--- title: "Digital Product Passport: the 6 key steps to ensure you aren’t caught unprepared." description: "The Digital Product Passport is being introduced for specific product groups, but compliance takes time. Six operational steps to prepare: mapping products and roles, managing supply chain data, linking the passport to the item, registering it, controlling access, and updating e-commerce systems." url: https://www.dppdesigner.com/en/articles/dpp-6-key-steps-to-ensure language: en published: 2026-05-23 updated: 2026-11-04 author: "Corrado Facchini, CTO & Innovation Manager" publisher: "DPP Designer" --- # Digital Product Passport: the 6 key steps to ensure you aren’t caught unprepared. The Digital Product Passport is being introduced for specific product groups, but compliance takes time. Six operational steps to prepare: mapping products and roles, managing supply chain data, linking the passport to the item, registering it, controlling access, and updating e-commerce systems. The Digital Product Passport (DPP) is no longer just a topic for conferences. The Ecodesign for Sustainable Products Regulation (ESPR, EU Regulation 2024/1781) has been in force since July 18, 2024; in May 2026, CEN and CENELEC published the first six European technical standards for the DPP; and in July 2026, the Commission launched the **EU registry for passports**, complete with a testing environment and a dedicated helpdesk. However, the obligation does not take effect for everyone on the same date. The DPP becomes mandatory **on a product-group-by-product-group basis** through delegated acts that define specific content and deadlines, with an adaptation period of at least 18 months following their adoption. Eighteen months may seem like a long time, but it is not—especially when you consider that, in the interim, you may need to renegotiate supplier contracts, organize product master data, update labels and packaging, upgrade your IT infrastructure, and familiarize yourself with the EU registry. Here is what the adaptation process entails in practical terms. ## What adaptation entails: operational steps ### 1. Mapping products and roles The first step is to conduct an inventory. Identify which of your products fall under a category subject to the DPP (either currently or as part of the Commission’s work plan) and determine your specific role for each: **manufacturer, importer, distributor, or retailer**. This is not a trivial question, as obligations vary significantly depending on your role: the entity placing the product on the market is responsible for creating, registering, and maintaining the passport, while those who distribute or sell the product must ensure it is present and accessible to the customer. A single operator may also hold different roles across different product lines: for instance, a company might act as a manufacturer for its own collection, while serving as an importer for items sourced from Asia and sold under its own brand. **Expected outcome:** A matrix mapping products to roles and their corresponding delegated acts, including the indicative application date for each product line. ### 2. Data collection and governance Data lies at the heart of the DPP, and this is where the bulk of the effort is concentrated. Manufacturers and importers must collect the information required by the relevant delegated act, which typically includes: - origin and composition of materials; - recycled material content; - presence of substances of concern; - environmental footprint (e.g., embodied carbon); - instructions for repair, disassembly, and end-of-life disposal. Much of this information does not originate within the company but is **provided by suppliers**. Consequently, it is advisable to update contracts and technical specifications now, establishing an obligation to provide data in a structured format—with clearly defined timelines and responsibilities—along with provisions for verification. Internal governance is also essential: determining who "owns" each data field, identifying the system where it resides (ERP, PLM, PIM), and establishing processes for managing updates and version control. The regulation requires that the data in the passport be accurate, complete, and up to date. ### 3. Linking the passport to the product The DPP must be linked to the physical good via a **persistent, unique identifier** and a **data carrier** (such as a QR code, barcode, or RFID/NFC tag). This carrier must be affixed to the product, its packaging, or the accompanying documentation, in accordance with the requirements set out in the relevant delegated act. The same act also defines the level of granularity for the passport—whether it applies to a specific model, a batch, or an individual item. Regarding the structure of identifiers, the reference is the European standard **EN 18219:2026**, which governs unique identifiers for products, economic operators, and facilities, and specifically provides for these three levels of granularity. The physical medium, meanwhile, is covered by the companion standard, EN 18220. We discuss this in detail in [From QR Codes to Unique URLs](https://www.dppdesigner.com/it/articoli/qrcode-url-unici-en18219). A practical tip: choose a domain and an addressing logic that you control—one that will remain functional even if you change your technology provider. A QR code printed on millions of items cannot be "updated." ### 4. Registering the DPP and ensuring its availability The passport does not reside in a single, centralized European database; the data remains with the economic operator or their service provider. However, the unique identifier and its associated metadata must be recorded in the **EU registry** before the product is placed on the market. This registry allows authorities—such as customs—to verify the existence of a passport for imported goods. Furthermore, the passport must remain accessible for the entire duration specified by the relevant delegated act, **even if the company ceases operations or goes bankrupt**. For this reason, the ESPR requires a **backup copy** to be held by an independent, third-party DPP service provider. When selecting a platform, therefore, consider not only its features but also its backup replication capabilities, data portability, and exit clauses. ### 5. Managing Access Not all information within the DPP is public. The passport incorporates **differentiated access levels** based on the user: - **Consumers**, who can view essential information regarding sustainability, usage, and maintenance; - **Supply chain operators**, who have access to more detailed technical data; - **Repairers and recyclers**, who require instructions on disassembly and product composition; - **Market surveillance authorities and customs**, who can consult the data necessary for compliance checks. This architecture ensures the transparency required by the regulation without exposing sensitive commercial data, such as specific formulations, supplier details, or costs. It must be designed with care: determining which data fields are assigned to which user profile is a decision that involves compliance, legal, and commercial departments—not just IT. ### 6. Updating Sales Channels and E-commerce The DPP must be accessible **prior to purchase**, even when the customer does not yet have the physical product in hand. Consequently, those placing a product on the market must provide retailers and marketplaces with a digital copy of the data carrier or the unique identifier. For their part, retailers and marketplaces must configure product pages, data feeds, and catalogs to display the link or QR code for the passport. In practical terms, this means adding a new attribute to PIM (Product Information Management) workflows and marketplace feeds, updating product page templates, and verifying that the link functions correctly across every channel. ## Where to Begin Even if the delegated act for your specific sector has not yet been adopted, now is the time to take action. Technical standards have already been published, the registry is operational, and the most time-consuming tasks—those involving data and suppliers—do not depend on the final details of the delegated act. A sensible sequence: 1. **Immediately:** map products and roles, and review supply contracts. 2. **Over the coming months:** take stock of available data and identify gaps, then select an identification scheme and a DPP (Digital Product Passport) platform. 3. **Upon adoption of the delegated act:** align data fields with the final requirements, conduct testing on the EU registry, and update labels and e-commerce channels. Waiting until the last minute means having to tackle everything at once. Starting early, by contrast, allows you to turn a compliance obligation into a valuable data asset—one that can also benefit quality management, marketing, and customer relations. ## Sources - [Regulation (EU) 2024/1781 – Ecodesign for Sustainable Products Regulation (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj) - [European Circular Economy Stakeholder Platform – New Digital Product Passport Registry goes live](https://circulareconomy.europa.eu/node/10178) - [Eunews – The EU launches the Digital Product Passport Registry](https://www.eunews.it/en/2026/07/22/an-identity-card-for-every-product-on-the-market-the-eu-launches-the-digital-product-passport-registry/) - [CDX – First European Standards for the Digital Product Passport Published](https://public.cdxsystem.com/en/web/cdx/w/first-european-standards-for-the-digital-product-passport-published) - [Think WIoT – CEN-CENELEC Publishes Six Standards for the EU Digital Product Passport](https://wiot-group.com/think/en/news/cen-cenelec-six-eu-dpp-standards-en-18xxx/) - [Genorma – EN 18219:2026 Digital product passport – Unique identifiers](https://genorma.com/en/standards/en-18219-2026) - [GS1 Italy – The Digital Product Passport (presentation)](https://gs1it.org/files/sharing/1742921310/3617/gs1it-digital-product-passportpptx.pdf) - [osapiens – DPP Digital Product Passport (IT)](https://osapiens.com/it/regulations/dpp-digital-product-passport) - [dpp-tool.com – ESPR Delegated Acts: timeline](https://dpp-tool.com/en/blog/espr-delegated-acts/) - [B.D. Emerson – Digital Product Passport: storage, back-up copy and registry](https://www.bdemerson.com/article/digital-product-passport) - [Renoon – Who is responsible for the Digital Product Passport](https://linguana.renoon.com/blog/who-is-responsible-for-the-digital-product-passport) - [DPP Designer – From QR Code to unique URLs (EN 18219)](https://www.dppdesigner.com/it/articoli/qrcode-url-unici-en18219)