EDUCATION: What the Digital Product Passport means for your labelling process
If you manufacture physical products for the EU market, you've probably heard the phrase "Digital Product Passport" by now — usually attached to sustainability reporting, circular economy targets, or compliance deadlines.
What's less often discussed is what the Digital Product Passport (DPP) means for the people responsible for your product labelling.
So we’re going to address that gap in the discussion with a series of articles that start here: a plain-English look at what the DPP is, what it requires physically on your product, and why your labelling and inspection process is about to matter more than it ever has.
What is the DPP?
The Digital Product Passport is a digital record — of material composition, carbon footprint, certifications, repair and recycling information and more — tied to an individual product throughout its life. It's mandated under the EU's Ecodesign for Sustainable Products Regulation (ESPR), with the specific data requirements for each product category set out separately.
The rollout is phased:
Batteries lead the way, with mandatory battery passports from February 2027 under the EU Battery Regulation
Other product categories — textiles, furniture, electronics, tyres, construction products, and more — follow through 2027–2029 as the European Commission finalises category-specific requirements.
Two things about this are consistent across every product category:
Every passport is reached by scanning something on the product — a QR code, a DataMatrix, an RFID tag, or similar. There's no DPP without a physical, machine-readable link from the product to its record.
Responsibility for accuracy sits with whoever places the product on the EU market — not with a regulator, not with a software vendor, and not with whoever printed the label. If the code is wrong, unreadable, or points to the wrong record, that's a compliance problem.
Why is this so important for your labelling team?
It's tempting to treat the DPP as primarily a data and IT project, preparing your products thoroughly for indexing on the DPP Registry. And most of the conversations you’ll hear around DPP are focused there.
But none of it matters if the physical code printed on the product doesn't reliably connect to that data. A passport that exists perfectly in your database is invisible to a customer, a repairer, a recycler, or a customs official unless the code in front of them scans correctly.
That connection is made — and can be broken — at the point of print.
Here are a few ways it breaks that have nothing to do with the underlying data being wrong:
The code is encoded correctly but prints at low contrast or with poor edge definition, and so grades below a usable standard
The human-readable text next to the code doesn't match what's actually encoded, because of a print error or a last-minute data change
The same identifier gets printed twice — on two different units, at two different sites — because nothing is checking for duplicates outside a single local batch
The label degrades between the point of print and the point someone actually needs to scan it, months or years later
None of these are data problems. They're print and verification problems, and they're exactly the kind of thing Perceptor’s label inspection solutions are designed to catch before poorly labelled - and non-DPP compliant - products make it out into the supply chain.
What "good" looks like for DPP
The Perceptor team is helping label production teams get ready for the Digital Product Passport now - and what they are doing isn't fundamentally different from a label room built on generally good manufacturing discipline. The difference is that they are applying DPP discipline consistently to every code ahead of deadlines, and not just to a sample of them:
Every code is graded against a recognised standard at the point of print, not just scan-tested
The encoded data is checked against the source record, catching mismatches before they leave the line
Duplicate checking covers your whole operation, across multiple sites, not just the current print run
A record is kept of what was inspected, when, and by which station — so accuracy can be demonstrated later, not just assumed.
You don't need to wait
Even if your specific product category isn't yet named in a DPP delegated act, the underlying capability — reliable, inspected, verified, traceable labelling — isn't something you’ll be able to build overnight when the deadline arrives. It will be built through the label inspection and verification process you run today, but applied with the DPP's much lower tolerance for error in mind.
The manufacturers who find the DPP straightforward when it reaches their product category will be the ones who already treat every code and feature on every label as something that must be verified and never assumed to be correct.
Perceptor IoT provides secure, real-time label inspection and verification for manufacturers preparing for Digital Product Passport requirements. Get in touch with the Perceptor team if you'd like to talk through what that looks like for labelling in your production environments.