Digital Product Passport: Opportunities for a stronger, more sustainable Single Market

By Alison Grace

By Amina Aissani

By Margaux Le Gallou

What is a Digital Product Passport (DPP)?

A Digital Product Passport (DPP) is a digital record for products, components, and materials [1]. It contains information about a product – including its sustainability, circularity, and safety – to facilitate compliance with relevant legislation. When the DPP is in place, it must then be filled with information, which will rely on harmonised sectoral product legislation and supporting standards.

Why is it relevant now?

The European Product Regulation proposal is due to be published by the European Commission on 6 October [2]. It covers:

• The New Legislative Framework (NLF) [3], which sets out the the conditions for placing a wide range of products on the EU market and rules for affixing the CE marking of products
• The Market Surveillance Regulation [4], which sets out how products entering the EU market are monitored

The European Product Regulation will provide the horizontal framework for placing products on the Single Market. It may be complemented by product legislation, which in turn is complemented by standards.

Because of this, the European Standardisation Regulation [5] – also being revised with a proposal due on the same day – will support the European Product Regulation. It governs how Europe’s standardisation system operates.

Together, these laws will set Europe’s baseline for sustainable, compliant products, and are essential for reinforcing the Single Market, closing loopholes, and updating definitions about products and economic operators. DPP will play a central role.

What would a strong DPP system look like?

A strong DPP system supports the sharing of product information, aiming to improve the overall quality of products on the EU market, including their sustainability. It can do this by:

• Facilitating customs and market surveillance checks – especially paper trails and access to information (without replacing checks on physical products).
• Providing an infrastructure to digitalise conformity documentation and a single point of entry to the EU Single Market – both for products that are obliged to create a DPP, and those that are not (yet).
• Clarifying roles and obligations to make sure DPPs are created and kept up to date throughout a product’s full lifecycle.
• Obliging Member States to check that DPPs exist – and verify their content: no data, no market access.
• Supplying environmental, safety, and health information of a product. For example, by providing transparency on the presence of substances of concern.
• Imposing penalties on companies that provide false information or fail to provide it altogether.

When paired with an identifiable mark, such as a CE marking, a strong DPP system is also an opportunity to keep consumers informed about the products they buy. For example, at the point of sale, or when a product is faulty and must be recalled.

Why are standards so important for a successful DPP framework?

The technicalities of the DPP rely on standards, which must be fit for purpose. The DPP can enable transparency, accessibility, and verifiability – including through the interoperability of data throughout the value chain.

Beyond IT, standards will also be used to refine the information requirements set in EU sectoral laws, such as ecodesign and product safety laws.

Standards will also enable DPP adoption beyond the EU – for manufacturers importing to the EU and their suppliers (who may not be directly involved with the EU market). Other countries, including China, are developing their own DPP, so coordination can support shared goals.

What are standards and why do we need them?

Standards are key for the EU Single Market. When a DPP framework is in place, they will work together to support manufacturers in placing their products on the market.

Standards set out specifications and technical information about products, materials, services, and processes. They provide a basis for mutual understanding, facilitating communication, measurement, manufacturing, and commerce (within Europe and with the rest of the world), reducing market barriers.

They are voluntary but can point entire industries in a certain direction. This can lower costs, increase safety and performance, foster interoperability, improve energy efficiency, and protect consumers, workers, and the environment.

In the EU, despite being voluntary in nature, standards complement legislation. For manufacturers to comply with product requirements, they must know how – and that is where standards come in. Adherence to a standard can show that a product conforms with EU law.

Who develops European standards, and how could this change?

Currently, the European Commission works with private standardisation bodies to ensure that standards are delivered effectively and made available to manufacturers. The European Standardisation Regulation governs these public-private partnerships.

In Europe, standards are primarily developed by the appointed European Standardisation Organisations, CEN, CENELEC, and ETSI. They are sometimes also developed by international partners ISO and IEC and brought in as European through the application of the Vienna and Frankfurt agreements [6].

Industry drives the process of developing standards at CEN, CENELEC, and ETSI. Decision-making belongs to the National Standardisation Bodies (NSBs) and Committees.

The Standardisation Regulation also recognises environmental, consumer, trade union, and SME interests as essential to the European standardisation system, bringing a greater variety of interests and expertise into the otherwise industry-dominated process [7]. These organisations ensure EU values are well represented in standardisation, adding balance, democratic legitimacy, and accountability.

With the Standardisation Regulation being revised, the way these partnerships are managed – and who is involved – may change. There could be broad implications on how standards are developed.

What are the opportunities of these revisions?

The EU must set up the right horizontal frameworks and systems to support product legislation. The European Product Regulation (with the DPP) is one side of this coin, and the Standardisation Regulation is the other. Both must be improved in tandem for better legislation.

Opportunities of the European Product Regulation:

• Strengthening the DPP framework in Europe. By clarifying roles and links between different pieces of legislation, the European Product Regulation could ensure coherent DPP implementation, with environmental information an essential piece of the puzzle. This will be key for the success of the European DPP, making the case for it to be a model on the international stage.
• Facilitating product inspections for market surveillance authorities. By centralising data, DPP and any other related databases could help national market surveillance authorities to check the compliance of products. It would also contribute to optimisation of work if multiple investigations on the same products are being led by several authorities.
• Allowing online marketplaces to detect non-compliance of products through DPP. The rapid growth of e-commerce led to an increase of non-compliant products on the EU market. The European Product Regulation could make online marketplaces liable for the products sold on their platforms, with DPP used as the main tool to detect non-compliance.

Opportunities of the European Standardisation Regulation revision:

• Timely availability of standards. If legislation enters into force before complementary standards have been fully developed, the implementation of the law in question could be seriously delayed. The European Commission could ensure the market always gets standards in time.
• More inclusive standards. The European standardisation system currently recognises the importance of environmental, consumer, worker, and SME interests. This must continue, with support directed to ensure balance and expertise remain in the system – at European, international and national level.

What are the risks?

Lack of ambition and harmonisation between these two laws could result in a system that does not function effectively – one cannot work well without the other.

Risks linked to the European Product Regulation:

• Using digital tools as an excuse to reduce checks on actual products. While the DPP could reduce paperwork and simplify access to documentation, market surveillance and customs authorities must still have sufficient resources to verify products on the market directly.
• Overestimating the capacity of the market to quickly move from physical CE marking to DPP. One novelty of the European Product Regulation is to introduce digital CE marking, stored in the DPP. This may be done in addition to, or instead of, the physical CE marking on products. However, from broken QR codes to unavailable websites, moving product conformity marks online could reduce access if companies struggle to implement functioning DPP. The transition phase must not be rushed – and support will be needed.

Risks linked to the European Standardisation Regulation:

• A system without balance: Inclusiveness criteria are needed to ensure that underrepresented stakeholders can effectively participate in standardisation from the outset – with facilitated access and effective participation within the European standardisation system. The EU needs a balanced system with a sufficient breadth of expertise to develop standards that serve the public interest.

Quotes

Margaux Le Gallou, Senior Programme Manager at ECOS – Environmental Coalition on Standards, said:

Ambitious product legislation and standards that serve the environment are what will ultimately make Digital Product Passports worthwhile – and with DPPs on the way for more products, the risk of low ambition is a less competitive Single Market on a huge scale. But set the framework up right, and Europe will be ready for the future.

Amina Aissani, Senior Programme Manager at ECOS – Environmental Coalition on Standards, said:

Europe can be proud of its standardisation system, which serves both market needs and the public good. A successful revision of the Standardisation Regulation will come down to balance – between the needs of industry and society, speed and consensus, competitiveness and credibility. Balance is essential for strength – and Europe needs a strong standardisation system for a safe, competitive, and sustainable Single Market.

Notes to Editors

[1] ‘Everything you need to know about the Digital Product Passport’, ECOS paper (March 2026): https://ecostandard.org/publications/everything-you-need-to-know-about-the-digital-product-passport/

[2] ‘Building an EU Product Act fit for circular economy and digital transition’, ECOS paper (March 2026): https://ecostandard.org/publications/eu-product-act-circular-economy-digital-transition-standardisation/

[3] EU New Legislative Framework (NLF) (incl. Decision 768/2008/EC and Decision 765/2008/EC). See this ECOS position (August 2025) for more information: https://ecostandard.org/publications/new-legislative-framework-circular-economy-digital-transition/

[4] EU Market Surveillance Regulation (2019/1020). See this ECOS position (February 2026) for more information: https://ecostandard.org/publications/market-surveillance-and-compliance/

[5] EU Standardisation Regulation (1025/2012). See this ECOS position (July 2025) for more information: https://ecostandard.org/publications/evidence-european-standardisation-r1025/

[6] The European Standardisation Organisations are officially recognised by Regulation (EU) No 1025/2012 as providers of European standards. CEN (European Committee for Standardisation), CENELEC (European Committee for Electrotechnical Standardization), and ETSI (European Telecommunications Standards Institute) have been working with the European Commission in this capacity since 1984. International standardisers ISO (International Standardization Organization) and IEC (International Electrotechnical Commission) also contribute to European standardisation.

[7] The European Standardisation Regulation gives a formal role to organisations representing consumers (ANEC), the environment (ECOS), workers (ETUC), and small businesses (SBS). Known as ‘Annex III’, these organisations build a bridge from policymaking and big business to the everyday reality of citizens. They flag safety risks, highlight environmental impacts, and ensure standards align with Europe’s strategic goals. They provide knowledge and experience that gives balance, legitimacy, and real-life insight into standardisation, ensuring that European standards are fit for a future-proof Single Market.

Contact:

Alison Grace
Senior Press & Communications Manager
alison.grace@ecostandard.org
+32 493 19 22 59