Understand / Practical guide
ESPR and Digital Product Passports
The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, provides a framework for product sustainability requirements. DPPs are part of its information architecture; the framework alone does not define an identical passport for every product.
Where passports fit
ESPR connects product performance requirements with information that can support purchasing, repair, reuse and oversight. Its reach is broader than the earlier energy-related-products approach, but the existence of the framework is not evidence that a particular product already has a passport obligation. Read the regulation.
The path from framework to implementation
| Layer | What it contributes | Project consequence |
|---|---|---|
| Framework regulation | Principles, powers, essential DPP requirements | Design for adaptable identity, exchange and governance. |
| Working plan | Priorities and intended timing for work | Choose what to monitor and where to prepare. |
| Product measure | Scope and detailed obligations | Create the binding requirements baseline. |
| Technical standards | Methods and system interoperability | Select applicable specifications and test versions. |
| Operating procedures | How your organisation fulfils the obligation | Assign owners, controls and evidence. |
Keep all five layers in the project documentation. Internal procedures can be stricter than the legal baseline, but should be labelled as internal decisions.
What the working plan can tell you
The first plan prioritises selected materials and finished-product groups, with horizontal work as well. It is useful for allocating discovery resources. It is not a substitute for the precise scope, exemptions and application clauses of a delegated act. Working plan 2025–2030.
Why compliance and architecture teams must work together
A product rule can change the granularity of identity, visibility of information and duration of access. Those decisions affect manufacturing labels, data storage, contractual service continuity and operating cost. Waiting until software selection to involve compliance can leave a polished public interface attached to the wrong identity model.
Create a decision log with a cited rule or a clearly labelled assumption for every architectural choice. Make uncertain choices reversible: configure fields and permissions, keep source systems separate from publishing, and avoid burying rule logic in individual integration scripts.
Sources for this guide
- ESPR — Regulation (EU) 2024/1781
- Commission working plan 2025–2030 — COM(2025) 187
- European Commission: Digital Product Passport
Reviewed 4 October 2026. Check the current legal text and applicable product measures before acting.