Passport to Sustainability

To manage this phasing effectively, organisations must map their portfolios against anticipated delegated acts, identify which products are likely to be in the first wave and align development timelines accordingly. As delegated acts are published, cross-functional teams should translate requirements into product specifications and data fields within the DPP, ensuring traceability from raw materials to finished goods.

Product-level requirements must be embedded throughout the product development process to ensure compliance at release. Companies should explicitly incorporate ESPR and DPP obligations at each stage – idea generation and screening, development and testing, business analysis, product development, test marketing and product release – so that by the time a product is launched on the market, it meets the requirements in force at that moment. This backward-looking alignment requires early identification of delegated acts, periodic compliance checks, and adjustments to design, documentation and data capture to reflect evolving rules before final launch.

At the very least, expect the DPP to contain information on products’ origin and composition (materials, substances of concern,  recycled content); performance and sustainability (durability, reliability,  energy and resource efficiency,  carbon and broader environmental footprints); circularity and repair (reparability scores, the availability of spare parts, maintenance and refurbishment, disassembly, end-of-life handling); and compliance documentation (declarations of conformity, technical files, user instructions).

Collecting data is only the first step; it must be accurate, traceable, and audit ready. Define a single source of truth and assign an owner for every field – for example, engineering bills of materials, procurement for supplier declarations and sustainability for lifecycle assessment data. Introduce controls such as role-based permissions, change logs and automated validations. Support these with an interoperable systems architecture that can compile, verify and securely share information across complex, multi-tier supply chains.

The DPP is intended to interoperate with existing and forthcoming EU regulatory regimes, enabling consistent, machine-readable product data exchange among manufacturers, suppliers, regulators and market actors. Companies should assume that DPP data models will need to align with broader compliance obligations and technical solutions – spanning identifiers, data carriers and APIs – must support cross-regulatory traceability and secure information flows.

In practical terms, this implies harmonising master data (e.g. product identifiers and versioning), adopting standardised data carriers embedded in products or packaging, and building interfaces that grant authorised stakeholders access to the right information at the right time. Clear access policies are vital to protecting commercially sensitive data while meeting transparency requirements.

The transition poses clear challenges. Many companies will face a material compliance burden, particularly in collecting, standardising, and maintaining granular data in diverse portfolios. Investments will be required in technologies, processes and expertise; data governance will need to be strengthened to ensure accuracy, security and interoperability; and supply chain transparency will demand disciplined engagement with upstream suppliers, often across jurisdictions and systems.

At the same time, the DPP unlocks significant strategic opportunities. By institutionalising transparency and verifiable sustainability information, companies can build trust with customers and regulators, create value through circularity and resource efficiency, and save costs by improving their lifecycle management. Enhanced visibility across the value chain reduces the risk of exposure – whether related to authenticity, compliance, or environmental performance – and enables more resilient, responsive operations. Over time, the DPP can become a backbone for sustainable product innovation, aftermarket services and closed-loop business models.

To achieve maximum circularity impact depending on the product categories, ESPR and DPP requirements will vary per sector:

• For textiles, detailed information on fibre composition, dyes and chemicals, and repairability is often provided to support circular business models (e.g. resale and rental).
• In the furniture category, modularity and disassembly, materials of origin, and end-of-life pathways are commonly considered. Intermediate products such as iron, steel, or aluminium will often be categorised by the traceability of inputs and process-level environmental data.
• Electronics and ICT equipment are typically accompanied by component-level bills of materials, software/firmware versioning, cybersecurity considerations for data carriers, disclosure of critical raw materials and standardised repairability metrics.
• Batteries and other energy-storage product categories often require state-of-health and cycle-count data, chemistry and recycled-content disclosure, sourcing transparency and end-of-life routing to facilitate high-quality recycling.
• For home appliances and consumer electronics, information on spare parts availability, repair instructions, energy performance, and disassembly guidance is often included to align with right-to-repair expectations.
• Construction products will frequently be supplied with declared performance parameters, environmental product declarations (EPDs), embodied-carbon data, and traceability of aggregates and additives.
• Automotive parts and tyres are often identified with serial-level information, detailed information on composition of materials, wear/performance data, and safe end-of-life processing that can be linked to vehicle-level records.
• Packaging is typically labelled with material identifiers, recycled-content percentages, compatibility with local collection and sorting systems, and data to support reuse logistics.

Proactive supplier engagement, contractual data-sharing obligations, and routine verification will be necessary across sectors.

• The ESPR and the DPP represent a structural shift in how products are designed, documented and managed throughout their lifecycle. While compliance will require sustained investment and disciplined execution, the pay-off is greater resilience, stronger market positioning and measurable sustainability performance. Companies that act now – by aligning product development with forthcoming delegated acts, building interoperable data systems and engaging suppliers – will be best placed to navigate regulatory change and capture competitive advantage.
• For organisations seeking support, an expert-led gap assessment and readiness plan can provide a clear, actionable path to compliance and long-term value creation, tying governance, architecture and supplier management into a coherent implementation roadmap.
• To learn more about efficient ways of approaching ESPR and DPP requirements or for a conversation about our ESPR and DPP readiness assessment, please contact us.