Digital Product Passport (DPP): what it is, how it works and the role of RFID

If your company manufactures, imports or distributes products within the European Union, the Digital Product Passport will change the way you identify every item you place on the market. This is not a distant prospect: the central European passport register has been operational since July 2026, the technical standards defining data carriers — including RFID — have already been published, and the first sector-specific requirement, the battery passport, comes into force on 18 February 2027.

The practical problem is not a legal one, but an operational one: the DPP requires every product to physically carry a data carrier that links to its digital information. This means we must decide now how each item will be identified – QR, Data Matrix, NFC or RFID – using which identifier, at what stage of the process, and how it will be integrated with the company’s systems. Choosing the wrong option will mean having to relabelling millions of units later on.

In this guide, you will find out exactly what the DPP is according to Regulation (EU) 2024/1781, how its architecture works, which deadlines are confirmed and which are merely indicative, and —based on our experience as a European manufacturer of RFID tags—what role RFID can actually play as a data carrier and as a data capture tool to populate the passport.

What is the Digital Product Passport (DPP)?

The legal definition is precise. According to Article 2(28) of Regulation (EU) 2024/1781 (ESPR), the digital product passport is ‘a set of product-specific data comprising the information specified in the applicable delegated act and accessible electronically via a data carrier’.

Three key points can be derived from this definition, which should be established from the outset:

• The DPP is information, not a label. The passport data resides on digital infrastructure (systems belonging to the manufacturer or DPP service providers), not within a chip.
• Access is both physical and digital. Each product carries a data carrier (QR code, Data Matrix, NFC, RFID, etc.) that contains or encodes a unique identifier; this identifier points to the passport data.
• The content is determined by each delegated act. There is no universal list of data: the European Commission defines the requirements on a category-by-category basis (batteries, textiles, steel, tyres, etc.).

Why does the DPP exist? The ESPR Regulation and the circular economy

The legal framework is Regulation (EU) 2024/1781 on the eco-design of sustainable products (ESPR), adopted on 13 June 2024 and in force since 18 July 2024. The ESPR replaces the previous Ecodesign Directive and extends its scope beyond energy-related products: it potentially affects almost any physical product placed on the market in the EU.

Chapter III of the ESPR (Articles 9 to 15) specifically regulates the digital product passport: general requirements, technical design, unique identifiers, central register, public web portal and customs controls. Two requirements of the regulation define the physical aspect of the system:

• The data carrier must be physically present on the product, on its packaging or in the accompanying documentation, as determined by the applicable delegated act (Article 10 of the ESPR).
• The unique product identifier is ‘a unique string of characters for the identification of a product which also enables a web link to the digital product passport’ (Article 2(30)).

The cause-and-effect relationship is straightforward: if the EU wishes to extend the useful life of products (repair, reuse, remanufacturing, recycling), it needs any authorised party — consumer, inspector, repairer, recycler — to be able to access accurate data on the specific product before them. The DPP is the mechanism; the data carrier is the gateway; and the unique identification at item level is the foundation.

How does a DPP work? Layered architecture

Two elements of European infrastructure complete the system:

• DPP Central Register (Article 13 of the ESPR). The regulation required the European Commission to establish, by 19 July 2026, a central register to securely store unique identifiers. That register was launched in July 2026. Important: the register does not store passport data, but rather the identifiers; it functions as a directory that points to where each manufacturer hosts its DPP.
• Public web portal (Article 14 of the ESPR). A European access point for searching and comparing passport information.

The operational implication for a manufacturer: the data remains their own and is hosted on their systems (or with their DPP service provider), but the identifier must be registered and access must be guaranteed throughout the product’s lifetime. This makes the quality of the physical identification — the label and its encoding — a compliance requirement, rather than a logistical detail.

What information does a DPP contain?

The level of granularity is also set by each delegated act: the passport can be defined by model, by batch or by individual item. This decision directly determines the identification technology: a DPP per model can be achieved with a QR code printed identically across the entire series; a DPP per item requires unit-by-unit serialisation — the natural domain of RFID and serialised 2D codes.

What is a data carrier?

The definition is deliberately technology-neutral. In practice, the options are:

• Printed 2D codes: QR and Data Matrix. Readable by a smartphone, with a marginal cost of almost zero if the label is already being printed.
• NFC (HF, 13.56 MHz): proximity reading via smartphone, offering a premium consumer interaction experience.
• UHF RFID (RAIN RFID, 860–960 MHz): bulk reading, at a distance and without line of sight; the de facto standard for traceability in retail, textiles and logistics. If you’d like to learn more about the underlying technology, here we explain what RFID technology is and how an industrial RFID tag works.

The European standard EN 18220 (Digital Product Passport — Data carriers), drawn up by the CEN/CENELEC JTC 24 and designated as a harmonised standard in July 2026, specifies the requirements for data carriers accepted for the DPP, including QR codes, Data Matrix and RFID (HF/NFC and UHF), along with placement and quality criteria. Its sister standard, EN 18219 (unique identifiers), supports various identification schemes, including GS1 Digital Link URIs.

A common mistake — even in specialist articles — is to describe the DPP as ‘a chip containing all the product information’. This is technically incorrect: the data carrier holds the identifier (and, in the case of RFID, optionally some additional data in user memory), but the product passport resides in the cloud. If the physical medium is damaged, the data is not lost; if the data is updated (following a repair, for example), there is no need to touch the tag.

What role does RFID play in the Digital Product Passport?

It is worth distinguishing between the two roles of RFID in a DPP project:

1. RFID as a data carrier

A UHF RFID tag (RAIN RFID, EPC Gen2 / ISO/IEC 18000-63 protocol) contains a chip with several memory zones relevant to identification:

• EPC memory: where the item’s identifier is encoded — typically an SGTIN, which combines the model’s GTIN with a unique serial number per unit.
• TID memory: programmed by the chip manufacturer, it includes a unique, non-modifiable serial number that provides an additional layer of authenticity.
• User memory (optional): available on some chips for additional data.

Under the GS1 Digital Link standard, this identifier is expressed as a web URI: the same identifier read by an RFID gateway in a warehouse can be resolved to the product’s digital passport. The joint position paper published by GS1 and the RAIN Alliance in September 2025 proposes precisely this combination — serialised GS1 identifiers on RAIN RFID, with QR/2D as a complementary carrier for the consumer — as the reference solution for DPPs.

2. RFID as a data capture tool

Here is the operational argument that legal guides often overlook: a digital passport is only useful if the data it contains is accurate and up to date, and that requires capturing events throughout the entire supply chain. Manufacture, dispatch, receipt, sale, return, repair, recycling: every event is a scan.

• With QR codes, each scan is manual, one by one and requires a line of sight.
• With UHF RFID, a gateway or handheld reader captures hundreds of items in seconds, without line of sight, whilst the product is still in its packaging — the basis of RFID applications in logistics.

The cause-and-effect relationship: the lower the cost of each read, the more checkpoints a company can afford, and the more complete and reliable the historical data feeding the DPP (typically via EPCIS events to ERP/WMS). That is why sectors that already use RFID at item level — textiles and retail, with tens of billions of UHF tags sold annually according to the RAIN Alliance — have a head start when it comes to DPP: the serialised identification infrastructure already exists.

RFID vs QR vs NFC: a comparison as data carriers for DPP

Three practical interpretations of the table:

• If the delegated act requires consumer access via a smartphone, an optical carrier (QR/Data Matrix) or NFC will be required. For batteries, Regulation (EU) 2023/1542 already specifies the use of QR codes.
• If the company requires automated inventory management, dispatch and logistics, UHF RFID is the only one of the three technologies designed to capture hundreds of units per second.
• The combination is natural, not redundant: a single label can integrate a UHF RFID inlay and a printed QR code with the same GS1 Digital Link URI. One identifier, two access points.

When will the DPP become mandatory? Verified timetable (August 2026)

Important notes on interpreting the timetable:

• The ESPR 2025–2030 work plan, adopted by the European Commission on 16 April 2025, prioritises textiles and clothing, furniture (including mattresses) and tyres as end products, and iron/steel and aluminium as intermediate products — categories relevant to RFID identification in the industry.
• Between the adoption of each delegated act and its effective application, the ESPR provides, as a general rule, for a minimum transition period of 18 months (Article 4); therefore, the application dates are estimated by adding this margin.
• Anything other than the Batteries Regulation and the ESPR framework should be treated as a provision, not an obligation. Delegated acts may be delayed or their scope adjusted.

DPP for batteries: the first obligation with a set date

The case of batteries serves as a model that other sectors should study, as it already specifies what the ESPR leaves to delegated acts:

• Defined data carrier: QR code printed or engraved on the battery.
• Level of detail: a passport for each individual battery (unique identifier), containing model and batch/unit data such as the carbon footprint per manufacturing plant and batch.
• Content: technical characteristics, chemical composition, carbon footprint, electrochemical performance, health status, dismantling and safety information, with different access levels for the public, authorities and authorised operators.

Does the mandatory QR code mean that RFID is no longer used for batteries? No: the QR code is the minimum access requirement, but internal production and logistics management of packs and modules may continue to rely on RFID for operational traceability. They are complementary layers: compliance (QR) and efficiency (RFID).

DPP for textiles: the sector that needs to prepare the most

Why does the textile sector have a head start if it already uses RFID?

• Serialisation is already in place. Brands that use RFID tags for textiles already assign a unique SGTIN to each garment: exactly the type of serialised identifier that the DPP requires at item level.
• Event capture is already in place. In-store stock-takes, goods receipts, dispatches and returns using RFID generate the traceability history that can feed into the passport.
• The hardware is already in place. Fixed and handheld readers, gates and source encoding are already deployed.

For a clothing brand, the right question is not ‘Will I have to add a QR code in 2029?’, but ‘How do I design my label today — care instructions, brand, RFID and 2D code—so that a single identifier can be used for stocktaking, logistics, anti-fraud and the digital passport?”. Anticipating this decision avoids having to duplicate labels and re-encode millions of garments.

The specific requirements of the Textile DPP (fibre composition, substances, recyclability, repair information) will be set out in the delegated act; until its adoption, they should be treated as provisional.

DPP standards: CEN/CENELEC JTC 24, GS1 and RAIN Alliance

Industry identification standards are based on this regulatory framework:

• GS1: GTIN for the model, SGTIN for the serialised item, GS1 Digital Link to express the identifier as a web URI, and EPCIS for sharing traceability events.
• RAIN Alliance: the passive UHF RFID ecosystem (EPC Gen2 / ISO/IEC 18000-63), which works with GS1 to ensure that a single identifier functions across RFID, QR codes and NFC.

For the technical reader, the conclusion is reassuring: there is no need to opt for a proprietary standard. GS1 identification combined with carriers standardised by EN 18220 is currently the approach with the lowest risk of obsolescence.

How to prepare your business for the DPP? Decision checklist

Before defining your identification strategy for the DPP, answer these questions:

1. Regulation: which category does your product fall into, and what is the status of its delegated act?
2. Level of detail: passport by model, by batch or by item? (this determines serialisation)
3. Identifier: Do you already use GTIN/SGTIN? How will you express the identifier as a URI (GS1 Digital Link)?
4. Data carrier: QR, Data Matrix, NFC, UHF RFID or a combination? Who needs to read it: the consumer, an operator or an automated gateway?
5. Surface and environment: Is the product made of fabric, plastic, metal, or does it contain liquids? Metallic surfaces and liquids alter the electromagnetic behaviour of a UHF antenna; there are specific RFID tags designed for metal.
6. Tagging point: at the point of manufacture, during processing, or in the warehouse?
7. Durability: must the tag withstand washing, temperature, chemicals and last for the product’s entire service life?
8. Data capture: Which events do you need to record (production, dispatch, sale, return, recycling) and with which readers?
9. Integration: How will you link read data with ERP/WMS/PLM systems and with your DPP platform (EPCIS events)?
10. Validation: Have you tested the tag on the actual product, at the actual distance, with the actual orientation and density?

Common mistakes when preparing identification for the DPP

• Waiting for the delegated regulation to come into force before starting. The regulation sets out the content of the passport, but serialisation, labelling and data capture require months or years to roll out. Those who wait end up relabelling.
• Treating the DPP as a software-only project. Without a tag that works on the actual product, there is no accessible passport. The physical layer is a compliance requirement.
• Choosing the data carrier based solely on unit cost. A QR code is almost free to print, but every manual scan incurs an operational cost. The correct calculation is total cost: tag + scans + errors avoided.
• Ignoring surface and environment. A standard UHF tag on metal or near liquids can go out of tune and lose performance drastically; there are tags designed for every surface.
• Serialising without a standard. Proprietary identifiers that do not fit within the GS1 Digital Link later require re-encoding. It is better to adopt a standard from the outset.
• Failing to define data governance. Who updates theproduct passport following a repair? Who is responsible for ensuring its availability throughout the product’s lifecycle? The ESPR requires persistent access.
• Scaling without a pilot scheme. Validate the tag, encoding, reads and integration on a single production line or in a single shop before rolling out across the entire operation.

Practical example: RFID and DPP for a fashion brand

Situation. A fashion brand producing 2 million garments per year, with manufacturing outsourced to several countries, 40 own-brand shops and online sales. It wants to get ahead of the textile DPP and, whilst doing so, resolve its stock-outs caused by inaccurate stock levels.

Identification approach.

• Identifier: SGTIN per garment (model GTIN + unique serial number), expressed as a GS1 Digital Link URI.
• Label: hangtag with a UHF RFID inlay and a printed QR code, both encoding the same identifier. For premium ranges, a wash-resistant , sewn-in RFID label.
• Encoding: at source, during label manufacture, with unit-by-unit verification (engraved EPC + registered TID).

Expected outcome. The brand automates stock-taking and dispatch using RFID (processes that are currently manual), and once the textile contractor finalises the passport’s content, it will have: serialisation per garment, a dual data carrier (RFID + QR) and an event history to feed into the DPP. The investment is justified by the immediate operational improvement; DPP readiness follows as a result.

Trace-ID tags recommended for traceability and DPP projects

At Trace-ID, we design and manufacture RFID tags in Barcelona, with full in-house manufacturing capabilities — including in-house antenna design, bonding, converting, printing and encoding — and performance verification using Voyantic equipment. For DPP-focused traceability projects, these product families are a common starting point:

TAR17/18 RFID tag (Impinj M700 series chips) · TARu8/u9 (NXP UCODE 8/8m/9 chips)

• Type: general-purpose UHF inlay/tag
• Dimensions: antenna 42×16 mm; inlay 44.45×19.05 mm
• Frequency: global 860–960 MHz (RAIN RFID, EPC Gen2v2 / ISO/IEC 18000-63)
• Memory: 96–128-bit EPC; 96-bit TID with a unique 48-bit serial number
• Stated applications: clothing, retail, pharmaceuticals, cosmetics and supply chain
• Why it fits with DPP: the EPC memory supports a serialised SGTIN and the unique TID provides an additional layer of authenticity per unit
• Link: RFID tags for clothing

TH-Wing RFID tag (M7/M8/U8)

• Type: UHF tag used in textile applications
• Dimensions: antenna 50×30 mm
• Frequency: global 860–960 MHz
• Application: textiles (sewn onto a satin strip or as a tag/sticker with the inlay protected between layers)
• Why it fits with DPP: format designed to accompany the garment throughout its use, a key requirement if the passport is to remain accessible after sale
• Link: RFID tags for textiles

For challenging surfaces (metal, industrial environments), we offer specific ranges of tags for metal, and we develop bespoke tags when the project requires it: material, adhesive, dimensions, chip and encoding are defined according to the surface, read range and operational process.

The specifications provided are taken from the Trace-ID 2025 catalogue; for each project, we recommend confirming the exact product code and its configuration with our technical team.

Frequently asked questions about the Digital Product Passport

Conclusion

The Digital Product Passport is no longer a concept under discussion: it is a system with regulations in force, an operational central register, harmonised technical standards and a first binding deadline (batteries, 18 February 2027). For the other priority sectors — textiles, steel, aluminium, tyres, furniture — the time remaining is not a waiting period, but a time for preparation.

The decision that an industrial company or a brand can (and must) take today does not depend on any delegated act: how to uniquely identify each product, which data carrier to use, and how to capture the data that the passport will require. RFID is not mandatory for the DPP; in many scenarios, it is the most efficient way to comply with it and to make it operationally viable whilst awaiting the obligation to take effect.

Sources and technical documentation

• European Union (EUR-Lex) — Regulation (EU) 2024/1781 (ESPR): definitions of DPP, data carrier and unique identifier (Art. 2, points 28–30); Chapter III (Articles 9–15); central register (Article 13). eur-lex.europa.eu/eli/reg/2024/1781/oj
• European Union (EUR-Lex) — Regulation (EU) 2023/1542 (batteries): battery passport from 18 February 2027; QR code; Chapter IX and Annex XIII. eur-lex.europa.eu/eli/reg/2023/1542/oj
• European Commission — ESPR Work Plan 2025–2030 (adopted on 16 April 2025): priority categories and indicative timetable. commission.europa.eu — ESPR
• CEN/CENELEC — JTC 24, DPP system standards EN 18216/18219/18220/18221/18222/18223/18239/18246; six of which are cited as harmonised in the OJEU (July 2026). cencenelec.eu — DPP
• GS1 + RAIN Alliance — Joint position paper ‘Advancing DPPs with GS1 Identifiers and RAIN Technology’ (9 September 2025). therainalliance.org
• RAIN Alliance — ‘Digital Product Passports Enabled by RAIN’ and position paper (2024). therainalliance.org — DPP
• GS1 — GS1 Digital Link and EPCIS. gs1.org/standards/gs1-digital-link