EU Digital Product Passport 2026: What Manufacturers and Importers Must Do

Key data

If your company sells products in Europe, this regulation requires you to act. Commission Implementing Decision (EU) 2026/1736, published on 15 July 2026, approves the harmonised technical standards that specify how the digital product passport (DPP) should be implemented, the central instrument of Regulation (EU) 2024/1781 on ecodesign of sustainable products.

This is not a statement of intent: the technical standards are already approved and define the concrete requirements for interoperability, data formats and unique identification systems that each product must have associated with it.

What does this regulation establish?

The digital product passport (DPP) is an electronic record linked to each item that must contain structured information on four key areas:

• Product composition: materials, components and substances used.
• Environmental footprint: environmental impact throughout the product lifecycle.
• Repairability: availability of spare parts, ease of repair and durability.
• End-of-life: disassembly, recycling and waste management instructions.

Decision 2026/1736 specifies the technical requirements that make this passport operational:

This decision develops the technical framework that Regulation (EU) 2024/1781 left pending. With its approval, companies now have the final specifications to begin adapting their systems.

Economic and operational impact

The DPP is not a minor administrative procedure. It involves a real transformation of information systems and the supply chain. These are the main cost and impact vectors:

• Digital infrastructure: companies must implement or adapt systems capable of generating, storing and sharing DPPs in the harmonised formats required.
• Supplier management: to complete composition and environmental footprint data, it is necessary to collect information from the entire supply chain, including second and third-tier suppliers.
• Product identification: each item marketed in the EU will need a unique identifier, which may require changes to labelling, packaging and internal traceability systems.
• Market access risk: non-compliance can result in barriers to access to the European market, with the consequent impact on sales and contracts.

Companies that already work with product lifecycle management (PLM) systems or advanced traceability standards will have an advantage. Those that do not will need to plan significant investment in technology and processes.

Who does it affect?

The regulation applies to all economic operators marketing products in the European single market:

• Manufacturers based in the EU that produce goods for the European market.
• Importers that introduce products from third countries into the EU market.
• Distributors that market products in the single market, regardless of origin.
• Authorised representatives of manufacturers not established in the EU.

In practice, this covers sectors as diverse as electronics, textiles, machinery, construction, household appliances, batteries or chemical products, among others. The specific sectoral scope will be defined by product categories in the delegated acts of Regulation (EU) 2024/1781.

Practical example

Imagine a Spanish company that imports LED luminaires manufactured in Asia for distribution in the European market. With the entry into force of the technical standards approved by Decision 2026/1736, this company—as an importer—will be responsible for ensuring that each luminaire marketed in the EU has an associated digital product passport with information on the materials used, the carbon footprint of the manufacturing process, repair instructions and recycling options at the end of its useful life.

To do this, it will need to coordinate with the Asian manufacturer to obtain all that data, integrate it into a system compatible with the harmonised formats required, assign a unique identifier to each unit and ensure that the information is accessible to market authorities and consumers. If it does not, the product cannot be legally marketed in the EU.

What should companies do now?

1. Assess the impact on your product portfolio: identify which categories of products you market in the EU will be subject to the DPP and on what timelines, following the calendar of delegated acts of Regulation (EU) 2024/1781.
2. Audit current information systems: check whether your management systems (ERP, PLM, WMS) can generate and manage DPPs in the harmonised formats required. If not, plan for adaptation or replacement.
3. Map the supply chain: identify what data you need from each supplier (composition, materials, environmental footprint) and establish mechanisms to collect it systematically.
4. Design the unique identification system: define how you will assign unique identifiers to each product and how you will link them to the corresponding digital record.
5. Involve suppliers and logistics partners: the required traceability requires collaboration from the entire chain. Communicate requirements to your suppliers as soon as possible to avoid bottlenecks.
6. Consult with a specialist in product regulation and sustainability: the technical and legal complexity of the DPP recommends having expert advice to avoid errors that could result in barriers to access to the European market.

Official source

Consult the complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601736