EU Digital Product Passport (DPP) 2026: a guide for distributors

The Ecodesign Regulation (EU) 2024/1781 introduces the Digital Product Passport (DPP) as a legal requirement for many categories of products sold in the EU. For distributors and importers, this represents a major administrative undertaking that needs to be planned for now.

What is the Digital Product Passport?

The DPP is a digital identifier (accessible via QR code, RFID or data matrix) that centralises all information relating to a product’s life cycle: materials used, carbon footprint, reparability, traceability, recycling instructions, declarations of conformity.

The EU’s objective is twofold: to enable consumers to make informed choices, and to facilitate sorting, repair and end-of-life recycling. To achieve this, companies must collect, structure and publish data that often did not exist in their systems.

Who is affected?

The DPP applies to products placed on the European market. The first categories covered are:

• Batteries(from 2027) — already covered by the Batteries Regulation 2023/1542
• Textiles(from 2026–2027) — clothing, textile household goods
• Electronics and ICT— smartphones, tablets, televisions, computers
• Furniture— products made from wood, steel and textiles
• Tyres, chemicals, paints(next wave)

As a distributor or importer placing these products on the EU market, you are directly covered — even if you are not a manufacturer.

What the DPP requires in practice

For each product concerned, you must be able to provide:

• Material composition (substances, percentages, origin)
• The life-cycle carbon footprint (LCCF)
• Repairability information (score, parts availability, warranty period)
• Certifications and declarations of conformity (CE, RoHS, REACH, etc.)
• Dismantling and recycling instructions
• Information on substances of very high concern (SVHC > 0.1%)

This data must be accessible via a unique digital identifier linked to the product, and stored in a register compliant with the requirements of the ESPR (Ecodesign for Sustainable Products Regulation).

The problem: this data comes from your suppliers

As a distributor, you do not manufacture the products — you resell them. The DPP data must therefore be passed on to you by your suppliers, then published under your responsibility on the EU market.

This involves:

1. Identifyingwhich products in your catalogue fall within the DPP scope
2. Requestingstructured data from your suppliers (composition, certifications, PCF, etc.)
3. Centralisingthis data in a system capable of storing it and versioning it by product reference
4. Publishingthe DPP with a digital identifier accessible on the product or its packaging
5. Keepingthis data up to date as products and regulations evolve

How a PIM prepares you for the DPP

A PIM is structurally the right tool for preparing the DPP. It already centralises product attributes, certifications and regulatory documents. For the DPP, you need to add:

• Specific DPP attributes (composition, PCF, repairability score, etc.)
• A workflow for collecting data from suppliers
• A completeness check prior to publication
• Integration with a certified DPP register (or export to that register)

ProductsManager integrates REACH, RoHS, CE and WEEE compliance modules, and is preparing native DPP support for the relevant categories. DPP fields are already available in theScale and Enterprise plans.

Key dates to note

The exact timelines depend on the delegated acts that the European Commission will publish category by category. But the direction is clear: it is better to start structuring your product data now than to have to rush to do it all at the last minute.

Where to start?

The first step is an audit of your catalogue: identify the relevant categories, assess the state of your current data, and list the missing data to request from your suppliers. This is exactly what the Compliance module in ProductsManager allows you to do.