The DPP is the same obligation for everyone – but not in the same way

Why? Here’s why.

One of the most common questions we hear from companies is: “Does the Digital Product Passport apply to us too?” The answer (in light of the plans set out in the regulation introducing the Digital Product Passport obligation) is almost* always the same: yes – but not in the same way as for others.

*Almost, because some sectors are subject to exemptions and have their own regulatory systems.

The Digital Product Passport (DPP) is not one universal set of obligations. Its scope, rollout pace, and required data differ significantly depending on the sector, product type, and the company’s role in the supply chain.

Below are a few examples that best show why a single “one-size-fits-all” approach to the DPP does not work.

Toys: safety, traceability and GPSR

In the toy sector, the DPP is closely linked to product safety and the new obligations under the GPSR (General Product Safety Regulation). Key areas for this sector include:

In this context, the DPP is not an add-on “for the future” but a practical tool for meeting GPSR obligations – organising data that must already be available to market surveillance authorities and consumers. The environmental impact dimension has been excluded for now – although it may, but need not, appear in the DPP (see: Toy Safety Regulation (EU) 2025/2509).

Batteries: regulation “here and now”, not in the future – first on the implementation list

Batteries are one of the most heavily regulated sectors covered by the DPP. Requirements include, among others: carbon footprint, material composition, durability and recyclability, and product lifecycle data. Companies must prepare data, processes and systems now, not when the final stage of the regulation enters into force.

Key regulations:

Regulation (EU) 2023/1542 on batteries and waste batteries – the obligation for a Digital Product Passport (DPP) for certain battery categories, the scope of data that must be in the passport, battery traceability, carbon footprint, durability, recyclability, and obligations for producers, importers and distributors.

It is also worth noting other acts linked to the implementation of the DPP:

Textiles: supply chain transparency, next in line after batteries

There are no clear sector-specific guidelines for textiles yet, although guidelines can be expected to align with the expectations set out in the Ecodesign for Sustainable Products Regulation (ESPR) and the EU Strategy for Sustainable and Circular Textiles.

In textiles, the focus is on: origin of raw materials, production processes, environmental and social aspects, and preparing the product for reuse and recycling. This is a sector where the DPP simply will not work without supplier cooperation. The passport becomes a tool for organising the entire supply chain, not just the individual end product. Work on detailed regulations is being carried out as a matter of priority.

Furniture: DPP, GPSR, EUDR

The furniture sector is also among the first sectors chosen for the rollout of Digital Product Passports in the EU, making DPP preparation here urgent and multi-faceted.

For furniture, the DPP covers, among other things: material composition and origin of raw materials, environmental information, repairability, disassembly and recyclability, and data consistency across the product lifecycle. At the same time, obligations under the GPSR are increasingly important, in particular: product and batch traceability, responsibility for product safety throughout its use, and quick access to information in the event of reports, incidents or recalls.

A further key element is EUDR (EU Deforestation Regulation), which requires: confirmation of the origin of raw materials such as wood, traceability in the supply chain, and linking environmental data to product documentation. Although delayed, EUDR will in all likelihood be an element to be reported in the DPP.

The DPP as a collection of information

In this context, the DPP acts as a common “data container”, bringing together the requirements of sectoral regulations under ESPR, GPSR and EUDR in a single approach.

The growing role of customs data

In the background, work is underway on changes in the customs area. As part of the reform of the Union Customs Code (UCC), the aim is full digitalisation of procedures, removal of the customs exemption for consignments up to €150, and the creation of a central EU data portal (EU Customs Data Hub). These changes, being rolled out gradually by 2032, will include tighter e-commerce trade, a new “Trust & Check” trusted trader status, and better risk management.

For importers (who also face the obligation to implement the DPP for products they place on the EU market for the first time), this means that data used today for customs, EUDR and product safety will increasingly need to be consistent and interlinked.

The DPP does not start with a system

The DPP starts with understanding the sector context and related regulations – such as GPSR, EUDR or customs changes. What is critical for batteries will not be the priority for toys. What works for textiles will not translate 1:1 to furniture or construction. So preparing for the DPP requires an individual analysis; it should not be based on off-the-shelf templates – it is best to start by verifying obligations, data and processes.

What does this mean in practice?

The first step is not to implement new technology, but to have a conversation and clarify assumptions. Companies that start preparing for the DPP without taking account of their sector and related regulations more often: make wrong system decisions, burn through budget, and feel worn down by constant change.

As a provider of digital solutions for meeting the DPP obligation, we recommend a more systematic and analytical approach. If you want to see how the DPP (and GPSR, EUDR, customs obligations or other requirements) apply in your sector, it is worth starting with a consultation with us.