EU Digital Product Passport Working Plan Published: What LCA Practitioners Need to Know

The European Commission has published the first Ecodesign for Sustainable Products Regulation (ESPR) Working Plan for 2025-2030, providing clarity on which products will require Digital Product Passports (DPPs) and establishing key implementation timelines that will reshape how Life Cycle Assessment data is collected, verified, and communicated.

Key Points

• First working plan adopted on April 16, 2025, outlining priority product categories

• Iron and steel products face earliest DPP requirements, with regulations expected in 2026

• Battery Passports mandatory for industrial and EV batteries from February 18, 2027

• European standards for DPP systems due by December 31, 2025

The DPP Framework

A Digital Product Passport is a structured collection of product-related, machine-readable data that stores relevant information about a product's sustainability, durability, and environmental aspects. Unlike traditional documentation, DPPs are designed for automated processing and integration with LCA tools and building information modeling (BIM) systems. Each DPP links to a physical product through a unique identifier accessed via QR codes, NFC chips, or RFID tags, enabling stakeholders from consumers to recyclers to access relevant sustainability data.

Implementation Timeline

The phased rollout begins with high-impact sectors before expanding to broader product categories:

• 2026: Iron and steel products face first DPP requirements, focusing on emissions, energy efficiency, and resilience metrics
• 2027: Battery Passports become mandatory for industrial and electric vehicle batteries (February 18). Textiles, footwear, and aluminum products follow later in the year
• 2027-2030: Remaining priority categories including furniture, tyres, chemicals, ICT products, and electronics progressively added

Connections to LCA Practice

The DPP framework will change how LCA data is used and shared. For practitioners, several implications emerge:

• Data requirements: LCA data will need to be structured for machine readability, compliant with formats like EN ISO 22057, ILCD+EPD, and openEPD. This requires consideration of data architecture from the outset of LCA projects
• Product carbon footprint integration: DPPs will include product carbon footprint (PCF) data alongside circularity metrics. The GHG Protocol Product Standard and ISO 14067 methodologies will underpin these disclosures
• Verification needs: Third-party verification of LCA data feeding into DPPs will become standard practice, increasing demand for critical review and verification services
• Supply chain data collection: Bill of Materials (BOM) integration and supplier data reconciliation become critical as DPPs require lifecycle-wide information

Standards Development

The CEN-CENELEC-ETSI Coordination Group on Smart Manufacturing and the proposed Joint Technical Committee on Digital Product Passport are working to deliver harmonized standards by the December 2025 deadline. A proposal for an international joint technical committee (ISO/IEC JTC Digital Product Passport) is also under evaluation, with comments requested by October 2025. These standards aim to prevent fragmented, incompatible DPP implementations across sectors and regions.

Public Consultation

The European Commission's public consultation on Digital Product Passports ran through July 1, 2025, gathering stakeholder input on key aspects including data storage, management by service providers, and access controls.

Preparing for Compliance

For LCA practitioners and their clients, preparation should begin now:

• Review data management systems for machine-readable output capabilities

• Ensure LCA methodologies align with PCR requirements likely to underpin DPP regulations

• Build relationships with verification bodies experienced in digital environmental declarations

• Monitor delegated acts for specific product categories relevant to your clients