Digital Product Passport for chemical products: deadlines, requirements and preparation

The European Union has adopted a new regulation that changes the rules of the game.

The Digital Product Passport (DPP) is becoming mandatory for all products on the EU market – including chemicals.

Many domestic companies are not aware of all the requirements and obligations related to the DPP. And the compliance deadline is 2028-2030.

In this article you will learn:

What the “Digital Product Passport” is and how it works
Specific deadlines for the chemical industry
Which data you already have (80% in the SDS!)
How to prepare in 5 steps

What is the Digital Product Passport?

The DPP is a set of structured digital data about a product – from composition and safety to environmental characteristics.

That data is accessed via a QR code (or an NFC tag) on the product label.

You scan the QR code → you get the data relevant to you:

If you are a consumer:

Basic safety information
Hazard pictograms
How to dispose of the product

If you are a B2B customer:

The complete SDS
REACH registration number
Transport documentation
Certificate of analysis

If you are a regulator:

The full compliance dossier
Change history (audit trail)
Supply chain transparency

The key point: One QR code, different content for different users.

This is possible through “resolver” logic – the system detects who is scanning and shows the appropriate data.

Why does the DPP matter? (And why now?)

The EU adopted the ESPR Regulation (EU 2024/1781) in July 2024.

The goal: a circular economy – products must be designed for:

Longer use (durability)
Easier repair (reparability)
Better recycling (recyclability)

The DPP is the tool for this – it provides transparency on materials, composition and carbon footprint.

Without a DPP = you will not be able to sell the product on the EU market. Simple as that.

Deadlines: when does the DPP become mandatory?

The ESPR is in force. Implementation is phased – different products get different deadlines.

Confirmed dates:

📅 February 2027 – DPP MANDATORY for batteries

EV batteries
Industrial batteries >2kWh
Light means of transport batteries

📅 2027-2028 – Priority products

Textiles
Detergents
Construction materials
Furniture and mattresses

Why are chemicals later?

The European Commission postponed chemicals because of:

Overlap with REACH/CLP (avoiding duplication)
Trade secrets (protecting competitive formulations)
A lack of sustainability standards

Projection for chemicals:

📅 End of 2025 – EU study (which chemicals come under the DPP)

📅 2027-2028 – Delegated acts for paints, lubricants, chemicals

📅 2029-2030 – Compliance deadline (12-18 months after the act)

This means: you have 24-36 months to prepare.

The question is not “whether” – but “how and when”.

You already HAVE 80% of the data (in the SDS!)

The good news: you already have most of the data for the DPP in the SDS.

What exists in the SDS:

✅ Product identification (Section 1)

✅ Hazard identification (Section 2)

✅ Composition/information on ingredients (Section 3)

✅ First aid measures (Section 4)

✅ Handling and storage (Section 7)

✅ Exposure controls/personal protection (Section 8)

✅ Ecotoxicological information (Section 12)

✅ Disposal (Section 13)

✅ Transport information (Section 14)

What is NEW for the DPP:

❌ Carbon footprint – kg CO₂ per kg of product

❌ Recycled content – % of recycled materials

❌ Water footprint – m³ of water per kg

❌ Packaging recyclability – whether it can be recycled

❌ Production location – where it is produced

❌ Batch traceability – from raw material to product

The gap = 20% – but it can be filled step by step.

Sources for this data:

Carbon footprint → LCA study or the TfS PCF guideline
Recycled content → Supplier declarations
Production location → Company data

Substances of Concern – a broader definition

The DPP requires information on Substances of Concern (SoC).

This is not just the SVHC list from REACH – it covers more:

What counts as SoC:

CMR substances (carcinogenic, mutagenic and toxic to reproduction)

Categories 1A/1B
Threshold ≥0.1% w/w

PBT/vPvB (Persistent, Bioaccumulative, Toxic)

Do not degrade in nature
Accumulate in organisms

Endocrine disruptors (ED)

New CLP hazard classes
Affect the hormonal system

Respiratory/skin sensitisation

Categories 1, 1A, 1B
Relevant for worker protection

The key difference: impact on recycling

The DPP does not only ask “is it dangerous to people” but also “does it hinder recycling?”.

Example: Brominated flame retardants may not be CMR, but they prevent plastic recycling.

The DPP must flag this as “incompatible with recycling”.

That is why DPP = a tool for the circular economy, not only for safety.

The technology behind the DPP

The DPP uses the GS1 Digital Link standard – the same system as barcodes in supermarkets.

How it works:

You get a GTIN (Global Trade Item Number) – a unique product number
You generate a QR code that contains the GTIN + a link to the data
Whoever scans the QR – gets data tailored to them

In practice:

QR code on the label
Behind the QR – all the data (SDS, PCF, instructions)
A different view for the consumer, B2B and the regulator

We will leave the details of the GS1 technical implementation for the next blog post.

What the industry is asking of the EU

In December 2025, the chemical industry (Cefic + FECC) organised a workshop and published recommendations.

Top 3 requests:

1. Realistic preparation time

18-24 months after the delegated act
Gradual implementation (not all at once)
Additional time for small and medium-sized enterprises (+6-12 months)

2. Tools adapted to small businesses

Simple interfaces
Template-based systems
Affordable SaaS models (not €50K+ software)

3. Smart verification

Checking the methodology (HOW the data was obtained)
Sample checks (not 100% coverage)
Self-declaration + on-site checks

The industry’s message: “Gradual implementation – NOT a ‘big bang’ that chokes small and medium-sized enterprises.”

How to prepare: 5 steps

Don’t wait for the delegated act. The infrastructure is being built NOW.

STEP 1: Data check (1 month)

Map what you have:

✅ SDS for all products?
✅ REACH registrations up to date?
❌ Carbon footprint data?
❌ Recycled content %?

Make a list of gaps – that is your roadmap.

STEP 2: Pilot project (2-3 months)

Choose 2-3 products:

A simple product (one substance)
A complex mixture (10+ substances)
A hazardous product (CMR or SVHC)

Create a DPP manually (Excel/Word).

Goal: Understand the process before automating it.

STEP 3: Supplier engagement (ongoing)

Ask your suppliers for:

Substance composition (CAS numbers, %)
Carbon footprint (PCF) – if they have it
Recycled content %
Certificates (ISO 14001)

Reality: 80% will not have a PCF.

That is OK – document what you have requested. Regulators look for “demonstrated good faith”.

STEP 4: Choosing the technology (3-6 months)

Three options:

A) Manual (Excel + QR generator)

Free
Slow, error-prone
OK for <20 products

B) SaaS platform (€100-400/month)

Automatic SDS → DPP mapping
QR code generation
Version control
OK for small and medium-sized enterprises (20-500 products)

C) Enterprise software (€50K+ licence)

Full ERP integration
Multi-site implementation
For 1000+ products

Advice for small businesses: Start with B (SaaS).

STEP 5: Monitoring the regulations (ongoing)

Stay up to date:

ECHA newsletter (sign up at echa.europa.eu)
EU Official Journal (weekly checks)
Industry events (Cefic, associations)

Key date: End of 2025 – the EU study on chemicals.

Once the delegated act is published (2027?) → you have 12-18 months.

But preparation starts today.

Conclusion: first or last-minute?

The Digital Product Passport is coming. The question is not IF – but WHEN.

Summary:

✅ ESPR adopted (July 2024)
✅ Battery passport mandatory (Feb 2027)
✅ Chemicals on the list (2028-2030)
✅ 80% of the data in the SDS
⚠️ 20% new (sustainability)

Two scenarios:

Scenario A – Early adopter:

Preparation in 2026-2027
Ready 12-18 months BEFORE the deadline
Advantages: Competitive edge, smooth implementation, no panic

Scenario B – Last minute:

Waiting for the delegated act
Implementing a system 6 months before the deadline
Advantages: None

The choice is yours.

Next steps

Data check – SDS → DPP mapping (1 week)
Pilot – 2-3 products manually (1 month)
Suppliers – request PCF data (now)
Technology – Research SaaS platforms (1-2 months)
Monitoring – ECHA newsletter (ongoing)

The compliance deadline is coming faster than you think.

Start today.

Follow the series

This is the introductory post. Upcoming topics:

GS1 Digital Link – a step-by-step technical guide
A Substances of Concern checklist for your products
Carbon footprint – practical examples
Collecting data from suppliers – templates

Follow the blog or sign up for the newsletter.

Have questions?

We will analyse your products and give recommendations for DPP preparation.

References:

This blog post is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed chemical adviser or a lawyer specialising in chemical regulation.