The Digital Product Passport Is Coming for Plastics: Is Your Data Ready?

The European Commission launched the Digital Product Passport Registry this summer, together with a testing environment and user guidelines. Furthermore, Implementing Regulation (EU) 2026/1778 laying down how the registry will operate, has been adopted and entered into force on 6 August 2026. After two years of policy development since the Ecodesign for Sustainable Products Regulation (ESPR) entered into force, the Digital Product Passport has moved from concept to infrastructure. Most recently, the last two standards in the set were published this month, with the first mandatory passports applying from February 2027 for certain large batteries. 

For the plastics value chain, this is a highly relevant topic: plastics sit inside almost every product category the DPP will eventually cover. The information the passport must carry such as material composition, recycled content, substances of concern and product lifecycle is challenging across a fragmented value chain of resin producers, compounders, converters and recyclers. This article explains what the DPP is, who will carry obligations, what data it will demand, and how to start getting ready for the DPP. 

A digital identity card for products, but not a central database 

The DPP, introduced by the ESPR, is best described as a digital identity card for products, components and materials. For each product covered by a delegated act, a passport must be made available in electronic form, carrying information that can range from technical performance and material origins to repair activities, recycling capabilities and lifecycle environmental impacts. The information must be accessible to consumers, authorities and companies along the value chain, in each case according to access rights defined in the applicable delegated act. The framework is layered, and understanding these layers matters for economic operators tracking their obligations:

• The ESPR sets the framework; 
• Delegated acts adopted under Article 4 define the concrete data requirements and access rights per product group; 
• Implementing acts govern shared infrastructure, like the Implementing Regulation (EU) 2026/1778 now does for the registry; 
• Harmonised standards specify the technical architecture.

The new DPP Registry, established under Article 13 ESPR, is not a central database of product data. It stores unique product identifiers and, for imported goods, commodity codes. The passport data itself remains with the economic operator or its DPP service provider. The model is decentralised by design; product data stays at the source under the control of the company responsible for it and is made accessible under defined conditions. 

Who will carry obligations, and who gets rights 

The ESPR applies to any physical good placed on the market or put into service, including components and intermediate products, and it distributes obligations and rights across the whole value chain. There are certain exceptions, including food, feed, medicinal and veterinary medicinal products, living plants, animals and micro-organisms, products of human origin, plants and animals relating to future reproduction, and vehicles already covered by their own sector-specific rules. 

The economic operator placing a product on the EU market, whether it is a manufacturer, authorised representative or importer, must make the DPP available. Furthermore, DPP service providers hosting passports face strict purpose limitation: they may not sell, reuse or process passport data beyond what is necessary to provide their service, unless the economic operator agrees otherwise. 

On the other side, a long list of actors gains access rights. Customers, distributors, professional repairers, refurbishers, remanufacturers, recyclers, market surveillance and customs authorities, and civil society organisations may access DPP data free of charge, according to the access regime set in each delegated act. 

Consumers should be able to consult the passport before they are bound by a contract, including in distance sale contracts. For recyclers and compounders in the plastics chain, this marks a significant change to the current state of play, considering the DPP is designed to provide material and substance information that often never travels past the first buyer. 

What data the passport will demand 

The precise data points will be set product group by product group in delegated acts, but the ESPR already defines the categories under Article 7. These include, among others, general product and operator identification; use, repair and life cycle; compliance and conformity documentation; and product performance information such as durability scores, repairability scores and carbon or environmental footprints. 

Article 7(5) ESPR sets a mandatory minimum for substances of concern: the passport must identify such substances by name or numerical code, state their location within the product, give their concentration or concentration range at the level of the product, component or spare part, and provide instructions for safe use and for disassembly, reuse, recycling and environmentally sound end-of-life management. 

The quality bar is equally demanding: DPP data must be accurate, complete and up to date, and must be maintained that way for at least the expected lifetime of the product. The passport must even remain available if the company responsible becomes insolvent or ceases activity. 

The timeline 

DPP obligations arrive sector by sector, each moving on its own legal track under the ESPR framework and its sector-specific counterparts: 

• Batteries lead the way: under the Batteries Regulation (EU) 2023/1542, a digital battery passport becomes mandatory for every EV battery, light means of transport (LMT) battery, e-bikes and e-scooters, for instance, and industrial battery above 2 kWh placed on the market from 18 February 2027, now under five months away. 
• Toys are next under the new Toy Safety Regulation (EU) 2025/2509, in force since 1 January 2026, every toy placed on the EU market must carry a digital product passport from 1 August 2030. 
• Construction products follow under the recast Construction Products Regulation (EU) 2024/3110, in force since 7 January 2025 with its main provisions applying from 8 January 2026. 

Beyond these dedicated regimes, the Commission's Ecodesign for Sustainable Products and Energy Labelling Working Plan sets out the further product groups it intends to prioritise for future ESPR delegated acts: textiles and footwear (its top priority, with ecodesign measures tentatively expected in 2027), furniture, mattresses, tyres, and steel and aluminium. Several of these draw heavily on petrochemical inputs, synthetic textile fibres, polyurethane mattress foams, and rubber/elastomer compounds in tyres, even if "plastics industry" isn't the precise label for all of them. 

A value-chain data problem, not a company data problem 

Almost none of the information a passport requires originates from a single entity in the plastics value chain. Material composition comes from polymer producers and compounders; recycled content and its evidence from recyclers; substance information from chemical suppliers up the chain; end-of-life data from waste operators. The economic operator who must "make the DPP available" is, in practice, assembling a dossier from data held by others, each with its own systems, formats and confidentiality concerns. This is precisely the fragmentation problem that a sectoral data space exists to solve. Projects such as CircPlastX provides a data space which is essentially the structured environment in which this assembly can happen: catalogue and metadata functionalities so datasets are described and discoverable; the Asset Administration Shell for consistent, machine-readable product and material descriptions; role-based access, purpose limitation and audit trails so that a supplier can contribute substance or composition data for a compliance purpose without exposing its formulations to the open market. 

CircPlastX's core services map directly onto the DPP's demands: certification of recycled content supports the recycled-content claims that passports and the Packaging and Packaging Waste Regulation will require; improved life cycle assessment data quality feeds environmental footprint information; and substances management support addresses the substances-of-concern category head on. The data space does not take over anyone's DPP obligations, those remain with the economic operators, but it makes them practically fulfillable. 

For more information on these themes, see our related CircPlastX articles: 

• Data Sharing You Can Trust: The Legal and Trust Framework Behind CircPlastX 
• From legal text to usable data: making plastics compliance easier 
• Digital Product Passports and Data Spaces: Different Paths, One Shared Goal – Trusted Data Sharing 

What plastics companies can do now

Readiness starts with knowing your data: 

• Which of the DPP data categories do you already hold, in what form, and with what quality? 
• Which will you need from suppliers, and do your contracts entitle you to receive it in a usable, machine-readable format?
• Which of your own data is commercially sensitive, and under what conditions are you prepared to share it downstream? 
• Who in your organisation is authorised to decide, and how quickly can that decision be made once a customer, auditor or supplier asks? 

Once you know where you stand, a few concrete steps carry you from assessment to action: 

• Start by confirming your own role in the chain: not everyone who touches a product is an economic operator for ESPR purposes, so establish whether you are the one placing it on the EU market under your own name, as set out above, since that is what determines whether the DPP obligation sits with you or further downstream.
•  From there, work out your timeline: product groups move onto the DPP at different points, batteries first, others to follow. 
• The next question is less legal than practical: what data actually exists. Much of what a passport needs, composition, supplier records, quality data, is usually already sitting somewhere in a PIM, ERP or PLM system; the real exercise is retrieving it, verifying it and keeping it up to date, rather than generating it from scratch. 
• Once you know what you hold, the applicable delegated act (or in the meantime the JRC methodology) tells you precisely which fields your DPP must carry, which is what turns the legal requirement into a workable data specification. 
• From there it becomes a question of architecture: identifiers, data carriers and hosting are technical choices with legal consequences, and increasingly less open-ended than they used to be.
  • The eight horizontal DPP standards developed by CEN/CLC/JTC 24 under standardisation request M/604 now split into two groups: 
    • Six, EN 18216:2026 (data exchange protocols), EN 18219:2026 (unique identifiers), EN 18220:2026 (data carriers), EN 18221:2026 (data storage, archiving and persistence), EN 18222:2026 (APIs for lifecycle management and searchability) and EN 18223:2026 (system interoperability), are both published and cited: Implementing Decision (EU) 2026/1736 entered into force on 15 July 2026, giving them the legal presumption of conformity under the ESPR. 
    • The remaining two are published but not yet cited: EN 18239:2026, covering access rights management, information system security and business confidentiality, and EN 18246:2026, covering data authentication, reliability and integrity, built around a secure electronically signed data construct (ESDC) aimed at limiting product fraud and counterfeiting. 
  • Together, these eight standards specify much of the architecture that determines how the access rights set out in the applicable delegated act actually get enforced in practice. 
• And none of these needs to happen in isolation: standardisation bodies, industry players and solution providers are working through the same questions, and a fragmented value chain like plastics has more to gain than most from a shared approach rather than each company solving DPP compliance on its own. 

Conclusion 

The Digital Product Passport is no longer a policy proposal to watch from a distance. With the registry live, the first implementing rules in force and the initial harmonised standards published, the infrastructure that plastics companies will plug into what is being built now, regardless of whether a delegated act for their own product group has been adopted yet. 

For the plastics value chain specifically, the DPP will rarely arrive on its own. It sits alongside the Packaging and Packaging Waste Regulation's recycled-content and labelling rules, REACH's restrictions on substances of concern, and, for polymers used in batteries or construction products, sector regimes with their own passport timelines. Getting the data architecture right is only half the exercise: each of these regimes allocates obligations, liability and access rights slightly differently, and a company that treats them as one undifferentiated "sustainability data" project risks building a system that satisfies none of them precisely. 

Contracts with suppliers and customers will also need to catch up, since who warrants the accuracy of data passed along a value chain, who bears the cost of a passport that turns out to be wrong, and on what terms confidential formulation data can be shared downstream are legal questions as much as technical ones, and existing supply agreements rarely answer them by default. 

Companies that start mapping these obligations now, rather than waiting for their own product group's delegated act to be adopted, put themselves in a position to comply on their own timeline. 

This blog post is written as part of Timelex's participation in the CircPlastX project, funded by the European Commission's Digital Europe Programme under Grant Agreement 101195258. To learn more about the project or explore participation in the data space, visit the CircPlastX website or contact the consortium.