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With the Ecodesign for Sustainable Products Regulation (ESPR) expected to become operational in 2027 and the European Commission due to propose Digital Product Passport (DPP) content for certain product groups, Daniel Sabin Diaz, global senior solutions consultant at Systech, outlines the…
With the Ecodesign for Sustainable Products Regulation (ESPR) expected to become operational in 2027 and the European Commission due to propose Digital Product Passport (DPP) content for certain product groups, Daniel Sabin Diaz, global senior solutions consultant at Systech, outlines how it will affect data carrier printing, data exchange and stakeholder responsibilities.
What a fascinating concept! This is not a passport for an individual person, it’s a passport for a product. The Ecodesign for Sustainable Products Regulation (ESPR) entered into force on July 18, 2024. This regulation serves as a key pillar of the Green Deal and supports Europe’s objective of becoming the first climate-neutral region by 2050.
The ESPR is expected to become operational starting in 2027, with different product classifications having varying priorities and deadlines. A recent study published by the European Commission highlights the analysis and priorities for specific product groups. Among these, textiles and footwear, with an estimated market size of €175 billion, have been identified as the first priority due to their significant environmental impact.
In the coming years, the European Commission will propose specific requirements, standards, and Digital Product Passport (DPP) content for these product groups through delegated acts, as outlined in the ESPR working plan. This new regulation is poised to affect nearly all industries, with the exception of food and pharmaceutical products, which are governed by their own regulatory frameworks. Some of these concepts are discussed in my book, Track and Trace for Supply Chain Visibility in Pharmaceuticals, Beverages, Foods, and Cosmetics. All packaging industry will be affected as data carrier printing, data exchange and responsibilities will change. While the regulation is still a work in progress and clear requirements have yet to be finalized, three critical elements will determine its success:
1. Data carrier and embedded information
2. Data exchange protocols and standards
3. Stakeholders and their responsibility
A detailed explanation will be shown below for these 3 elements:
1. Data Carrier: QR, Data Matrix, RAIN RFID, NFC?
The directions and recommendations from GS1 are to use Quick Response (QR) and Data Matrix codes. RAIN RFID and NFC will only be used as additional options if approved, due to the extra hardware, costs, and efforts required.

We took a look at the data carrier technologies that can be used to store the necessary data to tell the entire story of the product, including raw materials. It looks like QR will be the preferred option for most products.
There is another key element: what data will be on this data carrier. What is clear is that, in some cases, we must identify the product in a unique way. The following identifiers are required:
There will be options regarding the embedded data, depending on the kind of product, but a combination of SN and GTIN, as described above, is the only way to make any product unique. This is important for traceability, maintenance, and warranty returns. Adding batch numbers will provide additional benefits. This is what is required to make the product journey specific to the product.
Another important element will be the Global Location Number (GLN), which can be used by companies to identify their locations, giving them complete flexibility to identify any type or level of location required. A company’s GLN will demonstrate the ownership of the product through manufacturers, importers, distributors, repairers, recyclers, etc.
2. Data exchange:
Data Exchange is an element that is not easy to implement, yet it is always required to exchange information. When the user scans the product, different elements should be shown, such as: source, footprint, maintenance details, documentation, warranty, and instructions. These are all static elements that can be added to the passport details once the product is created. However, there are others, like ownership of the product, that will change once the product is sold.
For example, products are typically sold by the manufacturer to the distributor or importer within EU borders. This is a change in custody, meaning a new owner. If it is sold to a final customer, that could also be marked in the DPP. The physical product will change ownership, and that change should be reflected in the data when a customer scans the product’s QR code. This information should be shown in the public details shared. The owner’s traceability requirements are still in progress, and it is yet to be defined which group of products will be affected.
As I explain in my book, data exchange and integration is one of the more difficult topics nowadays due to the complexity, variety of systems, and different standards.
The manufacturers or economic operators are the main responsible parties for the DPP creation. Product identification characteristics will be added to the product, and the DPP itself will be created. It is important to note that, within a manufacturing environment, there are several challenges involved in integrating software through data exchange. Many types of software are involved in this area, and the integration and maintenance of these systems are critical to the success of DPP implementation.

3. Stakeholders:
The regulation will impact several stakeholders. Almost all businesses in Europe and all businesses outside Europe that want to export their products to Europe will be impacted. This list describes some of them and their responsibilities.
4. Advantages of DPP:
Sustainability: The information in the DPP will allow the EU to control resources utilized and emissions released during the manufacturing process, and it will provide full details of the environmental impact of the product.
Circularity: Full visibility of the raw materials and components used within a product, along with details of which parts of the product can be recycled and reused, will enable circularity.
Counterfeiting: The DPP will reduce the efforts of counterfeiters, as the product will have a digital twin.
Diversion: Criminals will face a difficult task entering products into Europe that are supposed to be sold in other regions, as they will need to have a DPP assigned.
Customer experience: Clients will gain information about the manufacturing process, resources, and raw materials. Additionally, brands can improve their relationship with clients to increase loyalty and retention.
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