DPP and packaging data: What you need to know

The Digital Product Passport (DPP) is set to become a key tool in the EU’s efforts to increase transparency, traceability and documentation across value chains. Packaging will not necessarily have its own Digital Product Passport. Nevertheless, packaging data may become relevant as the EU rolls out DPP requirements. There is therefore good reason to start focusing on packaging data now.

For many companies, the key realisation is that working with DPP is largely about working with data. And packaging plays a much greater role in this than many may realise.

Packaging data may become part of a product’s DPP

As the EU gradually introduces DPP requirements for different product groups under the Ecodesign for Sustainable Products Regulation (ESPR), the product passport must contain the information necessary to document the product’s sustainability, circularity and compliance.

This means that packaging data may become a relevant part of the product’s overall data set if the packaging has an impact on the product’s environmental and resource profile.

Companies should therefore already consider whether they can document:

• Material composition
• Use of recycled materials
• Recyclability
• Chemical content and any substances of concern
• Traceability in the supply chain

This is data that may be requested both in connection with DPP and as part of the documentation required under the Packaging and Packaging Waste Regulation (PPWR).

PPWR already sets requirements for digital packaging information

Although packaging will not necessarily have its own DPP, the PPWR includes its own requirements for digital access to packaging information.

From 12 August 2028, packaging must carry harmonised labelling and a digital data carrier, such as a QR code, providing access to relevant information about the packaging. This requirement follows from Article 12 of the PPWR.

This means that companies should already begin building up the data that will later need to be made available digitally.

Focus on data rather than technology

When DPP is discussed, the conversation often turns to QR codes, digital platforms and IT solutions. But for most companies, the biggest challenge is not the technology. It is the underlying data.

The key questions are therefore:

• Do we know exactly which materials our packaging consists of?
• Can we document this information for customers and authorities?
• Do we have access to data from our suppliers?
• Is the data structured and up to date?
• Are roles and responsibilities for documentation clearly assigned within the organisation?

For many companies, the answers to these questions will determine how well prepared they are for both DPP and PPWR.

Start with what you already need for PPWR

Much of the data work that companies are already undertaking as a result of the PPWR may also be relevant in a future DPP context.

Technical documentation, declarations of conformity, information on materials and recycled content, and supplier data are examples of information that companies will need to have in place anyway in order to document their packaging’s compliance with the PPWR.

The key message is therefore: Do not wait for the final DPP requirements before getting your packaging data in order.

Start working systematically now with the data your company has, where it comes from and how it is documented.

This will also provide a better foundation for meeting the digital information requirements under the PPWR and the DPP requirements that become relevant to the company’s products.