EU’s Digital Product Passport Registry raises new data demands

The European Commission (EC) has introduced the Digital Product Passport (DPP) Registry and testing environment to establish DPPs as “a practical reality for businesses placing products on the EU market,” following the adoption of the Implementing Regulation establishing the practical arrangements for the Registry. 

Packaging Insights speaks to the plastics research center Aimplas, the European Organisation for Packaging and the Environment (EUROPEN), and Henkel, to find out how DPP can support data-sharing and transparency for packaging companies.

“The launch of the DPP Registry is an important milestone in the EU’s broader digital transition. It provides the infrastructure that enables the creation, management, and access to DPPs across the EU Single Market,” Marzia Scopelliti, senior public affairs manager at EUROPEN, tells us. 

“For the packaging sector, it is important to recognize that the main legislative framework remains the EU Packaging and Packaging Waste Regulation (PPWR), which already establishes specific rules for packaging, namely on labeling, with possibilities to use digital data carriers under certain conditions.”

Sonia Albein Urios, circular economy and environment cluster leader at Aimplas, adds that the Registry moves the DPP from a “regulatory concept” toward an “operational system.”

“The Registry will act as the common EU indexing service for DPP. It will store unique product identifiers, registration information, and selected metadata, while the detailed product information will generally remain in decentralized systems managed by economic operators or specialized service providers.”

Meanwhile, a Henkel spokesperson shares: “The launch of the DPP Registry is an important step toward the future implementation of DPPs. The successful implementation at scale will continue to require harmonized standards, reliable data across value chains, and clear frameworks that can be applied consistently across industries. Close collaboration among all stakeholders will be key.”

“At Henkel, we are actively preparing for DPPs across our consumer and industrial businesses. We are closely monitoring regulatory developments and working across our businesses to ensure that relevant product information can be provided in line with future requirements.”

DPP infrastructure

EUROPEN sees the launch of the DPP Registry is an important milestone in the EU’s broader digital transition.The DPP was established under the Ecodesign for Sustainable Products Regulation (ESPR). The EC describes the concept as a digital container of product information that strengthens supply chain transparency, informed consumer choices, and facilitates regulatory compliance. 

Aimplas’ Albein Urios explains that for the packaging industry, the Registry’s immediate significance is mainly indirect, as packaging is not currently subject to a general DPP obligation under the Ecodesign for Sustainable Products Regulation. 

“However, packaging will play an essential enabling role. In many cases, the data carrier giving access to the passport, such as a QR code or another digital identifier, may be placed on the packaging, due to the PPWR,” Albein Urios continues. 

“Packaging manufacturers will therefore increasingly need to ensure that their solutions are compatible with traceability systems, data carriers, product identification requirements, and the information flows of their customers. The launch of the Registry also provides greater clarity regarding the digital infrastructure to which future passports will have to connect.” 

EUROPEN’s Scopelliti adds: “While packaging is not one of the priority products in the scope of the ESPR, the use of digital tools can bring real benefits. They allow information that is currently printed on packaging to be made available digitally, giving businesses greater flexibility while providing consumers and authorities with access to more detailed and up-to-date information.”

“This can help reduce information on-pack, supporting the packaging minimization objectives, improve user experience, and support the EU’s digitalization objectives.” 

Ensuring compliance 

Even if packaging itself is not expected to require mandatory DPPs, packaging companies should closely monitor developments, explains Scopelliti. “Sectors that rely extensively on packaging for their products, such as batteries, textiles, and electronics, are among the first product groups expected to implement DPPs.”

Packaging manufacturers should have the possibility to use DPPS on a voluntary basis, according to EUROPEN.“At the same time, companies should closely monitor how the PPWR and the ESPR develop together. Where the PPWR already allows the use of digital data carriers, packaging manufacturers should have the possibility to use DPPS on a voluntary basis if they create added value.”

However, businesses should not face overlapping or contradictory requirements between the two legislative frameworks, she asserts. “A coherent approach will be essential to avoid unnecessary administrative burden and implementation costs.”

At the same time, Aimplas’ Albein Urios says the institute is developing a multidisciplinary approach that combines regulatory expertise, knowledge of materials and products, sustainability assessment, traceability, and digitalization.

“Our support starts with identifying the legislation and product-specific requirements applicable to each company. From there, we can help determine the relevant DPP data points, assess the availability and quality of the information, identify gaps in the company’s current systems, and define how data should be collected, structured, updated, and exchanged throughout the value chain.”

For plastic products and packaging, Aimplas can also provide the technical information for the passport, including material composition, recycled content, recyclability, environmental performance, carbon footprint, substances of concern, and end-of-life recommendations.

Last year, Sandra Ramos, a circular economy researcher at Aimplas, spoke to Packaging Insights about the digital passport for plastic products developed by Aimplas to inform consumers about product traceability, materials, recyclability, and carbon footprint.

“In addition, we support companies in selecting suitable data carriers and developing pilot DPP solutions and demonstrators. Our objective is not only to help companies create a digital interface, but to ensure that the information behind the passport is reliable, verifiable, interoperable, and consistent with regulatory requirements,” she told us.

Implementation cohesion 

One of the main remaining challenges to implementing DPP at scale is ensuring that the different EU legislative frameworks work together, argues Albein Urios. 

“If companies are required to provide the same information under both the PPWR and the ESPR, or if the two frameworks require information in different formats, implementation could become unnecessarily complex and costly. Avoiding duplication of obligations should therefore be a key priority.”

Aimplas is developing a multidisciplinary approach to determine relevant DPP data points.Another important challenge concerns data governance, she continues. “A DPP may contain different types of information, ranging from sustainability data and compliance documentation to commercially sensitive business information. It is therefore essential to clearly define who can access which information.”

“Consumers, market surveillance authorities, and business partners all have different information needs, and access rights should reflect those differences while ensuring confidential business information remains protected.” 

Interoperability is another critical issue, according to Albein Urios. The DPP architecture should enable different systems to communicate with one another so that information can be exchanged efficiently across the value chain, she explains. 

“DPPs have significant potential to improve transparency, support circularity, and facilitate the flow of information across value chains. For packaging, however, the PPWR should remain the primary regulatory framework, and any future DPP requirements should avoid regulatory duplication, inconsistencies, or conflicting obligations.” 

Recently, Packaging Insights also spoke to personal care packaging provider Segede about transparency in the DPP era.

Earlier this year, Securikett launched a strong-adhesive security label designed to keep DPP data accessible throughout a product’s lifecycle. Last year, Henkel, Korozo Group, and R-Cycle partnered to trial DPPs.