INDEPENDENT GUIDANCE EU regulation · Product data · Enterprise procurement

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

LayerWhat it contributesProject consequence
Framework regulationPrinciples, powers, essential DPP requirementsDesign for adaptable identity, exchange and governance.
Working planPriorities and intended timing for workChoose what to monitor and where to prepare.
Product measureScope and detailed obligationsCreate the binding requirements baseline.
Technical standardsMethods and system interoperabilitySelect applicable specifications and test versions.
Operating proceduresHow your organisation fulfils the obligationAssign 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

Reviewed 4 October 2026. Check the current legal text and applicable product measures before acting.