Manufacturer
PrimaryPrimary responsibility. Creates the DPP, ensures data accuracy, and registers it in the EU registry. Applies to brands manufacturing in the EU and brands commissioning production from contract manufacturers.

The DPP is the central instrument of the EU's new sustainability framework for products.
A digital product passport is a structured digital data record containing information about a product's composition, origin, environmental footprint, care instructions, and end-of-life options. The QR code or other data carrier on the product label is simply a link to this record. The actual data is stored in a digital system and accessible to different users based on their role, whether consumer, repairer, recycler, or market surveillance authority.
The European Union introduced the DPP as the core tool of the Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781), which entered into force on 18 July 2024. The regulation replaces the older Ecodesign Directive that focused primarily on energy-related products, and expands its scope to cover virtually all physical products placed on the EU market. The DPP connects the entire value chain and enables the sharing of verifiable data between manufacturers, distributors, consumers, and regulators.
Structured information across categories defined in Annex III of the ESPR. The exact scope for textiles will be specified in the delegated act, but the framework is clear today.
ESPR defines clear roles for each actor in the value chain. Understanding your role is the first step toward preparation.
Primary responsibility. Creates the DPP, ensures data accuracy, and registers it in the EU registry. Applies to brands manufacturing in the EU and brands commissioning production from contract manufacturers.
When the manufacturer is based outside the EU, the importer assumes manufacturer-equivalent obligations. Must verify the DPP exists and take responsibility for its accuracy and completeness.
E-shops, brick-and-mortar stores, and online marketplaces cannot sell products without a valid DPP. Must verify that required information and identifiers are present before making a product available on the market.
Acts on behalf of a non-EU manufacturer within the limits of a written mandate. Does not assume overall product compliance responsibility unless explicitly stated in the Regulation.
ESPR Article 2 introduces the role of "digital product passport service provider." Companies like cyrcID provide the technical infrastructure for creating, hosting, and managing DPPs. Data accuracy responsibility remains with the manufacturer.
A 30-minute working session with our methodology lead clarifies your obligations under the ESPR before you commit to anything.
If you sell textile products on the EU market, you are subject to this regulation. It does not matter whether you have 5 or 500 employees. ESPR applies to all entities placing products on the single market.
The Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781) entered into force on 18 July 2024 and sets the legal framework for mandatory DPPs.

Replaces the older Ecodesign Directive (2009/125/EC). Expanded scope from energy products to virtually all physical goods on the EU market.
The European Commission identified priority product groups for delegated acts, including iron and steel, textiles, tyres, aluminium, furniture, mattresses, and ICT products.
Mandatory launch of the centralised EU Digital Product Passport Registry. The Commission must ensure it is operational, storing unique identifiers and enabling customs verification.
Preparatory work ongoing. The first product category expected to receive a finalised delegated act under ESPR.
Expected delegated acts for textiles, tyres, and aluminium. Preparatory studies for textiles underway.
Eighteen months after publication of the delegated act. EPR eco-modulation of fees begins. Furniture delegated acts expected.
Delegated acts for mattresses and ICT products. Expansion to additional product categories under subsequent ESPR working plans.
The delegated acts for textiles have not yet been adopted. The exact scope of obligations will be specified in the textile-specific delegated act (expected ~2027). The timelines above are indicative and may shift.
ESPR sits alongside four other EU instruments. DPP is the shared data layer that connects them.
From 2028, producer responsibility fees will vary based on product sustainability. Companies with active circular flows (repairs, take-back, resale) pay less. DPP provides the data for calculating eco-modulated fees.
The due diligence directive requires tracking environmental and social impacts across the supply chain. DPP architecture supports the collection and verification of this data.
Every environmental claim on a product or in marketing must be backed by verifiable data. DPP provides a structured source of this data and protects companies from greenwashing accusations.
Information on substances of concern that the DPP must contain builds directly on existing obligations under the REACH regulation. DPP consolidates this into a single digital access point.
Three pillars form the technical backbone of the DPP system under ESPR.
A QR code, NFC chip, or RFID tag on the label links the physical product to its digital record. ESPR does not prescribe a specific technology but requires the carrier to provide a reliable and verifiable link to the DPP stored in the EU registry. Technical standards are being developed by CEN/CENELEC Joint Technical Committee 24 (JTC 24).
The European Commission must launch the centralised registry by July 2026. Manufacturers will be required to register each DPP, ensure a verifiable link between the registry entry and the data carrier on the product, and maintain data accuracy for the required retention period. The registry will be interoperable with the ESPR web portal (Article 14).
Different users see different data. Consumers get information about composition, origin, and care. Professional repairers and recyclers receive technical data needed for their work. Market surveillance authorities have access to all information required to verify regulatory compliance. Commercially sensitive data remains protected through differentiated access rights defined in product-specific delegated acts.
DPP is not just a compliance obligation. Companies that start earlier gain better data, stronger customer relationships, and new revenue streams.
Customers pay more for products with verifiable origin and environmental footprint. A QR code on the label becomes a sales argument because it provides facts instead of marketing claims.
After a sale, visibility disappears. DPP changes that. Every scan, claim, and circular flow generates data that helps you design better products, predict their lifespan, and optimise inventory.
Companies with active circular flows unlock new revenue streams. DPP tracks every product movement and provides the data that proves lower EPR fees from 2028.
Customers add the DPP to their digital wallet under your brand. No app development needed. Direct communication through push notifications for care reminders, new collections, or recycling instructions.
*Indicative figures based on early adopter data and industry research. Actual results vary by product category and market.
Three concrete consequences for products placed on the EU market without a registered, valid passport.
Products without a valid DPP cannot be legally sold on the EU market. Customs authorities may refuse imports, and market surveillance bodies can order product withdrawal from the market.
Each EU member state will set its own penalties, which must be effective, proportionate, and dissuasive. Companies risk fines and reputational damage in customer-facing channels.
Retailers and online marketplaces will require DPP as a condition for listing products. Companies without DPP lose access to major distribution channels and may be excluded from public procurement.
ESPR is not designed to punish small companies. The goal is to create a level playing field where quality manufacturers with transparent practices gain an advantage over companies relying on greenwashing. DPP also opens new business opportunities in second-hand, repair, and recycling.
A practical sequence brands are already running through with us. None of it requires a finalised delegated act.
Try the calculatorIdentify key suppliers and assess what data you already have available. Material composition, country of origin, and care symbols are likely in your ERP or PLM system already.
AuditPrepare processes for structured data collection from your suppliers. You will need this data for a complete DPP meeting the delegated act requirements.
DataTry creating a digital product passport for your best-selling products. On the cyrcID platform, it takes minutes. Three passes are free.
PilotUse the cyrcID calculator for an indicative environmental footprint assessment of your products based on the PEF/PEFCR methodology. Find out where you stand.
MeasureThe textile-specific delegated acts are expected around 2027. Monitor their preparation so you have time for adjustments. Subscribe to our newsletter for updates.
Monitor
Try the environmental footprint calculator for free. No registration, no commitments, results in three minutes.