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What is the EU Digital Product Passport?

Published 12 June 2026 · 7 min read · by Nora Corrado, DPP Readiness Agency HCMC

Key takeaway: The Digital Product Passport is not a certification, a label, or an audit. It is a legally mandated digital identity file that must accompany every regulated product placed on the EU market. Without a valid, accessible DPP, a product cannot be sold in the EU — regardless of quality, pricing, or existing buyer relationships.

A New Legal Infrastructure for Product Data

On 18 July 2024, Regulation (EU) 2024/1781 — the Ecodesign for Sustainable Products Regulation (ESPR) — entered into force. This regulation mandates the Digital Product Passport (DPP) for all product categories covered by EU Delegated Acts. For the furniture sector, enforcement is projected for 2028–2029, following the adoption of a sector-specific Delegated Act expected in 2027.

The DPP is not a certificate of compliance, a sustainability label, or a voluntary standard. It is a mandatory digital record — a structured data file attached to every regulated product and accessible via a GS1 Digital Link QR code.

Six Mandatory Data Categories (Annex III)

01 — MATERIAL ORIGIN
Material origin & composition

Source country, timber species, FSC/PEFC certification chain. Covers all materials across supply chain tiers.

02 — CHEMICAL DATA
Chemical data & SVHC

SVHC declarations, REACH compliance (Reg. 1907/2006), Safety Data Sheets for all supply chain tiers. Self-declaration insufficient.

03 — CARBON FOOTPRINT
Carbon footprint (ISO 14044)

ISO 14044-compliant Life Cycle Assessment. Cradle-to-gate CO₂ per unit. Third-party certified — self-estimates not accepted.

04 — SUPPLY CHAIN
Supply chain traceability

Tier 1–3 supplier mapping, GS1 EPCIS 2.0 digital event records for each shipment. Persistent, auditable chain.

05 — REPAIRABILITY
Repairability & durability

Repairability indicators per product category. Availability of spare parts. Durability data where specified in Delegated Act.

06 — QR IDENTIFIER
GS1 Digital Link QR code

Persistent URL resolving to live DPP record. GS1 Digital Link Standard v1.3. Must remain active for full commercial lifecycle.

Who Must Comply — and When

SectorDelegated ActEnforcement
Batteries~2025February 2027
Textiles2025–20262027–2028
⚑ FURNITURE2027 (est.)2028–2029
Electronics2027–20282029–2030

Three Actors Have Immediate Access

When a DPP is active, three distinct actor groups can access it simultaneously:

ENFORCEMENT
EU Customs & Market Surveillance

Verify compliance at point of import. Non-compliant goods blocked.

COMMERCIAL
European Buyers & Retailers

Already embedding DPP requirements in RFQs and supplier contracts — active 2025–2026.

CONSUMER
End Consumers

Scan QR at point of purchase to verify origin, materials, end-of-life instructions.

Where Vietnam Stands Today

NDI pre-audit assessment data across the HCMC-Binh Duong-Dong Nai manufacturing cluster (2025–2026) shows a clear picture:

<10%

of export managers have substantive DPP knowledge

<2%

have initiated any form of compliance action

The window is open. It will not remain open indefinitely. Building DPP compliance from zero takes 18–24 months. Starting in 2026 is not early — it is on time.

Sources: Regulation (EU) 2024/1781 (ESPR), Art. 9, Annex III · EC ESPR Work Plan 2022–2024 · GS1 Digital Link Standard v1.3, 2024 · ISO/IEC 18004:2015 · GS1 EPCIS 2.0 · NDI Pre-Audit Assessment, HCMC-BD-DN cluster, 2025–2026

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