How to Prepare for the DPP: A Step-by-Step Plan

The plan below is written for smaller companies without a dedicated compliance department. It assumes the status of 11 November 2026.

Before you start: decide how certain your deadline is

Your level of urgency depends on which regime your products fall under.

Your products	Status	What that means for planning
LMT batteries, industrial batteries above 2 kWh, electric vehicle batteries	Passport from 18 February 2027	Implementation project now
Detergents, toys	Passport from 23 September 2029 and 1 August 2030	Fixed dates, requirements known in outline; plan and budget
Iron and steel	Delegated act indicated for Q4 2026	Follow the draft closely; prepare data
Textiles, aluminium, tyres	Delegated acts indicated for 2027	Prepare data and identifiers
Furniture, mattresses	Indicated for 2028 and 2029	Basic preparation, monitoring
Other products	No passport schedule under the first working plan	Monitoring only

Use our DPP scope and timeline checker for a first orientation and the DPP timeline by product group for the detail. If batteries are your topic, go straight to the battery passport guide.

Step 1: Build a product inventory with a regulatory column

List your product lines. For each line record:

the product group in the regulatory sense, ideally with its customs code
the EU act that would create the passport
the status: in force, adopted or expected
the date, and whether it is fixed or indicative
the source and the day you checked it

The customs code matters because delegated acts usually define scope by code and definition, and because the registry stores the commodity code for imported goods.

Output: one table that tells you where a passport is coming and how firm the date is.

Step 2: Assign your role per product line

For each line, decide whether you are manufacturer, importer, distributor or dealer in the legal sense. Typical pitfalls:

Own-brand products made by a contract manufacturer make you the manufacturer.
Buying directly from a supplier outside the EU makes you the importer.
Selling through your own online shop makes you a dealer for those sales as well.

The role decides whether you must create the passport, verify it or only display it. Our article ESPR for SMEs lists the duties per role.

Output: a role next to every product line, and a list of lines where you are responsible for creating a passport.

Step 3: Fix your identifiers

Every passport hangs on a persistent unique product identifier. Check what you have:

Do all products have a globally unique identifier, such as a GTIN, or only internal article numbers?
Is the identifier stable over time, or reused when a product is discontinued?
Can your systems record batch or serial numbers if a legal act requires batch or item level?
Do you know the identifiers of your own company and sites that you use in trade and customs, such as your EORI number?

Do not invent a private numbering scheme for the passport. The ESPR requires identifiers that follow recognised standards, and a harmonised standard on unique identifiers, EN 18219, has been cited in the Official Journal.

Output: an identifier policy on one page: which identifier, at which level, issued by whom.

Step 4: Inventory your data against the known categories

You do not need the final field list to find your gaps. Use the categories that EU law already names:

product identification and classification
manufacturer, importer and responsible operator details
compliance documents: declaration of conformity, technical documentation, certificates
instructions, warnings and safety information
composition and substances of concern
performance and durability information
repair, maintenance and spare part information
end-of-life information: disassembly, recycling, disposal
environmental information where required, such as carbon footprint or recycled content

For each category note: do we have it, where is it stored, in which format, who owns it, and does it come from a supplier? The DPP data checklist builder produces this list per product group, and what data goes into a DPP explains the legal background.

Output: a gap list. Typical findings are data that exists only in PDFs, data that sits with one person, and data nobody has ever requested from suppliers.

Step 5: Talk to suppliers early

Much passport data originates upstream: material composition, origin, recycled content, test results. Collecting it is usually the slowest part of preparation, because it depends on other companies.

Tell key suppliers which data categories you expect to need.
Ask in which format they can deliver, and whether they already do so for other customers.
Add data delivery and update duties to new supply contracts.
For importers: make clear that you cannot place a product on the market without a passport once the obligation applies.

Avoid sending long questionnaires based on guesses about future fields. Ask for the categories that are certain and widen the request when the delegated act is published.

Output: a list of suppliers with a contact person for product data and a note on what they can deliver.

Step 6: Decide on the data carrier, but do not print yet

Plan where a data carrier can go on the product, its packaging or its documentation, and test whether a 2D code prints legibly on your materials. Decide which domain the link will use; it must remain under your control for as long as the passport has to stay available.

Hold back on permanent marking until the legal act for your group specifies carrier, placement and level. The exception is batteries, where the QR code requirement and date are fixed. Details are in QR code, NFC or RFID: DPP data carriers.

Output: a tested label position and a decision on the domain.

Step 7: Plan hosting, back-up and registration

Three system elements are set by law, whatever tools you use:

Storage. The passport data is stored by the responsible economic operator or by a DPP service provider it authorises.
Back-up. Under the ESPR, a back-up copy must be available through a DPP service provider, so that the passport survives if your company ceases to exist. The detailed rules for service providers are to come in a delegated act that the Commission indicates for 2027.
Registration. The passport must be registered in the EU DPP registry, which returns a registration identifier. Registration is possible through a user interface or an interface for systems, and the Commission offers a testing environment.

When you later compare options, the legal requirements give you criteria: open standards, interoperable formats, machine-readable data, no vendor lock-in, and the ability to transfer your data.

Output: a short requirements note for hosting, back-up and registration. No purchase decision is needed at this stage.

Step 8: Set up monitoring and ownership

Requirements will arrive in stages. Give one person the task of watching:

the Commission's Digital Product Passport page and its timeline
the "Have your say" portal for draft delegated acts on your product group
EUR-Lex for adopted acts and amendments
your national standards body for the harmonised standards

Record each check with its date. When a draft act for your group appears, review steps 3 to 7 against it.

Output: a named owner, a quarterly reminder and a change log.

Mistakes to avoid

Waiting for full certainty. Supplier data and identifier clean-up take time and do not depend on the final act.
Overbuilding. Designing a complete data model for fields that do not exist yet leads to rework.
Treating the passport as an IT project only. Roles, contracts and data ownership matter as much as systems.
Confusing indicative and fixed dates. Budgeting against a Commission quarter as if it were a legal deadline creates false urgency or false comfort.
Calling a voluntary product page an EU passport. A passport in the legal sense exists only where a legal act requires and defines it.

One-page checklist

Product inventory with legal act, status, date and source per line.
Legal role assigned for every product line.
Identifier policy written down; all products carry a unique, stable identifier.
Data inventory completed against the known categories; gaps listed.
Key suppliers informed; data clauses in new contracts.
Label position tested; link domain decided.
Requirements note for storage, back-up and registration.
Owner named; quarterly check of Commission page, draft acts and EUR-Lex.

Sources

This article is general information, not legal advice. Status checked on 11 November 2026.

FAQ

When should we start preparing for the Digital Product Passport?

Start now with the steps that do not depend on a delegated act: product inventory, roles, identifiers and a data inventory. Postpone irreversible decisions, such as permanent labels or rigid data models, until the act for your product group is published.

Do we need special software for the DPP?

Not to prepare. The first steps are organisational and about data quality. Which technical setup you need depends on requirements that, for most product groups, are not yet final. The law requires open standards and no vendor lock-in.

How long does preparation take?

There is no reliable general figure, and we do not want to invent one. It depends on the number of products, the depth of your supply chain and the state of your product data. Collecting supplier data is usually the slowest part.

What is the first concrete step?

A list of your products with, for each one, the EU act that would create the passport, its status and your legal role. Everything else builds on that list.