ESPR and the DPP are changing the game

After a decade or so of stagnation, sustainability is evolving quickly, and has already moved on from mere reporting to be more about product-level data. This means material composition, durability, recyclability, repairability, and traceability are fast becoming market-access requirements.

And it is in this context that the Digital Product Passport (DPP) is set to become a core requirement for selling goods in Europe and beyond.

A DPP is a standardised way of making detailed data available to anyone who scans a code on the product. That includes consumers, regulators, retailers, and everyone else involved in the supply chain. It supports transparency, circularity, safety, and regulatory compliance across industries.

The QR code on your packaging becomes the entry point. When scanned, it reveals the DPP as a mobile-friendly landing page customised for the user’s language and location.

A DPP becomes a passport to trade

Around 40% of EU goods trade involves non-EU partners, roughly $1.2 Trillion. Around 1 in 5 goods imported into the EU comes from China. That context matters because the DPP system under the Ecodesign for Sustainable Products Regulation is no longer a single “2027 compliance deadline”. It is now a phased rollout starting in 2026, with batteries, textiles, and electronics, with other product groups to follow. Exporters selling into the EU will need to be ready well ahead of their product group’s rollout date.

And the stakes are real. Failure to comply risks blocked shipments, fines, and competitive disadvantage.

The official EU requirements are still being finalised. But the direction is clear, and waiting until the last minute will only create stress and technical debt. The companies preparing now will move fastest once the policies are implemented.

What does “ready” really mean?

While specifics vary by category and region, a solid DPP typically includes a core set of information to meet regulatory requirements and ensure transparency and compliance.

It starts with the product name and description, the foundation of the passport that outlines what the product is and its key characteristics, and also includes:

• Ingredients or materials, so consumers and regulators can see what a product is made of, whether it is food, cosmetics, or textiles.
• The country of origin, because visibility into where a product was produced or assembled supports traceability and consumer trust.
• Manufacturing and batch information, which supports quality assurance and enables targeted recalls if needed.
  Recycling or disposal instructions, which are essential for meeting environmental labelling laws and promoting responsible consumer behaviour through sustainable practices.
• Certifications and sustainability data, which can support brand values and customer expectations.
• Safety information and warnings, because any product that could present a risk must include relevant usage instructions or hazard symbols.

This is where many teams hit a wall.

The challenge we consistently see across retailers and brand owners is that product and materials data is fragmented, incomplete, and inconsistent across suppliers.

Robust material, lifecycle, and supply-chain data is becoming mandatory as part of product identity, but most organisations are still trying to assemble it in spreadsheets, across multiple systems, with no single source of truth.

This is also where packaging shifts from a background consideration to a critical gateway for compliance and data. Packaging is the carrier of the code, and the bridge between the physical product and its digital identity.

Where to start

At Phantm, we help teams consolidate product data once, use AI and machine learning to close data gaps, and reuse that data across ESPR, Digital Product Passports, CSRD, and EPR, without rebuilding datasets for every new regulation. Supporting the collection, validation, and consolidation of packaging data is exactly what we do.

Our technology is evolving by design, mirroring the rapidly changing global regulatory landscape. It helps businesses navigate what is ahead with confidence, while delivering value today.

If this is on your radar, reach out to one of our data packaging experts to see the platform in action.

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