What data goes inside a Digital Product Passport?
Most teams treat the Digital Product Passport as a sustainability document. The bigger question, and the one that decides whether you are ready, is plainer than that. What data actually goes inside it, and which part of your business already holds that data? A passport is only as good as the fields behind the QR code. This article walks through the data a DPP carries and where each field comes from. For the wider picture, start with our guide on what a Digital Product Passport is.
What data does a Digital Product Passport contain?
A Digital Product Passport carries structured data across the product lifecycle. Under the EU Ecodesign for Sustainable Products Regulation (Regulation 2024/1781), Article 9 and Annex III set the categories: a unique product identifier, material composition, recycled content, carbon and environmental footprint, substances of concern, durability, repairability, and end-of-life instructions.
The exact fields differ by product group. A textile passport and a battery passport ask for different things. The categories, though, are consistent because they come from the same legal source. Annex III of the ESPR lists durability and reliability, repairability and maintainability, upgradeability, recyclability, recycled content, substances of concern, environmental and carbon footprint, and microplastic release.
Each category is a data field, and each field has an owner inside your business. The unique identifier comes from your numbering system. Material composition comes from your bill of materials. Carbon footprint comes from a lifecycle calculation. Recycled content comes from supplier declarations. None of it is invented at the point you build the passport. It is pulled from records you already keep, or should be keeping. For a field-level breakdown by category, see what is inside a Digital Product Passport.
Where does the unique identifier and material data come from?
The unique product identifier is the anchor of every DPP. It links the physical item to its digital record, usually through a GS1 Digital Link encoded in a 2D barcode. Material composition and the bill of materials come from Product Development. Recycled content percentages come from Procurement, drawn from supplier declarations and certificates.
The identifier is the part most teams get right, because they already run product numbering for retail. The harder part is the structured data behind it. Material composition sits in design and engineering files. Recycled content lives in purchasing records, often as a supplier claim that has never been checked against a certificate.
The EU Battery Regulation shows how specific this gets. From 18 August 2028, the battery passport must disclose the recycled content percentage of cobalt, lead, lithium, and nickel in the active materials. That is four named substances, each needing a verified figure traced back to a supplier. The identifier is the easy field. The supply chain data behind it is the work. How that identifier is structured for scanning is covered in our note on GS1 Digital Link link types.
What about carbon footprint, substances and end-of-life data?
Carbon footprint is a calculated value covering raw material extraction, manufacturing, distribution and end-of-life. Substances of concern follow legal thresholds, including substances of very high concern above 0.1% by weight under REACH. End-of-life data covers sorting, disassembly and recycling instructions. These fields draw on compliance, manufacturing and quality records.
Carbon footprint is the field that catches teams out, because it is not stored anywhere as a single number. It is produced by a lifecycle calculation. For EV batteries, the carbon footprint declaration has been mandatory since 18 February 2025, covering extraction, cell manufacturing, assembly, distribution and end-of-life.
Substances of concern are different. They are a disclosure tied to a legal threshold. The ESPR points to substances of very high concern present above 0.1% by weight under REACH, plus substances in specific hazard classes. That data comes from your quality and regulatory function, cross-checked against the formulation. End-of-life instructions, the sorting and disassembly detail, come from product and packaging design. Getting these fields right is what separates a passport that works from one that fails an audit. Our guide on choosing DPP software covers how to manage that data in one place.
Who inside a business actually owns the data?
No single team owns a Digital Product Passport. The data comes from Product Development, Procurement, quality and manufacturing. Sustainability usually interprets the regulation but rarely generates the underlying records. This split is the most common reason DPP projects stall, because the rule lands on a team that does not hold the data.
Our co-founder James Williamson puts the operational reality plainly.
This matters because the regulation is moving. The DPP registry and web portal go live in July 2026. Battery passports are required from 18 February 2027 for EV and industrial batteries above 2 kWh. The textiles delegated act is expected in 2027, with requirements following around 2028. The brands that cope are the ones treating the passport as a data project owned across functions, not a label owned by one team.
Accuracy is the part you cannot fake. Ian Batt, founder of Small Things Wine, learned this exporting across multiple regulatory markets.
If you are preparing for the 2027 and 2028 DPP deadlines, the first step is mapping which team holds each data field. See how Orijin Plus manages structured product data across raw materials and manufacturing, or start at orijinplus.global.
Frequently Asked Questions
What is the unique identifier in a Digital Product Passport?
The unique identifier is the data point that links a physical product to its digital passport record. It is usually a GS1 Digital Link encoded in a 2D barcode or QR code on-pack. When scanned, it points to the structured data that makes up the passport. It is the anchor field that every other piece of DPP data attaches to.
Does a DPP include carbon footprint data?
Yes. Carbon and environmental footprint is one of the data categories defined in Annex III of the EU Ecodesign for Sustainable Products Regulation. The figure is a calculated value covering raw material extraction, manufacturing, distribution and end-of-life. For EV batteries, a carbon footprint declaration has been mandatory since 18 February 2025.
What are substances of concern in a Digital Product Passport?
Substances of concern are materials a DPP must disclose because they carry health, safety or recycling risk. The ESPR points to substances of very high concern present above 0.1% by weight under REACH, substances in specific hazard classes, and substances that harm reuse or recycling. The data comes from quality and regulatory records checked against the product formulation.
Where does recycled content data come from?
Recycled content data comes from Procurement, drawn from supplier declarations and certificates. Under the EU Battery Regulation, from 18 August 2028 the battery passport must disclose the recycled percentage of cobalt, lead, lithium and nickel. Each figure must trace back to a verified supplier source rather than an unchecked claim.
Does a Digital Product Passport apply to food and drink?
Not yet directly. DPP requirements under the ESPR start with non-food categories, with textiles, electronics, toys and furniture in the early scope. Food, beverage and alcohol brands face similar directional requirements through other EU regulations covering traceability and structured product data, so the underlying data discipline still applies.
Who can see the data inside a DPP?
DPP data uses a tiered access model. Public data is open to consumers through the QR code. Restricted data is available to repairers and recyclers. A further tier is reserved for market surveillance authorities and customs. The same passport serves different data to different audiences depending on access rights.
How is DPP data kept up to date after a product ships?
The identifier on-pack is fixed at print, but the data it points to is held digitally and can be updated. A managed digital link and resolver lets a brand correct or add data after a product is on shelf, without reprinting packaging. This is why the passport is treated as a living data record rather than a static label.
