From QR Code to Data Basis: What the Digital Product Passport Means for Packaging

The EU Ecodesign for Sustainable Products Regulation (ESPR) has been in force since 18 July 2024 and provides the framework for product group-specific requirements. Future legal acts are intended to define which information on durability, reparability, resource efficiency, recyclability, recycled content, substances of concern and information obligations must be made available electronically. The digital product passport is intended to make this possible. It is not a single PDF or a central database, but a structured, interoperable data foundation. Access is provided via a data carrier such as a QR code, watermark or comparable solution, depending on the requirements, on the product, the packaging or the accompanying documents. Which data must be included and who is allowed to view, amend or update information will be regulated for each product group.

“The digital product passport (DPP) goes far beyond previous product documentation,” explains David Villamil, Product Manager at automation specialist SEW-Eurodrive. While conventional documents such as data sheets or certificates are usually static and isolated, the DPP is based on structured, standardised and machine-readable data formats and defined terms, Villamil continues. “This allows the required information on product characteristics to be processed and shared more efficiently.”

According to David Villamil, another key difference lies in the life cycle approach. “Conventional documentation often only covers the placing-on-the-market phase. The DPP, by contrast, accompanies a product throughout its entire life cycle – from development and use through to recycling,” Villamil emphasises. In addition, the DPP can be updated continuously, “for example in the event of material changes or repairs carried out”. By contrast, conventional documents often become outdated quickly and no longer reflect the current status of the product.

PPWR, ESPR and the Digital Product Passport as a Package

One aspect is particularly important for the packaging industry: although the EU Packaging and Packaging Waste Regulation (PPWR), which will apply from 12 August 2026, does not initially introduce a general digital product passport for packaging, it does bring new requirements for packaging data, labelling and the digital provision of information. The Packaging Regulation covers packaging regardless of material or origin. It provides for harmonised labels, digital data carriers for certain information, requirements for reusable packaging and digital labelling for substances of concern.

Where the packaged product itself falls within the scope of a digital product passport, the European Commission’s plans provide for product and packaging information to be accessible via the same data carrier, while remaining distinguishable. Companies linked to priority ESPR product groups, such as steel and aluminium packaging and their supply chains, as well as paints, varnishes, printing inks and coatings, should coordinate data models and verification processes at an early stage. “Anyone who treats ESPR, the digital product passport, PPWR and labelling separately risks duplication of work, inconsistencies and retrofit costs,” emphasises Jenny Walther-Thoss of consultancy BP Consultants, for example.

Who Is Responsible for the Data?

With regard to the DPP, responsibility is organised in a decentralised manner but clearly assigned – according to the so-called owner principle. “This means that each actor is responsible for providing and ensuring the quality of its own data,” says Villamil.

Specifically, component suppliers are responsible for their material and component data. Packaging manufacturers and machinery manufacturers are responsible for their respective product data. Overall responsibility for the end product or machine lies with the machinery manufacturer.

“Platform operators, by contrast, primarily provide the technical infrastructure, ensuring that data can be efficiently collected, processed and made accessible, without being responsible for the content of the data,” Villamil explains.

Automation Supports Implementation

The product manager sees automation in particular as the key to implementing the DPP and the requirements of the PPWR in a scalable and audit-ready manner. “This includes, in particular, automatic data collection, for example via ME systems, as well as the integration of existing ERP and PLM systems,” says Villamil. Digital twins would also enable end-to-end traceability throughout the entire product life cycle. “In addition, standardised interfaces (APIs) ensure efficient and consistent data exchange between all parties involved,” he adds. “Automation technology and software help to avoid manual errors, improve data quality and increase process efficiency.”

For data to function effectively along the supply chain, Villamil identifies four key prerequisites. First, clear identifiers are needed so that each product can be assigned unambiguously, for example via identification links in accordance with IEC 61406. Second, standardised terms and data models are essential. Product characteristics must be based on clearly defined semantics, for example on international ISO or IEC standards and the IEC 61360 Common Data Dictionary. Third, interoperable systems are required that can communicate across company boundaries. A suitable set of rules for this is specified, among others, in the standards of CEN-CENELEC JTC 24. Fourth, clear data governance is needed. It must be clearly regulated who may create, amend and view data in order to ensure data quality, security and trust along the supply chain.

Villamil sees the most common mistake as companies beginning their preparations too late. Businesses should analyse at an early stage which data is already available, for example on materials, weight, recyclability or carbon footprint. It is equally important to involve suppliers in good time, because a large proportion of the relevant information is generated along the supply chain. Villamil also recommends continuously monitoring relevant DPP standards and delegated acts and, where possible, actively contributing to their development.