Urgency for a digital product passport tool is part of the European Union’s schemes with a broad goal of vastly improving efficiency through sustainable practices in production and supply chains. Even if it is only a side effect, the global business environment frequently incentivizes wastefulness and in some cases, as with tariffs, has unintended and undesired, negative consequences. The digital product passport (DPP) requirement for products sold in the E.U. is designed to make a positive difference in the business of  inefficiency. This is why a product passport for every industry, and eventually every product, is part of the European Circular Economy Action Plan. Businesses will need to endure a period of adjustment and stay abreast of the regulations as they are being enforced in a phased schedule, including transitional phases. Many businesses will want assistance with compliance. At the very least all businesses selling in the European market need to be familiar with what the new laws mean for their business, especially as new requirements come online. This article should be helpful toward that end.

The Circular Economy Action Plan/CEAP is part of the ambitious new European Green Deal. The European Green Deal is the E.U.’s answer to the United States’ Inflation Reduction Act, another massive plan for stewarding more environmentally sustainable activity. This world changing project has 3 broad goals:

1. No net emissions of greenhouse gasses by 2050
2. Economic growth decoupled from resource use
3. No person and no place left behind

Although these goals seem broad, and some have called them too ambitious, there is a substantial budget that’s already been dedicated to the New Deal. Funding comes from about 600 billion Euros of investment from the NextGenerationEU recovery plan, a post-pandemic investment effort, and includes investment from the EU’s sizable 7 year budget. Important details that will affect how companies selling in the E.U. need to comply with related regulations are consistently being released, including the release of the first working plan for the Ecodesign for Sustainable Products Regulation released in mid-April, 2025.

The European Union has introduced all new frameworks to make sure that the Circular Economy Action Plan is successful. The transitional phase of the E.U.’s plan to reduce and eliminate carbon leakage, the Carbon Border Adjustment Mechanism (CBAM), already began in October of 2023. CBAM success will be measured by the price of carbon between domestic products and the price of imports being equalized. Equalization of carbon prices means that production and industry will be difficult to move outside of Europe toward other geographical and regulatory environments for the purpose of rent-seeking. Where this happens today, it is overwhelmingly to take advantage of carbon production and byproducts being cheaper outside of Europe. The term “carbon leakage” describes situations where this occurs. Managing and enforcing the reduction in carbon leakage will require tools, such as QR code labeling, that can associate unit level products with origin information.

For the transitional phase that began in October, 2023, the industries that rely on cement, iron and steel, aluminum, fertilizers, electricity, and hydrogen are obligated to report volumes of their imports and associated greenhouse gas emissions. No costs are imposed on businesses at this first stage of the CBAM. For the relevant industries, the first reporting will be due for submission on January 31, 2024 and must include data from the 4th quarter of 2023. The expectation is that additional industries will be added to the reporting scheme based on how reporting for this first cohort of industries goes. The CBAM will likely be implemented very quickly though. The Green New Deal target for net greenhouse gas emissions by 2030 is a reduction to 55% compared to 1990 levels. Perhaps the most important concept being applied for achieving this reduction is the Digital Passport, a key part of the Circular Economy Action Plan (CEAP), although it’s not completely clear on how product information compliance will be achieved, whether through the inclusion of mandatory product information with a product passport or whether through providing information using the ubiquitous Energy Labels. This will surely depend on the product type.

The Circular Economy Action Plan has the following goals:

Make sustainable products the norm in the E.U.

• Empower consumers and public buyers
• Focus on the sectors that use most resources and where the potential for circularity is high such as: electronics and ICT, batteries and vehicles, packaging, plastics, textiles, construction and buildings, food, water and nutrients
• Ensure less waste
• Make circularity work for people, regions and cities
• Lead global efforts on circular economy

To confirm progress toward these goals, the European Union will use the Digital Product Passport. The Digital Product Passport is a way to associate broader product information and make it relevant and accessible at the unit level. The first industry to require a Digital Product Passport are batteries. According to Regulation (EU) 2023/1542 of the European Parliament and of the Council (esp. Item 44 of the introduction), the Digital Product Passport is meant to satisfy the following requirements:

1. The product should be labeled to provide reliable and clear information including waste related details.
2. Details about discarding the product, including waste operators that can appropriately treat waste batteries should be provided.
3. The product should be labeled with its main characteristics, including the presence of hazardous substances.
4. The advised  information should be made available by means of QR codes that can be printed or engraved on the product or to the packaging and accompanying documents, with respect to ISO/IEC guidelines for standard 18004:2015.

The release of exact requirements will be staggered according to the priority of industries. Despite what can be perceived as an uncomfortable delay, you can be confident that the requirements for one industry will be indicative of requirements for other industries. For example, the information requirements for batteries are indicative of what will be required for other products. Even with variations in the requirement related to product category, it’s clear that QR codes have been identified by the European Commission as totally acceptable choice for delivering required information to product end users. This has already been established with the use of QR codes to deliver energy label information on household appliances sold in the E.U. market.

The ecodesign for sustainable products framework sets design requirements to significantly improve their circularity, energy performance and sustainability aspects. It is designed to set performance and information requirements for all categories of physical goods sold in the EU market. Exceptions, such as food and feed, are defined in Regulation (EC) No. 178/2002. The framework also sets requirements for:

• Durability, reusability, upgradability and reparability
• Presence of substances that inhibit circularity
• Energy and resource efficiency
• Recycled content
• Remanufacturing and recycling
• Carbon and environmental footprints
• Information requirements, including the so-called Digital Product Passport

As with other parts of the E.U. Green New Deal, the “Digital Product Passport” is meant to provide and be a tool for monitoring the provision of critical, mandatory information about products sold in the E.U. The process of accessing the Digital Product Passport information is explicitly expressed described as “scanning a data carrier” that includes “attributes such as the durability and reparability, the recycled content or the availability of spare parts of a product.” The data carrier of choice for compliance is a QR code. Such data carriers are already being used in the compliance of E.U. requirements for wine labels, where nutrition and ingredient information is mandatory for wines produced after December 8, 2023.

The battery industry is among first with a product category that needs to provide product related information to consumers. Regulation (EU) 2023/1542 is effective beginning February 18, 2024 and includes the requirement for a carbon footprint declaration starting from the following dates:

1. February 18, 2025 for electric vehicle batteries
2. February 18, 2026 for rechargeable industrial batteries (except those with exclusively external storage)
3. August 18, 2028 for LMT batteries
4. August 18, 2030 for rechargeable industrial batteries with external storage

Because the battery industry is among the first industry to have these new information requirements, all other industries can benefit by observing these requirements to get an idea for how their industry will be expected to comply with regulations. One of the most interesting among the requirements is easily a carbon footprint declaration.

The carbon footprint declaration for electric vehicle batteries, rechargeable industrial batteries with a capacity greater than 2 kWh, and LMT batteries will require the following information:

1. administrative information about the manufacturer;
2. information about the battery model;
3. information about the geographic location of the battery manufacturing plant;
4. the carbon footprint of the battery, calculated as kg of carbon dioxide equivalent per one kWh of the total energy provided by the battery over its expected service life;
5. the carbon footprint of the battery differentiated according to life cycle stage as described in point 4 of Annex II;
6. the identification number of the EU declaration of conformity of the battery;
7. a web link giving access to a public version of the study supporting the carbon footprint values referred to in points (D) and (E).

The Waste Framework Directive (WFD) lays down some basic waste management principles requiring that waste be managed in an environmentally empathetic way. The WFD states that waste must be managed as follows.

• without endangering human health and harming the environment
• without risk to water, air, soil, plants or animals
• without causing a nuisance through noise or odours
• and without adversely affecting the countryside or places of special interest

The 2023 Amendment to the Waste Framework Directive proposes a focus on textiles waste. For textile companies, that suggestion of urgency is now being re-emphasized. As of late April, 2025, E.U. legislators were still reviewing the Textile Labelling Regulation but the first working plan for the Ecodesign for Sustainable Products Regulation has been released. The working plan was originally meant to include:

• iron and steel
• aluminum
• textiles (namely garments and footwear)
• furniture (including mattresses)
• tyres
• detergents
• paints
• lubricants
• chemicals
• energy-related products
• Information and communication technologies and other electronics

This list has been updated with the the release of the Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 in mid-April 2025. The most notable change is that the first working plan includes the following. We’ve also listed timelines for adoption:

• four final products: Textiles/Apparel (working in synergy with the Textile Labelling Regulation that is currently still under review), furniture, tyres (tires are already regulated by EU 2020/740 but the working plan aims to improve recyclability and end-of-life waste management), and mattresses.
  • Adoption for textiles is set for 2027.
  • Adoption for furniture is set for 2028.
  • Adoption for tyres is set for 2027.
  • Adoption for mattresses is set for 2029.
• two intermediate products: Iron & Steel (1) and Aluminum (2). Adoption is set for
  • Adoption for Iron & Steel is set for 2026.
  • Adoption for aluminum is set for 2027.
• two legal acts setting horizontal requirements: The first is repairability, including scoring. This could include products such as consumer electronics and small household appliances. The second is for recycled content and recyclability of electrical and electronic equipment. This one should have the most impact on increasing circularity of critical raw materials used in products.
  • Adoption for repairability requirements is set for 2027.
  • Adoption for recycled content and recyclability of electrical and electronic equipment is set for 2029.

The release of this working plan does not mean that the ESPR will not include products out of these categories. It means that these are the priority industries that were chosen based on where researched showed the potential for gains toward sustainability in the E.U. and indeed globally were more evident. Textiles are estimated to constitute a 78 billion euro, out of 142 billion euros for all textiles and footwear, market size. It’s no wonder that this industry has the first and highest support priority in the ESPR working plan, followed by furniture, tyres, and mattresses. The adoption timelines for tyres, aluminum, and repairability requirements shouldn’t be sniffed at though: 2027 won’t be long in arriving, especially considering the preparations that companies will need to make for product compliance using labels and product passports.