Digital Product Passport (DPP): what the ESPR regulation says
The Digital Product Passport is introduced by Regulation (EU) 2024/1781 on ecodesign for sustainable products, known as the ESPR. It will make information on a product’s composition, repairability and end of life accessible through a data carrier attached to it.
The principle
The ESPR, in force since July 2024, replaces the former ecodesign directive and considerably widens its reach. It provides for a unique identifier, carried by a data carrier on the product, its packaging or its documentation, giving access to a structured data set.
The concrete requirements are not in the regulation itself: they will be set category by category, through delegated acts staggered over time. Textiles are regularly cited as one of the first categories targeted.
Food is out of scope
This is the point most often obscured in communication around the DPP: Article 1 of the ESPR expressly excludes food and feed from its scope.
A food brand will therefore not be subject to the Digital Product Passport under the ESPR for its foodstuffs. The DPP deadlines in circulation do not concern it directly.
The exclusion covers the foodstuff. Packaging falls under a separate body of rules on packaging and packaging waste, with its own information obligations.
What actually concerns food brands
For a food brand, the tangible deadlines lie elsewhere: the mandatory particulars of the EU Food Information Regulation, the dematerialisation opened to wine since December 2023, and the shift of checkouts to 2D codes described in 2D barcodes & Sunrise 2027.
The underlying logic is nonetheless the same as the DPP’s: a stable identifier on the product, structured and current data behind it. A brand that has done that work is ready, whichever obligation reaches it.