How to Create a Digital Product Passport: A Guide for SMEs
Step-by-step guide to creating your first EU Digital Product Passport. Covers data gathering, QR codes, and compliance for small brands.
You sell products in the EU. You've heard about Digital Product Passports. You've seen the acronyms (ESPR, DPP, GS1). And you probably have one question: what do I actually need to do?
Most DPP guides are written for enterprise supply chain teams with dedicated compliance departments. This one isn't. This is for brands with 10 to 500 products, no sustainability consultant on staff, and a real need to comply without overcomplicating things.
5 steps
From zero to live passport
~15 min
Per product (with data ready)
Free
To start (3 passports on LabelEU)
What is a Digital Product Passport, briefly?
A DPP is a structured data record attached to a physical product via a QR code. Scan the code, see the product's materials, origin, environmental data, and compliance information on a hosted web page. It's required under the EU's Ecodesign for Sustainable Products Regulation (ESPR).
If you want the full background, read our plain-English DPP guide. This article skips the theory and focuses on execution.
Ecodesign for Sustainable Products Regulation
Regulation (EU) 2024/1781
Framework regulation requiring Digital Product Passports for products sold in the EU. Product-specific rules roll out via delegated acts starting 2027.
Step 1: figure out if and when you need one
DPPs don't apply to every product at once. The ESPR sets the framework, but actual requirements arrive through product-specific delegated acts. The first hard deadline is batteries in February 2027.
Check where your products fall:
| DPP deadline | Urgency | |
|---|---|---|
| Batteries | February 2027 (confirmed) | High - under 12 months |
| Textiles / apparel | ~2028 (delegated act expected 2027) | Medium - start preparing now |
| Furniture / mattresses | ~2028-2029 (expected) | Medium - monitor delegated acts |
| Electronics | ~2028-2029 (expected) | Medium - monitor delegated acts |
| Cosmetics | TBD | Low - no delegated act yet |
| Toys / packaging | 2030+ (expected) | Low - later wave |
Not sure about your category?
The European Commission published a 2025-2030 ESPR Working Plan listing priority product categories. Steel, aluminium, textiles, furniture, and tyres are in the first wave. If your product doesn't appear, you have more time, but the DPP requirement will eventually cover nearly all physical goods sold in the EU.Step 2: gather your product data
This is where most brands stall, and honestly, it's the hardest part. The passport is only as good as the data behind it. Here's what you'll need for each product:
Core data (required for all product categories)
- Product identity - name, model number, SKU, brand, manufacturer name and address
- Material composition - what it's made of, with percentages (e.g., "65% organic cotton, 30% recycled polyester, 5% elastane")
- Country of manufacture - where the product was assembled or produced
- Compliance declarations - CE marking, REACH status, relevant certifications
Environmental data (required where delegated acts specify)
- Carbon footprint - total CO2e per product or per functional unit
- Recycled content - percentage of recycled materials by weight
- Durability information - expected lifespan, warranty period
- End-of-life handling - recyclability, disposal instructions
Where does this data come from?
| Typical source | If you don't have it | |
|---|---|---|
| Material composition | Supplier spec sheets or lab tests | Request from manufacturer |
| Country of manufacture | Your supply chain records | Check purchase orders / invoices |
| Carbon footprint | LCA provider or supplier data | Start with estimates, refine later |
| Recycled content % | Supplier certificates (GRS, RCS) | Ask supplier for chain-of-custody docs |
| Certifications | Certification bodies | Check if product qualifies |
| Care / disposal instructions | Internal product team | Draft based on product specs |
You don't need everything on day one
Article 9 of the ESPR requires data to be "accurate, complete and up to date," but the specific required fields depend on your product category's delegated act. Start with what you have. A passport with 8 out of 12 fields filled is better than no passport at all. You can update the data without changing the QR code.Step 3: choose a DPP platform
You need software that does three things:
- Hosts passport pages - a web page for each product showing all the DPP data, accessible to anyone scanning the QR code
- Generates QR codes - following the GS1 Digital Link standard, which is the URL format the ESPR references for data carriers
- Lets you update data - without reprinting labels. The QR code URL stays the same; the data behind it updates instantly.
Enterprise DPP platforms (Circularise, Spherity, SAP) are designed for companies managing thousands of SKUs across complex supply chains. If you're a brand with 50 products, that's overbuilt.
We built LabelEU specifically for this gap. The guided form walks you through every required field for your product category, generates the QR code, and hosts the passport page. Three free passports, no credit card required.
Step 4: create your first passport
Pick one product. Ideally your best seller or the one you have the most complete data for. Then:
- Enter your product data into the DPP platform. The form should map to the required fields for your product category.
- Review the generated passport page. This is what consumers, retailers, and authorities will see when they scan the QR code. Check that the data is accurate and reads clearly.
- Download the QR code. You'll get a print-ready file that encodes the GS1 Digital Link URL pointing to your passport page.
- Test the scan. Open your phone camera, point it at the QR code, and verify the passport page loads correctly.
The whole process takes about 15 minutes per product when you have the data ready. Data gathering is the time-consuming part, not the passport creation itself.
Step 5: integrate into your product workflow
One passport is a proof of concept. Rolling it out across your catalog requires a workflow:
- Label printing - decide where the QR code goes. On the product itself? Packaging? A hang tag? The ESPR requires the data carrier to be "physically present" on the product, packaging, or accompanying documentation.
- Supplier data collection - create a standard template or questionnaire for suppliers. You'll need the same data fields for every product, so make it repeatable.
- Update cadence - set a schedule for reviewing and updating passport data. Material suppliers change. Certifications expire. The data must stay current.
The QR code must be scannable
The regulation requires that the data carrier (QR code) is physically present and functional. Test print quality at your actual label size. QR codes smaller than 15mm x 15mm may not scan reliably, especially on textured surfaces. Test with multiple phone models before committing to a label layout.What about the EU DPP Registry?
Article 13 of the ESPR requires the European Commission to set up a central DPP registry by July 19, 2026. The registry will store at minimum the unique product identifiers and commodity codes for products entering the EU market.
As the economic operator, you'll need to upload your product identifiers to this registry. The registry will return a unique registration identifier per product. The Commission launched a public consultation on the registry's technical design in April 2025, with technical preparation ongoing.
For now, focus on getting your passport data and QR codes in order. Registry integration is something DPP platforms (including LabelEU) will handle when the registry goes live.
Who is legally responsible?
This trips up a lot of smaller brands. Under the ESPR:
- If you manufacture a product and sell it under your name, you create the DPP.
- If you import products from outside the EU, you're responsible for ensuring a DPP exists before placing the product on the EU market.
- If you're a distributor or retailer, you don't create the DPP, but you must make it accessible to customers.
For many small brands, "manufacturer" is the relevant role. Even if you outsource production, if you sell the product under your brand name, you are the manufacturer under ESPR definitions. The DPP is your responsibility.
Common mistakes to avoid
- Waiting for the delegated act - by the time your product category's rules are finalized, you'll have months, not years. Start gathering data now. The core data fields (materials, origin, compliance) are predictable across categories.
- Treating the DPP as a one-time task - the regulation requires data to be "accurate, complete and up to date." A passport you created and never updated is a compliance risk.
- Ignoring the QR code placement - a QR code tucked inside a box that gets thrown away doesn't satisfy the "physically present" requirement. Think about where the code needs to be accessible throughout the product's life.
- Overengineering the data - you don't need a full lifecycle assessment for every SKU on day one. Start with what your product category requires and build from there.
A realistic note on data gaps
Almost every brand we work with has gaps when they first create a DPP. The most common: carbon footprint data (requires lifecycle assessment), recycled content percentages (requires supplier chain-of-custody certificates), and end-of-life handling instructions (requires recycling research for your specific materials). This is normal. The goal is progress, not perfection on day one.The bottom line
Creating a Digital Product Passport is not as complex as the regulation text makes it sound. The hard part is data gathering. The actual passport creation is a form you fill out, a page that gets hosted, and a QR code you print.
Start with one product. See what data you have and what's missing. That single exercise tells you more about your readiness than any compliance whitepaper.