The Digital Product Passport: What Manufacturers Should Prepare Before the First Delegated Acts

In our piece on ERP and MES in the furniture industry we wrote about how the EU deforestation regulation turns manufacturing into a data business: to sell, you have to prove where the raw material came from.

The Digital Product Passport is the same mechanism, only wider. The deforestation rules require you to know the origin. The passport requires that knowledge to be available to anyone who scans the product, ten years later.

What the passport is and where it comes from

The legal basis is the Ecodesign for Sustainable Products Regulation, (EU) 2024/1781. The Digital Product Passport is, in the European Commission's own definition, a digital container for products, components and materials, holding information on safety, origin, material composition, repairability, environmental performance and reuse or recycling.

Alongside ecodesign, passport obligations also arrive through the Batteries Regulation and the Packaging and Packaging Waste Regulation. Which means it can reach you through more than one law, depending on what you make.

The dates that are known, and why "2030" is the wrong answer

• Batteries: February 2027. The first mandatory application.
• DPP registry: 2026. The EU-level infrastructure.
• Iron and steel: delegated act at the end of 2026.
• Textiles, aluminium and tyres: 2027.
• Furniture: 2028.
• Mattresses and recycled content rules: 2029.

After a delegated act is adopted, economic operators get at least eighteen months of transition. For furniture that puts the real obligation in 2029 or 2030.

Which is why many manufacturers conclude they have time. The conclusion is wrong, and the reason is simple.

Why the preparation happens now and not in 2029

A product leaving the factory in 2029 is made from material bought earlier, to a specification defined earlier, on a machine set up earlier, from a batch that arrived from a supplier at some moment somebody has to have recorded.

If traceability does not exist at the moment of production, it cannot be reconstructed afterwards. No consultant and no platform can tell you which board batch went into a unit that shipped two years ago if it was not written down at the time.

That is the same rule that already applies to the deforestation regulation, and companies that took that one seriously are already halfway there.

What specifically has to exist in the system

Unique identification at whatever level the rules require - model, batch or individual item - and a data carrier on the product itself. In practice that carrier is a 2D code, which means this project overlaps with the move to 2D barcodes arriving by the end of 2027. Whoever runs the two separately runs them twice.

A bill of materials with actual materials, not planned ones. The gap between what the technical documentation says and what was actually built in is precisely what the passport is meant to show.

Inbound batch traceability: which supplier batch went into which production batch. This is the longest part of the work and the part least dependent on how the rules end up being written.

Supplier documents attached to the batch, not to the supplier. A certificate sitting in a folder named after a supplier proves nothing about a specific item.

Repairability data: spare part numbers, instructions, availability. This is the part manufacturers most often do not hold anywhere in structured form.

Versioning. Products change over the years. The passport has to know which version of the data belongs to which manufactured item, rather than showing the latest one.

The most common mistake: treating the passport as a marketing page

A passport looks like a web page, so it easily gets handed to marketing. That is an expensive mistake.

It is a document whose data has to be accurate, provable and open to inspection. If marketing populates it by copying from a PDF catalogue, the first serious verification request brings it down, and the liability stays with the manufacturer.

Passport data has to come from the systems where it is created: the ERP, production, goods receipt.

What to do in the next twelve months

1. Establish which product group you fall into and when your delegated act lands. Without that date all planning is guesswork.
2. Inventory the data you already hold and where it sits: how much is in the ERP, how much in spreadsheets, how much only in the heads of people on the floor.
3. Introduce inbound batch traceability. Start here, because it takes longest and depends least on the final wording of the rules.
4. Decide on the data carrier and align it with the 2D codes you are introducing by 2027 anyway.
5. Only then choose a passport platform. The platform is the last step, not the first, because without data it displays empty fields.

If you want this to be one project rather than three

APPARO builds ERP and MES systems for manufacturing, with a focus on traceability that survives verification: batch on receipt, the actual bill of materials, documents attached to batches, and identification on the product.

We start with an inventory of the data you already hold and a map of where it is created. That immediately shows how much work actually sits between you and a passport, and how much of it you have to do anyway because of 2D codes and the deforestation rules.

Write to office@apparo.rs or book an intro call at apparo.rs/en/start-project.