Digital Product Passport

Executive Summary

The global trade system is undergoing a radical transformation from the "al-yap-at" (take-make-waste) model, where resources are consumed quickly and waste management reaches crisis size, to the "circular economy" model, which is based on resource efficiency and reuse of materials. The epicenter of this transformation is the "Green Deal" strategy of the European Union (EU). The most powerful and binding implementation tool of this strategy is what makes all lifecycle data of products transparent, verifiable and accessible. Digital Product Passport (DPP) system.1

This report examines the conceptual framework of the DPP, its legal basis (especially ESPR and Battery Regulation), its technical infrastructure (CIRPASS, blockchain, W3C standards), sectoral application calendars, and its profound impact on the EU's commercial partners, such as Turkey. Analyses reveal that DPP is not simply a digital labeling application; rather, it is a revolutionary "data governance system" that redefines the way global supply chains govern, data sovereignty, and international competition rules.3

1. Introduction: The Intersection of Sustainability and Digitalization

Industrial manufacturing processes have been shaped by an understanding that ignores the life cycle of products after reaching the final consumer for over a century. However, the climate crisis, lack of raw materials, and increased awareness of consumers have proven the unsustainability of this model. The EU aims to achieve environmental sustainability goals by using the power of digital technologies, with a strategy it calls "Twin Transition".5

1.1. Information Asymmetry and the "Green Laundering" Problem

Under current market conditions, consumers and regulators have difficulty accessing reliable information about the environmental impact of products. Extensive research by the European Commission shows that over 50% of environmental claims in the EU market are ambiguous, misleading, or unfounded, while 40% are not based on any concrete evidence.1 This creates a problem known as "Greenwashing", which leads to unfair competition.

DPP is designed to eliminate this information pollution. The system creates a "digital twin" that records the entire process from the extraction of a product's raw material to its production, from its use to its recycling. In this way, sustainability claims are removed from marketing slogans, placing them on a data-based and auditable basis.1

1.2. Transition from Linear Economy to Circular Data Systems

The circular economy aims to eliminate the concept of waste. However, for a product to be repaired, reused (re-use) or recycled (recycle), the contents, dismantling instructions and chemical components of that product must be known. DPP makes this cycle possible by providing a continuous flow of data between stakeholders in the supply chain (producers, repairers, recyclers).5 For example, a recycling plant can determine the correct method of parsing the fiber mixture of the waste textile product at its disposal by reading it over DPP.

2. Legal Framework and Regulatory Ground

Digital Product Passport is not a singular law, but an ecosystem of complex regulations integrated into each other. The basis of this structure Eco-design Regulation for Sustainable Products (ESPR) When creating, sectoral details are determined by special regulations.

2.1. Eco-Design Regulation for Sustainable Products (ESPR)

Officially enacted on 18 July 2024 (EU) 2024/1781 The Regulation numbered has replaced the former Eco-design Directive (2009/125/EC) and radically expanded its scope.8 The previous directive focuses only on energy-consuming products, while ESPR covers almost all physical products driven into the EU market, excluding food, feed, and medicine.9

Key Objectives and Mechanisms of ESPR:

• Horizontal Eco-design Requirements: The regulation gives the authority to establish common sustainability rules (horizontal rules) for groups of products with similar characteristics. This speeds up the process of setting individual standards for each product.8
• Performance and Information Requirements: The durability, reliability, reusability, upgradeability and repairability of the products should be increased. In addition, the pursuit of "Suspenseful Substances" (Substances of Concern) in products has been made mandatory.8
• Prohibition of Disposal of Unsold Products: ESPR includes substances that prohibit the destruction of unsold stocks, especially in the textile and footwear sectors, and mandate the introduction of these products into the cyclic economy. Firms must report transparently the quantities and causes of the products they destroy.11

2.2. EU Battery Regulation: First Application and Pilot Sector

The first and most comprehensive example of DPP implementation, EU Battery Regulation (EU) 2023/1542 It is brought to life. The batteries were selected as the pilot sector due to their complex chemical structure, critical raw material content, and strategic role in electric vehicle (EV) conversion.13

• Mandatory Calendar: As of February 18, 2027, a Digital Battery Passport will be mandatory for all electric vehicle batteries, LMT (light transport vehicles) batteries and industrial batteries with a capacity of over 2 kWh.13
• Data Scope: The passport must include the battery's carbon footprint, recycled cobalt, lithium, nickel and lead ratios, battery durability data, and disassembly instructions.15

2.3. Other Sectoral Arrangements and Expansion Plan

The EU Commission plans to include about 30 product groups under DPP by 2030. Following batteries, priority sectors include:

• Textile and Fashion: Under ESPR, DPP delegation laws for textile products are expected to be completed by 2027 and full implementation is expected to begin during 2028-2030.17
• Construction Materials (CPR): The revised Construction Materials Regulation (CPR), which came into force on January 7, 2025, stipulates the establishment of the DPP system in the period 2026/2027.13
• Detergents and Chemicals: The Revised Detergents Regulation will introduce a DPP requirement 42 months after the date of entry into force.13

3. Technical Architecture of Digital Product Passport

DPP requires a massive digital infrastructure where data from billions of products will be processed. The success of this system is based on the principles of interoperability, security and scalability. Instead of a single central database, the EU has adopted a distributed (decentralized) and standards-based architecture.

3.1. Identifiers and Data Carriers

Each product must have a unique identity within the system.

• Unique Product Identifier (Unique Product Identifier – UID): It is the product's identification number. It must comply with ISO/IEC 15459 standards. GTIN (Global Trade Item Number) provided by GS1 is the most common standard in this field.5
• Data Carriers: It is the physical interface that allows consumers and stakeholders to access data. Usually a QR code, RFID tag, or NFC chip is used. QR codes are the most commonly preferred method due to cost effectiveness and easy scanning with smartphones.1

3.2. Decentralized Data Storage and Blockchain Technology

DPP data is not collected on a central server of the EU. Instead, the data is stored in the manufacturers', suppliers' or third-party service providers' own systems. When the user scans QR code, the system pulls and merges this scattered data instantaneously.20

• Data Sovereignty and Privacy: This architecture allows companies to protect their commercial secrets (e.g. sensitive formulas or supplier pricing). The principle of "Need-to-know" (needs to know) is applied; that is, a consumer can only see the instructions for chemical dismantling of an authorized recycler battery while seeing the manual.7
• Blokzinciri and Trust: Blockchain and Distributed Notebook Technology (DLT) are used to ensure the irrevocability (immutability) of data. Especially in luxury products and battery passports, these technologies are critical to prove that data is not manipulated retroactively.20

3.3. Data Standards and Protocols: CIRPASS and W3C

Funded by the EU Commission CIRPASS The consortium (Collaborative Initiative for a Standards-based Digital Product Passport) sets the technical standards of the DPP.

• Semantic Interoperability (Semantic Interoperability): A common language is required for different software (e.g. the ERP system of a Turkish textile manufacturer with a German recycling robot) to understand each other. For this purpose JSON-LD The format and web ontologies are used.23
• W3C Verifiable Identification Information (Verifiable Credentials): Product data is packaged as "verifiable credentials" in accordance with W3C standards. This allows the digital passport to be cryptographically signed against fraud.25

3.4. Data Granularity (Details Level)

DPP data can be kept at three different levels 27:

1. Model Level: General information applicable to all products with the same model number (e.g. washing instructions for a T-shirt).
2. Party (Batch) Level: Data from a specific production series (e.g. chemical analysis report of the dye used in that party).
3. Product (Item) Level: Data specific to each individual product. Batteries that require serial number-based tracking are mandatory for electronic devices and luxury products.

Table 1: Digital Product Passport Data Layers and Access Rights

4. Sectoral In-depth Analysis

The DPP application contains different dynamics and data requirements for each sector.

4.1. Battery Sector: Dynamic Data Management

Battery passport is the most complex example of DPP because it changes not only static data (production location, chemistry) but also during use. Dynamic Data It has to include.

• Health Status (State of Health – SoH): The remaining capacity and performance drop of the battery must be recorded continuously. This data determines whether the battery can be used in energy storage systems (second life) after exiting the vehicle.14
• Critical Raw Materials: With the amount of cobalt, lithium, nickel, and lead contained in the battery, it must be declared how much of these substances come from the recycled source. As of 2031, the use of recycled raw materials at certain rates will be mandatory.16

4.2. Textiles and Fashion: Supply Chain Confusion

The textile industry is one of the areas where DPP implementation will be the most challenging. This is because of the global, multilayered and fragmented structure of the supply chain. The cotton of a garment can come from one country, the thread from another country, the fabric and the sewing from different countries.

• Traceability (Traceability): Brands will need to map not only the first tier (Tier 1) suppliers, but the entire chain (Tier 2, Tier 3, Tier 4) that goes down to the raw material.28
• Data Set: Fiber composition, safety of chemicals used, microplastic release potential and social fitness (workers' rights) data will be included on the passport.17
• Early adopters: Brands such as "Nobody's Child" have voluntarily started DPP practice, aiming to provide full transparency in their products by 2025. These brands use DPP as a tool that creates customer loyalty, not just a legal obligation.29

4.3. Electronics: A Reparability-Focused Approach

To reduce electronic waste, DPP focuses on "repairability". Implemented in France since 2021 Repairability IndexIt forms the model of the DPP implementation across the EU.

• Scoring System: Products are rated from 1-10 according to criteria such as ease of dismantling, spare parts price and availability, access to technical documents.30
• Software Support: The duration of software update support for smartphones and tablets is also included in the score, combating planned obsolescence.32

5. Strategic Impacts on Turkey and Customs Union Countries

Turkey will be affected by DPP regulations as much as Union member states, even more because of structural deficiencies, due to its being within the Customs Union with the EU and making about 40% of its exports to the EU.

5.1. "Digital Visa" for Export

DPP is a de facto entry into the EU market for Turkish exporter "Digital Visa" It gains quality. It is no longer enough to produce only quality and cheap products; it is also imperative to produce and share the product's data. Products that have no data or do not comply with DPP standards will not pass EU customs or will be treated as illegal products in the domestic market.33

• Textile and Ready-to-wear: In textile, Turkey's locomotive sector, the SME-weighted production structure is at great risk. EU brands have begun to request detailed data from Turkish suppliers. Suppliers who cannot provide this data have a high risk of being pushed out of the system (supplier consolidation).35

5.2. Green Covenant Action Plan and Compliance

T.C. The "Green Covenant Action Plan", run by the Ministry of Commerce, has set compliance with the DPP as a strategic priority. The years 2024 and 2025 are the last window of opportunity for Turkish industry to build its digital infrastructure.

• Cost and Technology Load: Turkish companies are required to integrate ERP (Corporate Resource Planning) and PLM (Product Lifecycle Management) systems into the data formats (GS1, CIRPASS) specified by the EU. This will result in a serious investment cost, especially for SMEs with low levels of digitization.36

6. Implementation Challenges, Risks, and Geopolitical Dimension

While DPP's vision is impressive, the practice process in the field is full of technological, economic, and political barriers.

6.1. The Digital Cliff of SMEs

While DPP is a manageable process for large companies, it can be an existential threat to SMEs. The cost of data collection, verification, and digital passport creation processes can melt the margins of small manufacturers. This can lead to the market being consolidated and small players being destroyed.37

6.2. Intellectual Property (IP) Concerns

Companies are wary of disclosing their trade secrets (formulas, sub-supply networks, cost structures) on behalf of supply chain transparency. It is essential that the DPP architecture offers mechanisms that control very tightly who sees the data.21

6.3. U.S.-EU Trade Tension and the "Brussels Effect"

U.S. administration and technology giants interpret these strict digital and environmental regulations brought by the EU (DPP, DMA, DSA) as "technical trade barriers" and protectionist policies targeting American companies. The U.S. Trade Representative (USTR) can threaten retaliation against the EU, arguing that such practices harm free trade.40 This is DPP's biggest political obstacle towards becoming a global standard.

6.4. Data Reliability and Control

Entering billions of data points into the system poses the risk of "junk data" (garbage in, garbage out). How will the accuracy of the data declared by manufacturers (e.g., "this cotton is organic" or "this battery contains 20% recycled cobalt") be audited? ESPR gives member states strict market surveillance (market surveillance) and prescribes deterrent penalties for violations (banning from public tenders, turnover-based fines).10

7. Future Predictions and Conclusion

By 2030, DPP will be the main element that determines the value of products, not just a compliance requirement.

7.1. Strategic Advice for the Business World

1. Data Management Investment: Businesses should view data as being at least as valuable as physical raw material. PIM (Product Information Management) systems should be invested.
2. Supplier Cooperation: New contracts should be made with suppliers based on data sharing, not just price.
3. Early Adaptation Advantage: Firms involved in pilot projects before the requirement begins will have a competitive advantage when the process begins.

7.2. Transformation of the Consumer Experience

Scanning QR code for consumers will allow to see not only the price of the product, but the ethical and environmental cost. This transparency will change purchasing decisions and force brands to act more responsibly. In addition, the digital passport of the product will function as a "digital deed" that proves the value of the product in the second-hand market.43

As a result; The Digital Product Passport updates the operating system of the global economy. This update removes transparency from being a choice, making it the basic requirement for market access. For production bases such as Turkey, this process requires a challenging transformation, but offers a historic window of opportunity for value added and sustainable exports.

Table 2: DPP Application Calendar and Critical Thresholds

Table 3: Cost Pens for Creating a Digital Product Passport

Note: This report was prepared on the basis of current EU legislation and sector analysis. Because the legislation is in a dynamic structure, technical requirements can be updated as the delegation laws come out.

Quoted works

1. The Digital Product Passport: A new era of transparency in the EU – Zevero, accessed January 10, 2026, https://www.zevero.earth/blog/digital-product-passport-eu
2. Digital Product Passport: What's a DPP – One Click LCA, accessed January 10, 2026, https://oneclicklca.com/en-us/resources/articles/digital-product-passport-whats-a-dpp
3. Digital Product Passport (DPP) – KPMG International, accessed January 10, 2026, https://kpmg.com/dk/en/esg/digital-product-passport–dpp-.html
4. EU's Digital Product Passport: Advancing Transparency and Sustainability . data.europa.eu, accessed January 10, 2026, https://data.europa.eu/en/news-events/news/eus-digital-product-passport-advancing-transparency-and-sustainability
5. Digital product pastsports (DPP): what, how, and why? – Circularise, accessed January 10, 2026, https://www.circularise.com/blogs/digital-product-passports-dpp-what-how-and-why
6. Project information – EU Funding & Tenders Portal – European Union, accessed January 10, 2026, https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/opportunities/projects-details/43152860/101083432/DIGITAL
7. Digital Product Passports: A Blockchain-based Perspective, accessed January 10, 2026, https://blockchain-observatory.ec.europa.eu/document/download/b6e3c85c-43c1-405b-aba8-e49a71249ef7_en?filename=EUBOF_DPP_report.pdf
8. The Ecodesign for Sustainable Products Regulation (ESPR) Regulation: What companies need to know Fitreach, accessed January 10, 2026, https://www.fitreach.eu/article/ecodesign-sustainable-products-regulation-espr-regulation-what-companies-need-know
9. Ecodesign requirements for sustainable products EUR-Lex - European Union, accessed January 10, 2026, https://eur-lex.europa.eu/EN/legal-content/summary/ecodesign-requirements-for-sustainable-products.html
10. Understanding the New Ecodesign for Sustainable Products Regulation, accessed January 10, 2026, https://www.lw.com/en/insights/understanding-the-new-ecodesign-for-sustainable-products-regulation
11. A guide to the Ecodesign for Sustainable Products Regulation (ESPR) – Circularise, accessed January 10, 2026, https://www.circularise.com/blogs/a-guide-to-the-ecodesign-for-sustainable-products-regulation-espr
12. The ‘E’ of ESG: Sustainable products – new EU Ecodesign rules for unsold consumer products, Jonas Köster, Tobias Klatt, accessed January 10, 2026, https://sustainability.freshfields.com/post/102lqlo/the-e-of-esg-sustainable-products-new-eu-ecodesign-rules-for-unsold-consumer
13. Digital Product Passports (DPPs) required by EU legislation across sectors: ESPR, toys, detergents, batteries, and more – Circularise, accessed January 10, 2026, https://www.circularise.com/blogs/dpps-required-by-eu-legislation-across-sectors
14. Understanding the EU Battery Regulation » TÜV SÜD, accessed January 10, 2026, https://www.tuvsud.com/en-us/resource-centre/blogs/mobility-and-automotive/understanding-the-new-eu-battery-regulation
15. EU battery passport regulation requirements – Circularise, accessed January 10, 2026, https://www.circularise.com/blogs/eu-battery-passport-regulation-requirements
16. Battery Regulation EU: Learn about battery passesports – Circularise, accessed January 10, 2026, https://www.circularise.com/blogs/battery-regulation-eu-what-you-need-to-know-about-battery-passports
17. Digital Product Passport for Textiles: What Fashion Brands Need to Know About the DPP, accessed January 10, 2026, https://www.carbonfact.com/blog/policy/digital-product-passport-fashion
18. GS1 Standards enabling the EU digital product passport, accessed January 10, 2026, https://gs1.eu/wp-content/uploads/2024/12/GS1-Standards-Enabling-DPP.pdf
19. How to create a digital product passport for compliance, accessed January 10, 2026, https://digital-link.com/guides/how-to-create-a-digital-product-passport/
20. A Decentralized Blueprint for Digital Product Passports – Digimarc Corporation, accessed January 10, 2026, https://www.digimarc.com/blog/decentralized-blueprint-digital-product-passports
21. A Comprehensive Guide to Digital Product Passports (DPP) – Wiliot, accessed January 10, 2026, https://www.wiliot.com/a-comprehensive-guide-to-digital-product-passports
22. The Digital Product Passport: A New Era of Luxury Unveiled – Aura Blockchain Consortium, accessed January 10, 2026, https://auraconsortium.com/insight/the-digital-product-passport-a-new-era-of-luxury-unveiled
23. Digital Product Passport » UN Transparency Protocol - UNECE, accessed January 10, 2026, https://untp.unece.org/docs/specification/DigitalProductPassport/
24. How the UN/CEFACT Transparency Protocol Team Build and Deployed Digital Product Passport Vocabularies - With Automation, Governance, and Interoperability at Scale - Alastair Parker, accessed January 10, 2026, https://jargon-sh.medium.com/how-the-un-cefact-transparency-protocol-team-built-and-deployed-digital-product-passport-3fa7492b9a7e
25. Digital Product Passport » UN Transparency Protocol - GitHub Pages, accessed January 10, 2026, https://uncefact.github.io/spec-untp/docs/specification/DigitalProductPassport/
26. Implementing Digital Product Passports using decentralized identity standards by Dr. Susanne Guth-Orlowski . Spherity . Medium, accessed January 10, 2026, https://medium.com/spherity/implementing-digital-product-passports-using-decentralized-identity-standards-f1102c452020
27. Project results – Circuit2, accessed January 10, 2026, https://cirpass2.eu/project-results/
28. EU Digital Product Passport: What it means for the textile industry, accessed January 10, 2026, https://blog.worldfavor.com/eu-digital-product-passport-dpp-what-it-means-for-the-textile-industry
29. Digital Product Passports: A Revolution in Transparent Fashion by Ilenia Vidili » Medium, accessed January 10, 2026, https://medium.com/@ileniavidili/digital-product-passports-a-revolution-in-transparent-fashion-a1671131a662
30. Repairability Index Calculator – Verisav Tools, accessed January 10, 2026, https://tools.verisav.fr/tools/reparability-calculator
31. Understanding the repairability Index » Punctuate Design, accessed January 10, 2026, https://www.punctuatedesign.com/blog/understanding-repairability-index
32. Durability Index for washing machines and televisions in France – SGS, accessed January 10, 2026, https://www.sgs.com/en/news/2024/06/safeguards-8724-durability-index-for-washing-machines-and-televisions-in-france
33. Digital Product Passport (DPP): all you need to know – Slimstock, accessed January 10, 2026, https://www.slimstock.com/blog/digital-product-passport-dpp/
34. Turkey's New E-Commerce Product Safety Regulation: A Guide for International Manufacturers – TURKISH REACH, accessed January 10, 2026, https://www.turkreach.com.tr/post/turkey-s-new-e-commerce-product-safety-regulation-a-guide-for-international-manufacturers
35. DIGITAL PRODUCT PASSPORT (DPP) – TTGV, accessed January 10, 2026, https://ttgv.org.tr/media/2024/06/dpp-infografik-4-1-.pdf
36. Digital Product Passport (DUP), accessed January 10, 2026, https://www.adaso.org.tr/Content/Files/fileMenager/2023/12//PDF-%20SN.BEK%C4%B0R%20ASLANER-%20D%C4%B0J%C4%B0TAL%20%C3%9CR%C3%9CN%20PASAPORTU.pdf
37. Navigating the Challenges of the Digital Product Passport – Matrec, accessed January 10, 2026, https://www.matrec.com/en/news-free/navigating-the-challenges-of-the-digital-product-passport
38. Digital product passport: mandatory with potential for SMEs – Arvato Systems, accessed January 10, 2026, https://www.arvato-systems.com/blog/digital-product-passport-mandatory-with-potential-for-smes
39. Digital Product Passports: Enhancing Transparency & Circularity – Anthesis Group, accessed January 10, 2026, https://www.anthesisgroup.com/insights/digital-product-passports/
40. USTR Bares Its Claws on Euro Tech Rules – CEPA, accessed January 10, 2026, https://cepa.org/article/ustr-bares-its-claws-on-euro-tech-rules/
41. US trade office threetens EU with fines over digital rules – POLITICO Pro, accessed January 10, 2026, https://subscriber.politicopro.com/article/2025/12/us-trade-office-threatens-eu-with-fines-over-digital-rules-00692996
42. Companies Selling Consumer Products in the EU (Particularly Clothing, Apparel, and Footwear Companies) Beware: The New ESPR Rules on Unsold Consumer Products Have Now Entered into Force Crowell & Moring LLP, accessed January 10, 2026, https://www.crowell.com/en/insights/client-alerts/companies-selling-consumer-products-in-the-eu-particularly-clothing-apparel-and-footwear-companies-beware-the-new-espr-rules-on-unsold-consumer-products-have-now-entered-into-force
43. Digital product passport (dpp): from scan to story – how your customer experiences your brand digitally (part 3) – Decographics.com, accessed January 10, 2026, https://www.dekographics.com/blog/dpp-digital-experience/
44. Digital Product Passports: How Retailers Can Turn Compliance to Consumer-Focused Value, accessed January 10, 2026, https://www.mintel.com/insights/retail/digital-product-passports-how-retailers-can-turn-compliance-to-consumer-focused-value/