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DPP Compliance: The roadmap to ready

Digital Passport solutions that empower businesses to easily collect and validate sustainability data—ensuring Digital Product Passport DPP compliance and full supply chain traceability.

Digital Passport solutions that empower businesses to easily collect and validate sustainability data—ensuring Digital Product Passport DPP compliance and full supply chain traceability.

New policy programmes introduced by the European Union are redefining the way businesses achieve regulatory compliance. By introducing demands for data collection from the supply chain, and new digital methods to achieve compliance, these policies are pushing the consumer product industry towards the precipice of change.

The introduction of the EU’s Digital Product Passport (DPP) contributes to this by creating a digital framework for sharing key product information – enabling better supply chain traceability, informed consumer decision-making, and easier regulatory checks. For businesses, it means moving toward a streamlined reporting system that supports compliance and circular economy goals.

The DPP presents significant opportunities for businesses that act early and integrate Digital Passport solutions into their operations – allowing them to achieve a more resilient supply chain, greater transparency, optimised resource use and costs, improved consumer engagement, and potential incentives through eco-modulation.

 

How to prepare now for DPP compliance

Implementing Digital Passport solutions that pull data from the supply chain and the product itself for DPP compliance, whilst providing compliance across multiple regulations can deliver long-term compliance and measurable returns on investment.

Digital Passport solutions prioritiesThe main priority for businesses in scope is data collection, with 3 key areas that will set businesses on the path to preparation: 

  1. Supply chain traceability
  2. Chemical usage
  3. Product circularity

 

Taking a proactive approach with Digital Passport solutions that cover the items listed allows businesses to identify gaps, prioritise high-risk areas, and gradually build the information needed for full DPP compliance.

 

Introducing the Roadmap to Ready: Digital Passport solutions

With our deep expertise in sustainability, product testing, and regulatory compliance, Eurofins Sustainability Services supports businesses in collecting and validating sustainability data and supply chain traceability to help you start your journey towards DPP compliance.

 

Supply chain traceability

Although the European Commission stated the DPP is not a traceability tool, achieving compliance with the Ecodesign for Sustainable Products Regulation (ESPR) requirements will demand significant supply chain traceability. Supply chain mapping has emerged as an invaluable first step in this. The most effective model is a risk-mapped supply chain, which highlights environmental hotspots and identifies suppliers in regions of high regulatory risk. This level of supply chain traceability allows businesses to target improvements and lay a strong foundation for DPP compliance and broader regulatory readiness.

Supply Chain Traceability for DPP compliance

Our Risk-Mapped Supply Chain uses sophisticated supply chain traceability technology to highlight issues by geolocations, analyse region-specific sustainability risks, and incorporate satellite imagery to assess environmental concerns directly relevant to DPP compliance. These are then visually layered onto an identified supply chain, often in the form of heatmaps, highlighting areas of concern or confirming low-risk suppliers.

Accurate risk assessment depends not just on digital supply chain traceability tools, but on material and product-specific expertise. Our specialist knowledge can help to produce accurate insights and workable improvements for supply chain traceability.

 

Substances of concern

The ESPR and its upcoming delegated acts will require companies to disclose detailed information about substances of concern (SoCs) in products on their DPPs. The European Commission estimates around 6,000 substances fall under the SoC definition – a significant increase in the number of chemicals businesses must already report on.

When considering all the different versions or variants of these substances, this figure is closer to 35,000 – vastly increasing the number of chemicals a business in scope must test for.

Chemical testing for DPP compliance

In light of the impact this has on businesses, we have developed Chem-ST™ Chemical Smart Testing – a revolutionary chemical assessment programme that offers an innovative and flexible solution to complex regulatory challenges. Unlike conventional Restricted Substances List (RSL) testing, which focuses on specific chemicals, Chem-ST™ uses a matrix-independent, composite testing model which allows for:

  • A wider net to be cast
  • More data to be generated
  • More coverage across multiple RSL categories
  • Cleansing of the supply chain in advance of restrictions

Every Chem-ST™ test not only supports current compliance efforts but also lays the groundwork for proactive preparation for the ESPR and DPP.

 

Durability

Under the ESPR, the Commission places prominence on product circularity features such as durability and repairability. The official EU ESPR FAQ provides insights into compliance with durability measures, stating that requirements must be verifiable by market surveillance authorities.

Durability testing for DPP compliance

Our Durability testing and verification marks helps clients differentiate their products in the market via credible, independent third-party assessment. Our durability testing specifications allow us to assess products for their durability for categories in which extended life would deliver significant, positive impacts and allows businesses to identify where improvements need to be made before the DPP comes into force. There are two durable testing marks available – Durable SILVER and Durable GOLD which are awarded to products that achieve durability above the accepted published industry standards.

These add value by demonstrating elevated performance above normal industry standards, helping to support sustainability claims and appeal to consumers who prioritise eco-friendly practices.

 

Recognising opportunity with DPP compliance

Businesses that embrace the digital architecture behind the DPP can turn regulatory pressure into operational efficiency. Gathering comprehensive supply chain traceability and product data will result in data that can serve many needs, particularly regarding DPP compliance.

The key to having a DPP programme is ensuring the implementation of tools and processes that can be used to gain or support compliance with multiple regulations and requirements, underpinned by excellent regulatory knowledge, data validation and material and product expertise.

Digital Product solutions for DPP compliance

Eurofins Sustainability Services’ Roadmap to Ready provides Digital Passport solutions for DPP compliance, so you can achieve supply chain traceability, chemical compliance, and durability in your products.

If you are interested in learning more about how you can use Eurofins Sustainability Services’ Roadmap to Ready to make meaningful strides on your journey to DPP compliance, contact us! We will be your partner to innovate your sustainability testing with our Digital Passport solutions.

 

Digital Product solutions for DPP compliance

Digital Product Passport resources to assist with DPP compliance

Eurofins is passionate about providing you with accurate, up-to-date, and reliable information. Please see below for valuable resources on DPP compliance, Digital Passport solutions, and supply chain traceability.

  • White paper | DPP Compliance: The roadmap to ready. Download now!
  • Webinar On-demand | Digital Product Passport: The roadmap to ready. Watch now!
  • White paper | AGEC’s Product Sheet for Effective DPP Preparation. Download now!
  • White paper | The EU’s Digital Product Passport: Unlocking a circular future. Download now!
  • Article | Roadmap to Digital Product Passport (DPP) compliance. Read now!
  • Webinar On-demand: The EU’s Digital Product Passport. Watch now!
  • Article | The rising importance of supply chain due diligence. Read now!
  • Article | Preparing for the EU Digital Product Passport (DPP). Read now!
  • Article | Strengthen compliance with supply chain traceability. Read now!
  • Article | The role of durability testing in sustainable product development Read now!
  • Webinar On-demand | Introducing durability testing and verification marks. Watch now!

 

Frequently asked questions about DPP compliance

Will consumers be able to see the same DPP compliance information as authorities?

No, this is likely to be different information and presented differently to the consumer than it is to market authorities. This is where it is helpful to imagine the DPP for one product as a federated network of platforms, so consumers will see a different set of information to DPP compliance authorities. The EU commission are very conscious of protecting sensitive data on the DPP, and this is why this concept of a federated network of platforms is being explored.

Will there be a grace period for businesses, after the product-specific delegated acts are published?

Yes, there is usually a grace-period of 18 months after a regulation is published. 18 months can sound like a really long time, but I really wouldn’t rely on leaving the massive task of preparation until then. As said, it will take a long time to gather the data and information. And you need to consider production lead times in that as well. So the sooner you can start building an insight into your supply chain and the how your product is already performing, in regards to chemicals and durability, the better.

Will products from outside the EU need a product passport too?

Yes, products imported on the EU market will also have to be accompanied by a product passport.

Will online marketplaces from outside the EU need to put DPP's on products?

The company or person putting the product on the EU market will be the one responsible for making sure it has a digital product passport.

Will the EU provide any more guidance on the tech system behind a DPP?

The DPP’s tech setup will be based on harmonised standards being developed by the European Standardisation Organisations (CEN/CENELEC), expected by the end of 2025. After that, the European Commission will roll out a few delegated and implementing acts under the ESPR to lock in the details, using those standards—or common technical specs if needed.

Is the Commission going to make a template for the DPP for small businesses?

There’s no official template or tool planned right now. The EU have said that they will provide help in aspects of the ESPR for SME’s, but there aren’t a lot of details about this at the moment.

How does the durable mark work and how can I use this to showcase DPP compliance?

The durability mark is a verification mark that shows a commitment to sustainable products. Once the product specific delegated acts are published and the exact durability and testing requirements are known, we will align our testing specifications accordingly. At that point, the durability mark can then also be used to demonstrate DPP compliance. The mark is intended for customers to feature on product packaging/labelling, promotional materials, the DPP, etc.

Can Eurofins Sustainability Services support with durability testing for eco-modulation incentives?

For those who may not be familiar, eco-modulation is a key provision of the French AGEC law, designed to incentivise brands to adopt sustainable practices by offering financial rewards for products that meet specific eco-friendly criteria. ReFashion manages this scheme on behalf of the French government, and if your products meet certain durability requirements, you may be eligible for financial incentives. We provide durability testing aligned with Refashions, however, please note that this is a completely separate service from our durability verification, as it follows ReFashion’s specific requirements and reporting guidelines.

Our durability verification, on the other hand, will be aligned with DPP compliance and requirements once they are officially released, and also, to the EU-wide eco-modulation scheme that will be coming into effect in the future.

What traceability will be required on the first textiles DPP?

We cannot say for certain, but we strongly recommend collecting supply chain data now – the more you gather, the better prepared you will be – not only for DPP compliance, but for other emerging regulations mandating traceability too.

Does a substance count as a SoC if it meets just one of the four criteria, or does it need to meet more than one?

It only needs to meet one. According to the ESPR, if a substance fits any one of the four criteria (a, b, c, or d), it’s considered a substance of concern.

If a substance is already restricted by another legislation, will requirements under the ESPR replace those obligations?

No, SoC requirements set out in delegated acts under the ESPR won’t replace existing requirements, unless it is stated.

How will chemicals that hamper reuse or recycling be identified for DPP compliance?

This will be a consultation process and an impact assessment. These substances will be specific to each product group. The list of substances may also change over time, due to revisions of the delegated act, or if recycling technology evolves in ways that eliminate a chemical’s negative effect on recycling.

SoC's include many chemicals that are present in products we use every day. Will this mean that there is a ban on those chemicals and they can't be used anymore?

This doesn’t mean that there will be a ban. For the majority of substances, this will be information about those chemicals. For example, this could be their concentration or where they have been used in the product.

“Substances of concern” is mentioned in the CSRD too. Is this the same list of chemicals?

No. At the moment this is not harmonised- the Commission may explore assessing possible alignment in the future, but not in the immediate-term future.

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