By 2030, every piece of packaging sold in Europe is expected to carry a digital identifier - this is not a distant vision, but regulatory reality. While many packaging leaders are focused on the PPWR deadline in August 2026, a second, far more technically demanding wave of requirements is building in the background: the Digital Product Passport (DPP).
What IT leaders, packaging engineers, and compliance managers need to understand now: the DPP is not a standalone IT project. It is built on the very same packaging data you need for PPWR - but it places significantly higher demands on data standards, interfaces, and infrastructure.
This article provides a technically grounded overview: what the DPP actually is, which data standards and interfaces matter, when it becomes mandatory for packaging - and why you should start preparing today.
What is the Digital Product Passport - and how does it differ from the DoC and technical documentation?
The Digital Product Passport (DPP) is a standardized digital data record that makes product-related sustainability and lifecycle information publicly accessible and machine-readable. It serves as a central information source about a product - from manufacturing and use all the way to reuse, recycling, or disposal - and acts as a digital "CV" for products.
Its legal basis is the Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781), which entered into force in July 2024. As part of the EU Green Deal, the ESPR was adopted to reduce the environmental impact of products across their entire lifecycle - and the DPP is one of its core instruments.
This often creates confusion for packaging stakeholders: How does the DPP relate to the PPWR Declaration of Conformity (DoC) and to technical documentation?
| Feature | Digital Product Passport (DPP) | PPWR Conformity Declaration (DoC) | Technical Documentation |
|---|---|---|---|
| Legal basis | ESPR (EU 2024/1781) | PPWR (EU 2025/40) | PPWR (EU 2025/40) |
| Main purpose | Product transparency & lifecycle information | PPWR conformity evidence | Technical evidence for audits |
| Accessibility | Public via QR-Code / API | Available on request for authorities | Internal / on request |
| Data content | Materials, CO₂, recyclability, reparability, origin | Recycling rate, recycled content, pollutants, void space | Test reports, supplier attestations, specifications |
| Effective from | From 2027 (batteries), packaging around 2030 | 12 August 2026 | 12 August 2026 |
| Data standard | GS1 Digital Link, EPCIS 2.0, JSON-LD | No EU mandatory standard (structured) | No EU mandatory standard |
| Overlap | Recycling & material data aligned with DoC | Data flows into DPP | Supports the DoC data |
The key point: all three instruments share the same underlying data - materials, recyclability, recycled content, and hazardous substances. If you are already building out your DoC data in a structured way, you are effectively laying the groundwork for your future DPP.
Which data standards apply - GS1, EPCIS, JSON-LD, and the EU data model
The EU has not created a proprietary DPP standard, but instead relies on established global norms. For packaging leaders and IT architects, three standards are particularly important:
GS1 Digital Link - the bridge between physical and digital
GS1 Digital Link connects a physical product via a web-based URI - encoded in a QR code - to its Digital Product Passport. It enables dynamic, updatable, and role-based access to DPP data across the entire product lifecycle.
Concretely: the QR code on the packaging does not contain the data itself, but a URL pointer. QR codes are the practical choice for several reasons: they can be generated at no cost, are universally readable by smartphones, are GS1-compatible, and are dynamic - the data behind them can be updated at any time.
Especially relevant for FMCG companies: the GTINs you already use for your products are the starting point. GS1 standards such as GTINs, Digital Link, and EPCIS ensure consistent product identification, traceability, and trustworthy data exchange across the value chain.
EPCIS 2.0 - the standard for traceability events
EPCIS is GS1's leading data exchange standard for transparency within organizations and across entire supply chains. It captures the "what, when, where, why, and how" of products and other assets.
EPCIS 2.0 provides standardized interfaces for event data across the supply chain. As an ISO standard, the current version 2.0 includes, among other things, a REST API for data exchange as well as support for sensor data and certification details.
For packaging stakeholders, this means in practice: whenever a packaging item is produced, shipped, or taken back, that event can be documented in a standardized way via EPCIS and linked to the DPP.
JSON-LD and the EU data model
All DPP data must be structured and machine-readable - typically in JSON-LD, aligned with Schema.org. The EU relies on GS1 Digital Link and EPCIS for supply chain events so that data remains interoperable across industries and borders.
The underlying Global Data Model (GDM) ensures that product attributes such as composition, origin, or sustainability information are consistently structured and machine-readable worldwide.
Which interfaces are needed? API, EDI, QR code
For FMCG companies with complex packaging portfolios, three interface layers are particularly relevant:
- QR code (GS1 Digital Link): Consumer and authority access, printed directly on the packaging. Scanning the code takes users to the DPP data.
- REST API: Machine-to-machine communication between internal systems (ERP, PIM, PLM) and DPP platforms as well as supplier systems.
- EPCIS repository: Standardized exchange of traceability events. GS1 EPCIS repositories enable supply chain partners to share track-and-trace data and link supply chain events to unique IDs.
For IT leaders, the crucial point is: your DPP infrastructure does not need to replace existing ERP and data management systems - it needs to connect to them. Globally standardized data structures form the foundation - including GS1 Digital Link for connecting physical products with digital information sources, and structured product data management in PIM, ERP, or PLM systems.
DPP roadmap 2026-2030: What is coming when - and when does packaging fall under the rules?
The ESPR work plan 2025-2030 was adopted on 16 April 2025 and defines which product groups will be covered by the ESPR and when. The key milestones:
- From 2026: Initial ESPR implementation begins; preparatory work for delegated acts is underway. Binding obligations only arise when product-specific acts enter into force.
- February 2027: Battery passports become mandatory for industrial and traction batteries above 2 kWh - the EU's first and trend-setting DPP. It documents the entire lifecycle of a battery, from raw material extraction to recycling.
- 2027-2028: Textiles, footwear, steel, and aluminium follow. Other product groups include energy-related products, iron and steel (with DPP requirements from late 2027/early 2028), tires, and aluminium.
- ~2030: By around 2030, the scope of the DPP is expected to be extended again through the PPWR, so that practically every piece of packaging sold in Europe must carry a digital identifier.
What applies specifically to packaging?
From 2030 onwards, manufacturers must ensure that packaging includes digital product information: recyclability, recycled content, and reusability. The PPWR explicitly links this requirement to QR code labelling obligations.
The PPWR timeline for digital labelling at a glance:
- From February 2027: EPR identification via digital labelling
- From August 2028: Harmonized sorting instructions
- From 2030: Full QR code labelling including sustainability data (recycled content, reuse standard, disposal)
For packaging stakeholders this means: the path to a full DPP runs through PPWR obligations - the underlying data is the same.
Why DPP preparation and PPWR compliance rely on the same data foundation
This is the most strategically important insight for FMCG companies: DPP and PPWR do not just overlap - from a data perspective, they are largely identical.
Compare the key data fields:
| PPWR requirement (from 2026) | DPP data field (from ~2030) | Identical? |
|---|---|---|
| Recyclability grade (A/B/C) | Recyclability under ESPR | ✅ Yes |
| Recycled content (%) | Recycled content & material origin | ✅ Yes |
| Material composition | Material declaration | ✅ Yes |
| Freedom from hazardous substances (PFAS, SVHC) | Substances of concern (REACH/ESPR) | ✅ Yes |
| EPR labelling | Product identification (GTIN/UID) | ✅ Yes |
| Supplier documentation | Traceability / origin | ✅ Yes |
The consequence: companies that are now structuring their packaging data for the PPWR Declaration of Conformity are already building the data foundation for their future DPP. This avoids having to launch a duplicate data project in 2028 or 2029.
The DPP thus evolves from a technical label into a legal instrument for verified sustainability - and at the same time fulfils the requirements of the Empowering Consumers Directive, which from September 2026 will ban vague green claims that are not backed by verifiable, structured data.
How Packa already supports DPP preparation today
The biggest practical hurdle on the path to the DPP is not technology - it is data. Typical FMCG portfolios have 30-70% missing or unstructured packaging data. Systematically closing this gap is the core preparation task.
Packa as a central packaging data platform is designed to address exactly this challenge:
- AI-powered specification digitization: Existing packaging data from Excel, ERP exports, PDFs, and CSV files is automatically captured, structured, and validated - without manual re-entry.
- Data gap analysis: Packa systematically identifies which DPP-relevant fields (material type, recycled content, recyclability grade, GTIN) are missing for each packaging item and initiates automated supplier requests.
- Central packaging data management: All specifications, supplier declarations, and compliance data are stored in a structured way on a single platform - exportable in standardized formats.
- PPWR compliance checks: Automated checks on recyclability, recycled content, and hazardous substances generate the data foundation that will also feed into the future DPP.
- Audit-ready documentation: All data is revision-safe, traceable, and exportable for authorities, retail partners, and future DPP platforms.
This means Packa covers exactly the preparatory steps that packaging stakeholders need to tackle now - before the DPP becomes mandatory.
5 steps to a DPP-ready packaging data foundation
Record all existing packaging specifications - from ERP exports, Excel spreadsheets, PDFs and supplier data. Systematically identify data gaps: experience shows that 30-70 % of the relevant packaging data are missing or unstructured in typical portfolios.
Check which of your existing packaging data (material type, recyclate content, recyclability level, absence of contaminants, GTIN) already cover DPP-relevant fields. Target gaps specifically through structured supplier communication.
Make sure your packaging has unique product identifications (GTIN). Prepare the technical infrastructure for GS1 Digital Link-enabled QR codes, through which the DPP will be retrievable later.
Define through which interfaces your packaging data will be machine-exchangeable in the future - whether via REST APIs, EPCIS repositories or EDI connections to trading partners and suppliers.
Use PPWR preparation as a starting point: the data basis for the DPP comprises recyclability grades, recyclate contents and material data you will need for the conformity declaration from August 2026.
Test your DPP readiness now
How well is your packaging data foundation set up for the Digital Product Passport today? With the following tool, you can check in just a few minutes which DPP-relevant data fields you already have - and where you still need to take action.
Conclusion: If you are PPWR-ready today, you will be DPP-ready tomorrow
The Digital Product Passport is no longer a vague regulatory intention - it is a concrete roadmap that begins with the battery passport in February 2027 and will fully cover packaging by 2030. For FMCG companies, the biggest opportunity lies in not treating PPWR preparation as a narrow compliance exercise, but as the strategic creation of a long-term packaging data infrastructure.
The technical standards are clear: GS1 Digital Link for data access via QR code, EPCIS 2.0 for supply chain data exchange, JSON-LD for machine-readable structuring. The interfaces are defined. What most companies are missing is the structured, complete packaging data itself.
Packaging leaders who build their data infrastructure now - structured, centralized, and validated by suppliers - will avoid duplicating their efforts. By 2030, they will already be DPP-ready.
You may also be interested in how PPWR DoC templates and Digital Product Passports will accelerate packaging compliance from 2026 and how PPWR compliance can be implemented without chaos.
Frequently asked questions
Is the Digital Product Passport mandatory for packaging starting from 2026?
No - the DPP is expected to be mandatory for packaging around 2030 once the corresponding delegated acts under the ESPR come into force. However, from 2026 there are already PPWR data requirements (recyclability, declaration of conformity), and from February 2027 the EPR labeling requirement with digital identifiers will take effect. Those who structure their packaging data now are also building the data base for the later DPP.
What is the difference between the DPP, the DoC, and the technical documentation?
The PPWR Conformity Declaration (DoC) is mandatory from August 2026 and internally confirms that a packaging meets the PPWR requirements. The technical documentation contains the verifiable evidence for that (supplier attestations, test reports, specifications). The Digital Product Passport (DPP) goes beyond this: it makes this and additional lifecycle information publicly and machine-readable - via standardized interfaces such as QR code, API and EPCIS.
Which data standards are relevant for the DPP?
The key standards are: GS1 Digital Link (connects physical products via QR code to digital data sources), EPCIS 2.0 (GS1 standard for the exchange of traceability events along the supply chain), GTIN/GLN (unique product identification), and JSON-LD (machine-readable data format). The EU aligns its DPP framework to these GS1 standards to ensure global interoperability.
How do existing PPWR data help with DPP preparation?
Very directly: recyclability grades (A/B/C), recycled content, material data and information on substances, which you collect for the PPWR conformity declaration, are exactly the data fields that the DPP will publish later. Those who currently collect and centralize their packaging data avoid later redundant data projects.
Does every individual packaging item need its own DPP?
It depends on the product-specific delegated acts that the EU Commission will publish progressively. In general: DPP data can be stored at the model-, batch-, or serial-number level. For FMCG companies with large portfolios (1,000+ items) a scalable data infrastructure is essential - manual one-off solutions are out.


