Eleven categories of data to be mapped before the delegated act for the DPP arrives

Why the Data Model Is the Question That Really Matters

When a company begins considering the Digital Product Passport (DPP), the instinct is to focus on the QR code, the platform, or the technology provider. In reality, the crucial question comes first: what data do we already possess, and what data will we need to generate?

Essentially, the passport is a structured set of information linked to a specific product, batch, or model; it is accessible via a data carrier and connected to a unique identifier. While the container itself matters, it remains empty without reliable data.

However, one point is often overlooked: there is no single data model that applies to all products. Regulation (EU) 2024/1781 (ESPR) is a framework regulation; it defines the types of information that may be included in the passport, but leaves it to sector-specific delegated acts to specify which data points are mandatory for each product group, the required level of granularity, and the associated access rights.

The practical implication is this: the work that can be done today is not "filling out the DPP," but rather mapping your existing information assets against the categories that will, in all likelihood, be required.

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The Eleven Data Families to Inventory

The DPP Designer guide organizes potentially required information into eleven families. For each one, we examine its contents, provide a concrete example, and identify where such data is typically located within a company.

1. Composition and Materials

A list of the materials and components that make up the product, including their respective percentages (for example, a garment composed of 80% cotton and 20% polyester).

• Where the data is found: Bill of Materials (BOM), technical specifications, and composition labels. - Note: For complex products, a hierarchical structure (product → components → materials) is required, rather than a simple text field.

2. Origin and Provenance

The place of manufacture for the finished product and the origin of the raw materials (e.g., assembled in Italy, with cotton sourced from Turkey).

• Where to find the data: Procurement systems, supplier declarations, customs documents.
• Note: This is typically supply chain data, which depends on second- and third-tier suppliers. It must be collected well before the product is placed on the market.

3. Sustainability Metrics

Environmental indicators calculated for the product, such as its carbon footprint, expressed in kg CO₂e per unit.

• Where to find the data: Life Cycle Assessment (LCA) studies, Environmental Product Declarations (EPD), Product Environmental Footprint (PEF) calculations.
• Note: The methodology is crucial. Delegated acts may mandate specific calculation rules; a value calculated using a different method might not be reusable.

4. End-of-Life and Recycling Instructions

Guidance on disassembly, recycling, or disposal (e.g., removing the battery before disposal).

• Where to find the data: Technical manuals, WEEE (Waste Electrical and Electronic Equipment) documentation, and data sheets for waste treatment facilities.
• Target audience: Primarily recyclers and waste treatment operators, who will often have dedicated access rights.

5. Compliance Documentation

Documents demonstrating adherence to applicable regulations, such as EU declarations of conformity, certificates, and test reports.

• Where to find the data: Quality department, technical files, and records held by Notified Bodies.
• Note: Annex III of the ESPR (Ecodesign for Sustainable Products Regulation) explicitly includes declarations of conformity and technical documentation as potential content for the product passport. ### 6. Repair and Spare Parts Information

Repair procedures and the availability of spare parts—for example, a repair manual including spare part codes.

• Data source: After-sales support, spare parts catalogs, PLM (Product Lifecycle Management) systems.
• Target audience: Professional repairers, refurbishers, and consumers.

7. Substances of Concern

Substances of concern present in the product and their respective concentrations—such as substances included in the REACH candidate list (SVHCs) at concentrations above 0.1% by weight.

• Data source: Supplier declarations, SCIP databases, laboratory testing.
• Note: The ESPR (Ecodesign for Sustainable Products Regulation) establishes a specific requirement to track these substances throughout the entire product lifecycle; this is an area where the reuse of data already collected for REACH, RoHS, and SCIP is particularly relevant.

8. Recycled Content

The proportion of recycled material contained in the product—for example, 30% recycled aluminum.

• Data source: Certificates from raw material suppliers, chain-of-custody certification schemes.
• Note: It is necessary to distinguish between pre-consumer and post-consumer recycled content—a distinction that may become significant under future delegated acts.

9. Durability and performance

Data on durability and in-use performance (e.g., 1,000 charging cycles and a 5-year warranty).

• Source of data: R&D, reliability testing, warranty terms.
• Note: Durability and reliability are among the product parameters for which the ESPR (Ecodesign for Sustainable Products Regulation) allows delegated acts to set minimum requirements, rather than just information disclosure obligations.

10. Instructions for use and safety

Guidelines for correct and safe use: washing instructions, warnings, and usage limitations.

• Source of data: User manuals, labels, safety data sheets.
• Note: This information often already exists in document format (e.g., PDF); the real challenge lies in transitioning to structured, multilingual data.

11. Battery state of health

Residual capacity and battery condition, updated over time (e.g., 85% residual capacity after three years).

• Source of data: Battery Management Systems (BMS), telemetry platforms.
• Note: This is the only category of data that is inherently dynamic: the passport is not a snapshot taken at the factory, but a record that evolves throughout the product's use.

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Static and dynamic data: a design distinction

These eleven categories fall into two groups with significantly different architectural implications.

Type	Examples	Who updates them	Implications
Static	Composition, origin, compliance, recycled content	The manufacturer, at the time of market entry	Generated once; must be version-controlled if the model changes
Semi-static	instructions, spare parts, end-of-life	the manufacturer, over time	require documentation maintenance
Dynamic	battery health status, repair events	downstream operators, devices	require write permissions for entities other than the manufacturer

Designing a data model without this distinction leads to systems that function at launch but fail to support the product's lifecycle.

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The regulatory framework: what each source says

ESPR, Annex III

Annex III of Regulation (EU) 2024/1781 lists the categories of information that a delegated act may include in the passport: these include the unique product identifier, the GTIN or equivalent code, commodity codes, conformity documentation, user manuals, and information regarding the manufacturer and the economic operators involved. It serves as a "menu" from which each delegated act can make its selection.

ESPR, product parameters

In addition to Annex III, the ESPR defines product parameters—such as durability, reliability, repairability, recycled content, recyclability, environmental and carbon footprint, and the presence of substances of concern—for which delegated acts may establish both performance requirements and information obligations. Many of these parameters are directly reflected in the data categories described above.

Batteries: the first operational case

For batteries, the data model is not merely a hypothesis: Regulation (EU) 2023/1542 introduces a mandatory passport for industrial batteries, batteries for electric vehicles, and batteries for light means of transport, with the specific content detailed in Annex XIII. This serves as the first concrete test case for European product passports and—uniquely, thus far—includes dynamic data regarding the product's "health" status.

Textiles, steel, aluminum, and other product groups

Delegated acts for other sectors are currently in preparation. The European Commission’s ESPR (Ecodesign for Sustainable Products Regulation) work plan for 2025–2030 identifies iron and steel, textiles, aluminum, tires, furniture, and mattresses as priorities. Tentative timelines for the corresponding delegated acts are 2026 for iron and steel; 2027 for textiles, aluminum, and tires; and 2028 for furniture. To support this process, the Joint Research Centre published a report in March 2026 on the methodology for defining Digital Product Passport (DPP) data requirements under the ESPR framework—a useful resource for anticipating the logic that will underpin the development of individual data models.

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Where to begin: a five-step approach

1. Inventory. For each of the eleven product categories, determine whether the data exists, where it is located, and in what format (structured, document-based, or non-existent).
2. Quality and Ownership. For all existing data, identify who is responsible for it and the extent to which it can be verified; data declared by a supplier without supporting documentation carries less weight than a formal certificate.
3. Supply Chain Gaps. Isolate data that relies on suppliers (such as origin, chemical substances, or recycled content) and initiate requests immediately, as these are typically the most time-consuming to obtain.
4. Granularity. Assess whether data is available at the model, batch, or individual item level. The delegated act will specify the required level of granularity; shifting from a model-based approach to an item-based one can fundamentally alter the underlying architecture. 5. Regulatory monitoring. Track the progress of the delegated act relevant to your sector and update the mapping as drafts and standards become more established.

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Conclusion

The data model for the Digital Product Passport cannot be designed in the abstract; it depends on the specific sector, the relevant delegated act, and the supply chain. However, waiting for the final rules is no reason to stand still. The eleven categories of information cover almost everything addressed by the ESPR (Ecodesign for Sustainable Products Regulation) and the Batteries Regulation. Knowing what data you currently possess, where it is located, and how reliable it is, is the most practical way to ensure you are prepared when the deadline arrives.