My name is Amy O’Brien, I’m the sustainability intern this summer with the RAIN Alliance. As a student studying sustainability with policy, law, and social science, introducing the Digital Product Passport (DPP) as a regulatory tool is of great importance to me as I begin my career journey. I believe the DPP will have a strong input in achieving the 2030 goal of reducing carbon emissions by 55% as set out by the Green Deal, while also working towards achieving many of the Sustainable Development Goals (SDGs) for example, number 13, Climate Action and number 8, industry, innovation and infrastructure.

Through this internship and working on the various DPP-related projects within the RAIN Alliance, I have gained great insight and experience to help guide my career direction. One of these projects is the DPP FAQ, aiming to answer all the burning questions you may have about DPP, particularly concerning RAIN as a data carrier.

Having the opportunity to work with those in the areas of expertise that I aspire to be part of in the coming years has been invaluable to me, and I’m excited to share a snippet of what I have learned as part of these projects in this blog.

The European Union (EU) has introduced the DPP as a first-of-its-kind regulatory tool to create transparency and unlock circularity. The DPP is both a structured collection of product-related data and a digital system that serves three main functions:

  1. Collecting and recording product information across the product lifecycle
  2. Digitally storing this data
  3. Providing easy data access to relevant stakeholders, in particular consumers and public authorities.

The intended scope of the DPP is information related to sustainability, circularity, value retention for reuse, remanufacturing, and recycling.

As mentioned above, the DPP is a strong step that has been taken towards the 2030 goal of reducing carbon emissions by 55% as set out by the EU Green Deal. It is particularly effective as it covers products sold in the EU market, throughout their entire lifecycle, from manufacturing to disposal.

In the timeframe of DPP implementation, the Ecodesign for Sustainable Products Regulation (ESPR) was published in the Official Journal of the EU and entered into force in July 2024, with the aim to adopt the ESPR working plan in April 2025, delivery of DPP standards by CEN and CENELEC by December 2025; the delegated act for textiles, including DPP rules, supplying broader eco-design requirements for each particular product group, to be published in January 2026; the delegated act for Iron and Steel DPP to be published in April 2026; from 2027, textile and steel & iron DPP will come into focus, in that order. It is important to note that this timeline is still indicative and is subject to changes based on the political decision-making dynamics.

The ESPR leads the charge as the main piece of legislation on DPP in the EU, outlining the general and technical requirements for its creation, access, and sharing. As set out under the ESPR, 80% of decisions on product design are to be taken during the creation of a product to minimise the environmental footprint throughout the product’s life cycle. Several other EU regulations and legislative proposals, such as the Batteries Regulation, Toy Safety Regulation, and Detergents Regulation, build on the concept of DPP and introduce this tool.

The CIRPASS consortium is a collaborative and objective industry forum, determining best practices and a standard-based DPP model aligned with the ESPR with a focus on the complete IT/Data structure.

If you are interested in learning more, this topic and much more is also discussed in the DPP FAQ.

The global impact of DPP and RAIN as a data-carrier

As mentioned above, this blog will go a bit more in-depth on the topic of DPP, covering its global impact and RAIN as a data carrier. I find it particularly important to discuss the global impact of a topic like DPP as, especially from my perspective as an intern still learning about DPP, it is easy to envisage it as a confined movement, exclusive to EU member states, when in fact, its impact is much greater than that.

DPP will have a global impact as requirements will apply to products imported into the EU, their components, and intermediary products in the same way the legislation applies to domestic products. Beyond this, EU legislation often inspires additional regulation globally, which is already evident in Japan, where policymakers are also looking at DPP as a regulatory tool, (more information is available on this topic at REITI, Circular Economy Initiatives in Japan) Today, RFID technology is widely adopted in various industries, in the supply chain and inventory management/retail. With the introduction of DPP, we can start using RFID technology as the solution for sustainability programs. In this way, RFID can be used to quantify carbon emissions to start driving significant environmental efficiencies.

Some important things to note are:

  • That data will be digitally connected through a data carrier to a unique product identifier
  • The data carrier will be physically present on the product
  • Certain topics are to be decided in future delegated acts such as data carriers and specific access rights
  • The information included in the DPP refers to the product model, batch, or item; Data will be stored in a decentralized manner; There will be an EU-operated centralized registry for DPP registration.
  • All information included will be based on open standards and will be developed with an interoperable format. (Responsibility to develop the EU technical standard has been given to CEN/CENELEC, (by December 2025))

There is no mandated data carrier for DPP expected at the ESPR level, but in future delegated acts, the data carriers will most likely be mandated for each product group. We believe that currently RAIN is under-represented as the data carrier of choice. As an industry, we need to add RAIN as an alternative DPP data carrier and influence European legislation through CIRPASS, Eco Design Forum, and CEN JTC24.

We need to develop technologies that:

  • Are economical and sustainable
  • Survive the lifecycle of items
  • Are compatible with industrial-scale manufacturing
  • Are not considered e-waste and can be embedded into products
  • Ultimately aim to bring RAIN to consumer smart devices.

If you’re interested in learning more, check out the DPP FAQ, which discusses these topics and much more. It aims to shed light on any questions you may have surrounding DPP and RAIN as a data carrier in a clear, concise, and fact-based manner.