Digital product passports are here. Here’s how to turn them to your advantage.

Sustainability has long been a watchword for the private and public sectors, with governments especially applying pressure to ensure all sections of society play their part in mitigating the impact of climate change. In fact, for over a year, the EU has been proactively implementing initiatives such as the Ecodesign for Sustainable Product Regulation (ESPR), which came into force this time last year to ensure that companies selling in the EU marketplace begin taking their eco-responsibilities seriously. 

As part of this regulation, the EU’s recently-published Energy Labelling Working Plan 2025-30 has brought into force a range of horizontal requirements such as repairability scoring (which could include consumer electronics), recycled content, and recyclability of electronic equipment. These steps are perhaps unsurprising when we consider that technology products generated approximately 62m metric tons of e‑waste in 2022, with only 22–22.3% of it being formally collected or recycled. 

The EU’s eco-movement

The ESPR is described as ‘the cornerstone of the Commission’s approach to more environmentally sustainable and circular products’, and stands as part of the larger Circular Economy Action Plan (CEAP). In short, it aims to set the design requirements for a vast number of products, within specified industries, that are placed on the EU market (regardless of where they were manufactured). Therefore, tech companies operating in the marketplace must take a greater interest in the carbon footprint of the products they put into circulation, to ensure compliance and support the EU’s circularity efforts. 

The ESPR aims to encourage the extension of product lifespans, resource efficiency, and enhanced recyclability, as part of its wider sustainability goals. As part of this legislative move towards a circular economy, the mandating of Digital Product Passports (DPPs) – a tool used for collecting and sharing product data throughout a product’s lifecycle – remains an essential tool for the EU. By mandating the use of DPPs, the Commission aims to ensure all parties involved in a product’s lifecycle, from manufacturer to consumer, are given greater transparency into a product’s makeup, functionality, distribution, and disposal. By doing so, the EU hopes to encourage manufacturers and supply chain managers to adopt more sustainable practices while encouraging consumers to be more conscious of the environmental implications in purchasing certain products. 

The mandate is set to apply to select product groups across a range of industries, including but not limited to the electronics, textile, and furniture industries. For technology products, it will be the new Working Plan’s horizontal requirements, such as repairability scoring, recycled content, and the recyclability of electronic equipment, that will be relevant and applicable. This delegated act (providing the regulatory requirements for products that fall into this group) is expected by 2027. Therefore, businesses must start preparing now to ensure their compliance and support a smooth transition amidst this changing landscape. 

How DPPs are powering sustainability initiatives in the tech sector

By design, DPPs act as a lynchpin for circularity efforts by facilitating the sharing of sustainability data vital to every stakeholder in the value chain. Additionally, they act as a digital record of a physical product, securely keeping track of information about it throughout its lifecycle, which can include data on its sustainability credentials, such as the carbon footprint of its production and other important details. Through their transparent nature, DPPs will support tech enterprises in streamlining compliance efforts and reducing the administrative burdens associated with this EU movement.

They can provide advice on how to dispose of a product to ensure that any elements that can be recycled have the opportunity to be reused. Typically, DPPs are accessible via a data carrier (such as a QR code) affixed to a physical product and scannable by a smartphone. The accessibility that DPPs provide through the compact data carrier enables all individuals active in a product’s lifecycle to access a range of data on demand and play a key role in ensuring the item’s circularity journey. 

They will play a crucial role in advancing technology products and their contribution to the EU’s circularity goals. By offering deep, transparent access to key product and material data, DPPs can help tech companies verify components and ensure they’re sourced sustainably and ethically. This level of insight empowers hardware manufacturers, device makers, and supply chain partners to make more environmentally responsible decisions and maintain greater visibility over the lifecycle of their products in circulation.

Getting compliant now

Tech companies should begin their path to compliance by ensuring they have the right data infrastructure and digital tools in place to support the shift toward DPPs. A foundational step in this process is education, developing a clear understanding of how evolving EU legislation will impact operations across hardware manufacturing, component sourcing, and product lifecycle management. Assigning a dedicated compliance or sustainability lead to navigate the technical and regulatory complexities of DPPs can help organisations shape a coherent, sector-specific implementation strategy.

In the early stages, it’s also essential to audit existing e-waste handling, repairability practices, and materials recovery workflows. Understanding how DPPs could enhance traceability and accountability within these processes can inform more sustainable operations and guide investment in necessary systems upgrades. As companies build this foundation, they’ll be better positioned to assess which aspects of their current processes, whether in sourcing, logistics, or end-of-life product handling, may be affected by DPP requirements. 

Given the complexity of tech supply chains, it’s worth considering early on who might lead or support DPP implementation, whether internal teams or external partners. Mapping the supply chain to pinpoint where data collection will be required can not only accelerate compliance but also enhance long-term operational resilience and transparency.

Matthew Ekholm is a DPP and Circularity Specialist at Protokol

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