The Digital Product Passport (DPP) is a central instrument of the European Ecodesign Regulation. It is intended to make information on a product’s sustainability, circularity and legal compliance accessible electronically to businesses, consumers and authorities. For materials such as steel and aluminum it is particularly relevant, because the Commission treats these products as a priority.
Legal basis: the ESPR
The legal basis is Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products (Ecodesign for Sustainable Products Regulation, ESPR). It has been in force since 18 July 2024 and replaces the Ecodesign Directive 2009/125/EC. Unlike the directive, it applies not only to energy-related products but to almost all physical goods on the EU market, with exceptions such as food, feed and medicinal products.
The ESPR defines the Digital Product Passport as a set of data specific to a product that includes the information specified in the applicable delegated act and is accessible electronically through a data carrier. A data carrier can be, for example, a barcode or a two-dimensional code. A unique product identifier links to the passport.
What information the passport contains
The specific data in the passport is defined by the Commission for each product group in a separate delegated act. According to the Commission, this can include:
- the product’s technical performance
- materials and their origins
- repair activities
- recycling capabilities
- lifecycle environmental impacts
The information requirements of the ESPR can also include information on a product’s carbon footprint or environmental footprint. In addition, the regulation provides for a Commission registry that stores at least the unique identifiers; the ESPR required it to be set up by 19 July 2026. The Commission launched the registry together with a testing environment on 20 July 2026. The details are laid down in Implementing Regulation (EU) 2026/1778 of 16 July 2026, in force since 6 August 2026. Companies only need to register once the acts for their product group apply; the Commission names 18 February 2027 for certain large batteries as the first deadline.
Timeline: what is officially set
The ESPR itself contains no single date from which the Digital Product Passport applies to all products. The obligation only arises with the product-specific delegated acts. According to Article 4 of the regulation, these apply no earlier than 18 months after their entry into force, or earlier in duly justified exceptional cases.
In its working plan 2025–2030 of 16 April 2025 (COM(2025) 187), the Commission lists iron and steel as well as aluminium as intermediate products. As the indicative year of adoption of the measures, it gives 2026 for iron and steel and 2027 for aluminium. These are planning dates for adoption, not the dates from which obligations apply.
Status iron and steel (10 October 2026): The Commission is preparing the delegated act for iron and steel. The feedback period for the initiative “Ecodesign requirements for iron and steel products” on the “Have your say” portal ran from 20 May to 12 August 2026 and is closed. The Commission now indicates the fourth quarter of 2026 as the indicative timeframe for adoption. No draft of the act has been published so far.
The year 2027 is often mentioned in connection with product passports. This date comes from a different regulation: under the Batteries Regulation (EU) 2023/1542, the battery passport applies from 18 February 2027 to certain batteries, including electric vehicle batteries and industrial batteries above 2 kWh.
Product carbon footprint (PCF)
The product carbon footprint (PCF) quantifies the greenhouse gas emissions of a product over its life cycle or a defined part of it. Requirements and guidelines for quantification are given in ISO 14067. For materials, the PCF depends on the production route, energy sources and input materials. It therefore has to be managed together with material, heat or batch and supplier if it is later to feed into component or product values.
Inspection documents according to EN 10204 and the 3.1 certificate
For metallic products, EN 10204 defines the types of inspection documents, often colloquially called material certificates:
| Type | Name | Content | Validated by |
|---|---|---|---|
| 2.1 | Declaration of compliance with the order | compliance with the order, without test results | manufacturer |
| 2.2 | Test report | compliance with results of non-specific inspection | manufacturer |
| 3.1 | Inspection certificate 3.1 | compliance with results of specific inspection | manufacturer’s authorized inspection representative, independent of manufacturing |
| 3.2 | Inspection certificate 3.2 | as 3.1 | additionally the purchaser’s authorized inspection representative or the inspector designated by official regulations |
The inspection certificate 3.1 therefore contains test results that belong to the delivered product. These values are an example of materials data that can be passed on digitally in the supply chain instead of being retyped from a PDF.
Older designations are still common in practice: today’s inspection certificate 3.1 replaces type 3.1.B of the previous edition (EN 10204:1991, German edition DIN EN 10204:1995-08). In addition, the test report 2.2 is not the same as an inspection certificate 3.1: it only contains results of non-specific inspection and is confirmed by the manufacturer without an independent inspection representative.
Standards for digital exchange
- VDA 231-301 defines a JSON schema for sampling and test information along the supply chain. It is published openly on GitHub and has a modular structure. Among other things, there are specific sub-schemas for inspection documents according to EN 10204, including the inspection certificate 3.1, and for substance declarations.
- DIN SPEC 9012 describes the exchange of conformity data in machine-readable form (electronic certificate of conformity).
Such standards do not create a DPP obligation, but they make available the data a product passport will need: composition, test results, substance data and origin.
What companies can prepare now
A product passport is only as good as the data behind it. Companies that already manage composition, inspection certificates, substance declarations and PCF in a structured way and with their origin will find it easier to meet future requirements. How this fits together is described in the article on materials data management and in the article on Enterprise Materials Integration.
Matplus supports this with Matplus EDA®, which addresses substance declarations, CO₂ reporting and the Digital Product Passport as application areas, with EDA DX for test certificates according to DIN SPEC 9012, and with import and export in VDA 231-301 format. Matplus presents data exchange with MatliX in the MatliX customer workshop.
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