structured DPP readiness check provides clarity on regulations, data gaps, systems, and the next steps for implementation.

Check your readiness now at DPP.jetzt

Bibliography

• Europäische Union: Verordnung (EU) 2024/1781 zur Schaffung eines Rahmens für Ökodesign-Anforderungen für nachhaltige Produkte, 13.06.2024, EUR-Lex, abgerufen am 23.07.2026. (EUR-Lex)
• Europäische Kommission: ESPR and Energy Labelling Working Plan 2025–2030, 16.04.2025, EUR-Lex, abgerufen am 23.07.2026. (EUR-Lex)
• Europäische Union: Verordnung (EU) 2023/1542 über Batterien und Altbatterien, 12.07.2023, EUR-Lex, abgerufen am 23.07.2026. (EUR-Lex)
• Europäische Union: Verordnung (EU) 2024/3110 über die Vermarktung von Bauprodukten, 27.11.2024, EUR-Lex, abgerufen am 23.07.2026. (EUR-Lex)
• Europäische Kommission: Ecodesign for Sustainable Products Regulation, laufend aktualisiert, Originalquelle, abgerufen am 23.07.2026. (European Commission)