Regulation (EU) 2024/1781 on the ecodesign of sustainable products (ESDP), which entered into force on 18 July 2024, is a key legislative pillar of the European Green Deal.

1. Regulatory framework and strategic importance of the EMFF

This framework initiates a fundamental transformation from the traditional linear model to a modern circular economy. The Digital Product Passport (DPP) is not just a technological addition, but a fundamental pillar of this change, digitally connecting the physical product with data about its entire life cycle.

According to primary legislation (Source 08), there is a fundamental shift in the responsibility of economic operators. Responsibility no longer ends with the „placing on the market“, but extends to the entire life cycle of the product. This means that the manufacturer must guarantee the integrity and availability of data even when the product reaches the hands of a recycler 10 years later. This legislation turns data into an integral part of the product’s identity, without which legal access to the EU market will not be possible.

Key objectives of the DPP and their strategic impact on operations:

• Transparency and legal protection: Providing verified environmental data.
  • „"So What?": The DPP serves as a key compliance tool The Green Claims Directive. Businesses thus gain legal protection for their marketing claims and avoid the risks associated with "greenwashing" (Source 05).
• Traceability and risk management: Monitoring the origin of raw materials and components.
  • „"So What?": This requires in-depth supplier audits and the implementation of real-time data sharing systems, which reduces operational risks and ensures continuity in an increasingly stringent regulatory environment.
• Supporting circularity and new business models: Information on disassembly and repairability.
  • „"So What?": Manufacturers must integrate circular requirements already at the design stage, enabling the transition to „product as a service“ models and increasing the residual value of materials.

These requirements are subject to a strict timetable that defines the transition from theory to mandatory market practice.

2. Implementation timetable: From the ESRF 2024 to the 2030 Work Plan

A phased approach is critical for successful adaptation, allowing businesses to optimize data infrastructure investments and avoid regulatory shocks. Based on the „Regulatory Hours“ (Source 10) and the Work Plan 2025–2030 (Source 07), the following chronology is set:

Management must strictly distinguish between the general regulation (ESPR) and delegated acts. The delegated acts will specify the exact scope of data for each category. Monitoring their preparation is crucial for the timely setting of the technical architecture that must serve this data.

3. Technical anatomy and data architecture of DPP

DPP is not just a digital label; it is a complex ecosystem requiring a change in the enterprise IT architecture. The key technical bridge between the physical product and the digital world of Industry 4.0 is the concept of Asset Administration Shell (AAS), which is an integral part of the reference architecture (Source 10).

The DPP technical stack consists of the following layers:

1. Data Carrier: QR codes, RFID chips or digital watermarks ensuring physical access to the passport.
2. Identifier (Unique Product Identifier – UPI): Stable and globally unique code. IT architects must work with formats such as GTIN, URI, DID or UUID (Source 10).
3. Data layers and logic:
   • Redirection layer: Ensures correct redirection of data requests.
   • DPP Assembler: A key element that compiles necessary data from multiple internal enterprise systems (ERP, PLM, CRM) in real time (Source 10).
4. Repository system: The difference between federated repositories (managed by enterprises) and the EU central repository for metadata.
5. Semantic layer: Use of ontologies (e.g. JSON-LD) to ensure machine readability and interoperability.

When defining data points, managers must link the JRC methodology (Source 02) with the guidelines CEN/CENELEC (Source 04). These standards, developed based on the experience of the project CircThread, transform scientific assessments into practical technical requirements, thereby eliminating the risk of incompatibility of data systems.

4. Analysis of priority sectors and implementation challenges

The textile and battery industries serve as implementation „laboratories“. In the battery sector (Source 11), the main challenge is data security in the global supply chain. In textiles (Source 03), the complex question of granularity is being addressed – whether DPP will be mandatory at the level of model, batch or item level, which fundamentally affects the cost of marking (Source 10).

For small and medium-sized enterprises (SMEs), Source 12 identified as the main barrier „"regulatory overlaps"“ (overlap with other regulations). The strategic solution for SMEs is:

• Avoid "black-box" solutions and prefer open standards.
• Harmonize data fields already at the audit stage so that one data set serves multiple regulatory requirements.
• Proactively monitor the project CIRPASS-2, which is currently being implemented 13 pilot projects in key sectors and defines best-practices for practice (Source 10).

5. Strategic Action Plan for 2026 and beyond

The year 2026 is critical for internal process auditing. Investment in DPP must not be seen only as a compliance cost, but as a tool to reduce inefficiencies caused by inconsistencies between different legislations (Source 13), which ultimately saves operational costs in e-commerce (Source 05).

Checklist for 2026:

• Data Audit & Access Control:
  • Mapping existing life cycle data.
  • Critical: Defining access rights (public vs. restricted/role-based access) – who can see sensitive composition information (Source 10).
• Identification & Integration:
  • Selection of UPI (GTIN/DID) and AAS-compatible data carriers.
  • Preparation of DPP Assembler for connection to corporate systems.
• Interoperability:
  • Alignment with open CEN/CENELEC standards to ensure independence from software vendors.
• Monitoring:
  • Monitoring outputs from 13 CIRPASS-2 pilots for timely process adjustments.

Enterprise architecture transformation must be based on the principle of: „"Market access by design, not by patchwork."“ Only integrating DPP directly into the DNA of processes will ensure long-term competitiveness in the EU single market. JRi&CO2AI