What Is a Digital Product Passport?
A Digital Product Passport (DPP) is a structured data record that travels with a product throughout its lifecycle — from raw materials through manufacturing, use, repair, and end-of-life. It is mandated by the Ecodesign for Sustainable Products Regulation (ESPR), published as Regulation (EU) 2024/1781 (OJ L 2024/1781).
Under ESPR Art. 9, a DPP must be accessible via a data carrier (typically a QR code) affixed to the product. It contains environmental performance data, material composition, repairability information, and the product’s carbon footprint.
The Battery Passport — First Deadline
The Battery Regulation (Regulation (EU) 2023/1542) is the first product category to require a DPP. Key dates:
| Requirement | Effective Date |
|---|---|
| Carbon footprint declaration for EV and industrial batteries | February 2025 |
| Carbon footprint performance classes | February 2026 |
| Full battery passport (digital, QR-accessible) | February 2027 |
| Maximum carbon footprint thresholds | February 2028 |
The battery passport must include: battery model identification, manufacturing details, carbon footprint per kWh of energy provided, material composition (including cobalt, lithium, nickel, lead content), recycled content share, expected lifetime, state of health data, and end-of-life collection information.
Who Is Affected?
- Battery manufacturers placing EV or industrial batteries on the EU market
- Importers of batteries or products containing batteries into the EU
- Authorised representatives of non-EU manufacturers
- Downstream users who need to access passport data for repair, recycling, or due diligence
The ESPR extends this model to other product categories over time. Delegated acts will define requirements for textiles, electronics, furniture, and other sectors — but batteries are the first mover.
Carbon Footprint in the DPP
The carbon footprint component of a DPP is where GHG accounting meets product regulation. For batteries, the carbon footprint must be calculated per the EU Product Environmental Footprint (PEF) methodology and expressed in kg CO2e per kWh of total energy provided over the expected battery lifetime.
This means manufacturers need:
- Lifecycle GHG data covering raw material extraction, cell manufacturing, pack assembly, and transport
- Emission factors aligned with PEF/EF 3.1 methodology
- Data quality documentation per EF 3.1 Annex I (the same DQR system BARGO’s tooling implements)
How BARGO applies this
BARGO’s tooling provides several building blocks for DPP carbon footprint compliance:
- Scope 3 Category 1 & 2 — purchased goods and capital goods calculations cover upstream material and component emissions.
- PEF/LCI export — the platform generates a Product Environmental Footprint-compatible Life Cycle Inventory in Excel format, following EF 3.1 Annex I naming conventions.
- DQR scoring — every emission factor in BARGO’s tooling carries a 5-dimension Data Quality Rating (technological, geographical, time, precision, overall) per EF 3.1, matching the DPP carbon footprint methodology requirement.
- Embodied carbon input — Category 2 (Capital Goods) accepts pre-computed embodied carbon values for products with Environmental Product Declaration (EPD) data.
What Is Not Yet Covered
- Full product-level lifecycle assessment (LCA) modelling — BARGO’s tooling calculates corporate-level GHG, not product-level LCA
- Battery passport data format generation (the structured XML/JSON that goes behind the QR code)
- DPP registry submission
These are on the product roadmap. Unbin’s current value is providing the emissions data and DQR-scored factors that feed into your DPP carbon footprint calculation.
Legal References
- ESPR — Regulation (EU) 2024/1781 (OJ L 2024/1781), Art. 9 (digital product passport), Annex VI
- Battery Regulation — Regulation (EU) 2023/1542
- Product Environmental Footprint (PEF) — Commission Recommendation 2013/179/EU (CELEX 32013H0179)
- EF 3.1 DQR — Commission Recommendation (EU) 2021/2279 (CELEX 32021H2279), Annex I