Imagine shopping online for a pair of jeans, scanning a Quick Response (QR) code, and instantly seeing an entire lifecycle profile: where the cotton was cultivated, how much water was used in its processing, whether pesticides were applied, the conditions of the garment workers, the carbon footprint of transport, and the certified businesses that will accept the jeans for repair or recycling. Satisfied with what you see, you click ‘buy’ for next-day delivery. This is not speculative fiction but the operational vision of how we will be using Digital Product Passports (DPP), a regulatory tool embedded in the European Union’s Circular Economy Action Plan and its flagship Ecodesign for Sustainable Products Regulation (ESPR) (EU) 2024/1781. Under the ESPR framework, products in certain sectors, such as textiles and electronics, will soon be prohibited from entering or circulating within the European Union (EU) market without a DPP.
The DPP is more than an enriched product label. It is a legally mandated, dynamic data record designed to follow a product across its entire life cycle, from raw material extraction to manufacturing, distribution, use, repair, and end-of-life management. In theory, this tool can accelerate a shift away from the linear “take–make–dispose” model by integrating environmental, social, and material data into decision-making at all levels. DPPs could be the key to the transition to a circular economy.
Regulatory and Technical Architecture
The ESPR empowers the European Commission to adopt delegated acts that will specify DPP requirements sector by sector, including the type of data, level of granularity, and means of digital access (QR codes, Radio-Frequency Identification (RFID) tags, blockchain integration). Sectors already under consideration include textiles, batteries, electronics, and construction materials. Providers such as Circularise, Everledger, and iPoint-systems are already piloting blockchain-based DPPs to enhance traceability while protecting sensitive information through selective disclosure.
The DPP sits at the intersection of environmental law, data protection law, intellectual property rights, and trade regulation and these legal regimes do not always neatly align. One big tension is between the need for transparency and the protection of sensitive commercial information. A repairer might need detailed data to fix a product, but a manufacturer might see that data as a trade secret. Similarly, full supply chain transparency may clash with General Data Protection Regulation (GDPR) (EU) 2016/679 privacy rules or even cybersecurity regulations.
There are also questions of data governance. Who owns the information in a DPP? Who decides who can access it and under what conditions? Will all consumers have full access, or will some information be limited to certain actors like recyclers, regulators, and repairers? These decisions will shape market competition, global trade, and even geopolitical relationships. The legal challenge lies in aligning this regulatory innovation with existing regimes:
- Data protection law (GDPR) (EU) 2016/679 when personal data (e.g., worker identity, small supplier contact details) is recorded.
- Trade Secrets Directive (Directive (EU) 2016/943 when disclosing material composition risks revealing competitive manufacturing methods.
- Cybersecurity law under the Network and Informative Systems 2 Directive (NIS2) (EU) 2022/2555 when DPP data systems form part of critical supply chain infrastructure.
- International trade law such as the World Trade Organisation’s Technical Barriers to Trade Agreement when non-EU exporters must comply with EU digital traceability standards.
Lifecycle Transparency and Environmental Justice
Applying a life-cycle assessment lens exposes both the strengths and potential weaknesses of the DPP. For example, a jeans DPP may accurately report cotton’s country of origin and the volume of water used in cultivation but will it capture upstream biodiversity loss from pesticide runoff or societal impacts for workers such as opportunities for access to education? Will it account for the carbon intensity of electricity used in weaving mills, particularly in countries with coal-heavy grids?
From an environmental justice perspective, the risk is that DPP-enabled transparency benefits affluent EU consumers while imposing disproportionate compliance burdens on producers in the Global South. Textile cooperatives in Bangladesh or small-scale electronics refurbishers in Ghana may lack the digital infrastructure to meet DPP standards, potentially excluding them from EU markets. Moreover, if repair and recycling facilities are concentrated in the Global North, the circular economy benefits may become more geographically uneven than within the current linear economy.
Accuracy and Accountability
A fundamental question is whether the DPP will measure what truly matters for sustainability. Data accuracy depends on robust verification mechanisms, independent audits, environmental performance certifications, and interoperable databases. Without these, there is a danger of ‘data-washing’: products may carry technically compliant DPPs that nevertheless omit socially or ecologically significant harms.
Furthermore, the DPP’s environmental performance claims must be contextualised: recycling potential is not the same as actual recycling rates. This gap mirrors existing shortcomings in extended producer responsibility schemes, where theoretical recyclability often masks low material recovery in practice.
Global Implications
As with the GDPR introduced above, the DPP could set a de facto global standard. Any manufacturer exporting to the EU will have to adapt, potentially harmonising product traceability protocols worldwide. However, divergences in data localisation laws (e.g., China’s Cybersecurity Law, Russia’s data residency rules) and differing environmental baselines (e.g., United States state-level vs. EU environmental metrics) could create compliance conflicts. There is also a risk that the EU’s digital traceability rules become a form of ‘green protectionism’, favouring well-resourced multinationals over smaller, decentralised suppliers.
Beyond Techno-Solutionism
While the DPP is a powerful governance tool, it is not a substitute for systemic change. Without parallel measures, consumption reduction targets, supply chain democratisation, and labour rights, including children’s rights, enforcement — it could devolve into a high-tech compliance ritual. Transparency is necessary but not sufficient: a perfectly documented unsustainable product remains unsustainable.
Designing for Equity and Efficacy
For the DPP to drive genuine ecological transition, its legal design must balance transparency with privacy, openness with trade secret protection, and environmental goals with social equity. Technical standards must be developed through participatory governance, ensuring inclusion of small-scale producers and repair networks. Verification systems must be independent and robust, embedding life-cycle thinking into every stage of data collection.
The DPP can be either a gateway to a just circular economy or a digital gatekeeper entrenching existing inequalities. Its trajectory will be determined less by the technology itself and more by the legal, institutional, and political choices made in its design and implementation.
This blog post is based on the paper to be presented at the SMART Network Symposium, Sustainability is (Still) Possible! Governing Market Actors for a Safe and Just Space, 18-19 September 2025, at the University of Turin
