DPP / ESPR: the digital product passport moves into execution mode

EU regulation 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR) was adopted in June 2024. It replaces the old Ecodesign directive (2009/125/EC) with extended scope and a central instrument: the Digital Product Passport (DPP), a digital passport attached to every physical product. For the French SME-mid-cap manufacturer, ESPR is not a 2030 topic: the first wave (batteries) is already active, and the textile wave arrives in early 2027.

The DPP, in practice

The DPP is a single digital sheet per product, accessible via QR code, NFC or any interoperable data carrier. It contains: material composition, raw-material origin, manufacturing steps, environmental performance (carbon, water, energy), repair/disassembly/recycling instructions, and end-of-life information. It follows the product from manufacturer to consumer, and remains accessible throughout the product's life (up to 20 years for some categories).

The regulation delegates precise specification to sectoral delegated acts. The schedule confirmed in April 2026: batteries (already in force via the Batteries regulation 2023/1542), textile and footwear (2027), consumer electronics (2027-2028), furniture (2028), detergent chemicals (2029).

Why industrial SMEs aren't ready

Downstream traceability is not upstream traceability

Most industrial SMEs have downstream traceability: starting from a finished batch, you can trace back to components. That is what food or automotive demand (product recall). The DPP demands the inverse: starting from an individual product and going down to its components, their origins, their environmental data sheets, their suppliers. This data structure does not exist in most industrial ERPs.

Tier 2 and tier 3 suppliers

To produce a DPP, the manufacturer must obtain information from suppliers (tier 1), but sometimes also from the suppliers of suppliers (tier 2, tier 3). For a shoemaker, this means tracing back to the leather origin — the farm. This information is not naturally available. Forward-looking manufacturers go through sectoral platforms (Higg Index for textile, Sustainable Apparel Coalition) to pool the collection effort.

The persistent unique identifier

The DPP attaches a persistent unique identifier to every individual product. Not a proprietary lot or serial number — a standard interoperable identifier, generally based on GS1 (DataMatrix or GS1 Digital Link). For a manufacturer producing 100,000 units per year, this means generating, attributing and managing 100,000 unique identifiers with their lifecycle, far beyond the traditional SKU.

Three levers used by sector leaders

The product identifier from design

Rather than generating the DPP at production output, leaders integrate the unique identifier into PLM (Product Lifecycle Management) from design. Every product variant (size, colour, finish) has its identifier planned. Manufacturing only has to assign the identifier to each unit, not create it.

The structured supplier API

Rather than asking each supplier to fill in an Excel sheet, advanced manufacturers have published a normalized supplier API (JSON Schema, GS1 Digital Link). Suppliers integrate once, feed data continuously, and receive faster payments if they complete the DPP data. This supplier logic is the heart of the 2027 topic.

The DPP as a commercial weapon

A rich DPP (precise LCA, recycled-material percentage, carbon by stage) becomes a strong commercial argument vis-à-vis large buyers (construction GCs, food retail, automotive) who must themselves report under CSRD. Manufacturers that produce a DPP more complete than the regulatory minimum win contracts — it is measurable.

The 2027-2030 scenario

For an SME-mid-cap manufacturer in textile, fashion, electronics, furniture or chemistry, the 2026 work is to: (1) map the products concerned and the SKUs to be DPP-equipped, (2) identify critical suppliers and structure data collection, (3) select or develop a tool to generate, publish, and version the DPP, (4) integrate the unique identifier into PLM and ERP, (5) test on a product family before generalization.

The estimated cost for a 50-150-person industrial SME is €80k-€250k over 18 months (ERP integration + supplier collection + DPP platform). It is significant, but it is also the condition for access to the European market post-2027.