🧾 Required Attributes for Products under DPP (ESPR)

Under the European Parliament’s 2024 position on the Ecodesign for Sustainable Products Regulation (ESPR), many product groups placed on the European Union market will be required to carry a Digital Product Passport (DPP).

The passport makes key information accessible throughout the value chain and supports circular economy objectives.

This article explains the required attributes for products under DPP as outlined in the Parliament’s text.

Many product types will fall under ESPR, while batteries are addressed under separate legislation and a dedicated Digital Battery Passport, and are therefore not covered here.

Overview of DPP Data Categories for Products

For products in scope of ESPR, the Digital Product Passport is a structured electronic record linked to each product, component, or batch.

According to the European Parliament’s 2024 position on ESPR, the DPP data set is organised into five main categories:

• Identification and contact information.
• Product and operational information.
• Product lifetime and sustainability information.
• Material and substance information.
• Environmental impact and efficiency information.

Delegated acts for each product group will specify which attributes are applicable and at what level of detail.

🧾 Identification and Contact Information

This first data block ensures that economic operators connected with the product can be clearly identified:

• Name, contact details, and unique operator identifier code of the economic operator established in the Union.
• Importer information, where applicable, including the information referred to in Article 23(3) and the Economic Operator Registration and Identification (EORI) number.
• Unique facility identifiers for relevant production or processing sites.
• Unique operator identifiers other than that of the manufacturer.
• Information related to the manufacturer, including its unique operator identifier and the information referred to in Article 21(7).

These attributes are fundamental for traceability, market surveillance, and incident management.

⚙️ Product and Operational Information

The second category of mandatory DPP attributes for products relates to use, documentation, and regulatory status:

• User manuals, instructions, warnings, or safety information required by other applicable Union legislation.
• Compliance documentation and information required under ESPR or other Union law, such as declarations of conformity, technical documentation, or conformity certificates.
• Relevant commodity codes, for example a TARIC code as defined in Council Regulation (EEC) No 2658/87.
• The Global Trade Identification Number as provided for in standard ISO/IEC 15459-6 or equivalent for products or their parts.
• The unique product identifier at the level indicated in the applicable delegated act adopted pursuant to Article 4.

Together, these datasets show how the product is classified and how it meets applicable EU requirements.

♻️ Product Lifetime and Sustainability Information

ESPR places strong emphasis on designing products for durability, repair, and circularity.

The DPP must contain information on:

• Durability and reliability of the product or its components.
• Ease of repair and maintenance.
• Ease of upgrading, re‑use, remanufacturing, and refurbishment.
• Information for consumers and other end‑users on installing, using, maintaining, and repairing the product to minimise environmental impact and ensure optimum durability, and on how to return or dispose of the product at end‑of‑life.
• Ease and quality of recycling.

These attributes support longer product lifetimes and more efficient resource use.

🧱 Material and Substance Information

A further essential group of DPP product data concerns materials and chemicals:

• Names of substances of concern present in the product.
• Location of substances of concern within the product.
• Concentration, maximum concentration, or concentration ranges of substances of concern at product, main component, or spare‑part level.
• Relevant instructions for the safe use of the product.
• Information relevant for disassembly, enabling safe and efficient recovery of parts and materials.

This information facilitates safe use, effective repair, and high‑quality recycling operations.

🌍 Environmental Impact and Efficiency

The final block addresses environmental performance indicators.
Depending on the product group, the Digital Product Passport may need to include some or all of the following types of information:

• Energy and resource performance
• Energy use or energy efficiency.
• Resource use or resource efficiency.
• Consumption of energy, water, and other resources in one or more life‑cycle stages.
• Weight and volume of the product and its packaging, and the product‑to‑packaging ratio.

• Circularity and waste‑related information
• Recycled content.
• Possibility of remanufacturing and recycling.
• Possibility of recovery of materials.
• Expected generation of waste materials.
• Amounts of waste generated, including plastic waste and packaging waste and their ease of re‑use, and amounts of hazardous waste generated.
• Avoidance of technical solutions detrimental to re‑use, upgrading, repair, maintenance, refurbishment, remanufacturing, and recycling of products and components.
• Incorporation of used components.

• Emissions and pollution
• Use of substances during the production process or leading to their presence in products, including once these products become waste.
• Emissions to air, water, or soil released in one or more life‑cycle stages of the product.
• Microplastic release.

• Footprint and use‑phase aspects
• The carbon footprint of the product.
• The environmental footprint of the product.
• Quantity, characteristics, and availability of consumables needed for proper use and maintenance.
• Conditions for use.

These attributes enable more transparent assessment of environmental impacts and support greener purchasing and design decisions.

🤝 How ComplyMarket Supports DPP Attribute Compliance

Implementing the required attributes for products under DPP will require significant coordination across design, engineering, regulatory, sustainability, and supply‑chain teams.

Economic operators must gather reliable data from suppliers, adapt documentation, and integrate new data structures into their product information systems.

ComplyMarket supports organisations by:

• Mapping existing product data against the ESPR Digital Product Passport categories and identifying gaps.
• Assisting with supplier engagement to obtain accurate material, substance, and environmental information.
• Reviewing technical documentation, identifiers, and user information for consistency with expected DPP structures.
• Monitoring delegated acts and regulatory developments to keep product datasets aligned with the evolving ESPR framework.

With structured preparation and expert support from ComplyMarket, manufacturers, importers, and brand owners can implement these DPP data requirements and secure ongoing access to the European market.