5 Myths About the Digital Product Passport

A Digital Product Passport (DPP) is a legally structured, machine-readable record tied to a specific product, required under ESPR and CPR once that product's category is covered by a delegated act. It's a relatively new requirement, and new requirements collect misconceptions faster than they collect clarity. Five of them come up constantly in conversations with manufacturers getting ready for compliance. None of them hold up.

A Digital Product Passport is just a QR code stuck on the product.

Not true: the QR code is only the entry point. The DPP itself is the structured dataset behind it, covering identification, technical and environmental data, durability and repairability information, and supply chain traceability.

The QR code (or equivalent data carrier) is what a customer, auditor, or recycler scans, but it's a pointer, not the passport. What it points to is a registry-connected record with defined data fields, the kind of thing that has to be built, populated, and kept current, not printed once. We go through exactly what belongs inside that record, field by field, in Module 4 of our course, What's Inside a DPP.

An EPD already counts as your Digital Product Passport.

Not true: an EPD is a voluntary environmental report, while the GWP figure CPR actually requires from January 2026 is a narrower, mandatory value nested inside a different legal document, the Declaration of Performance and Conformity.

An existing EPD is genuinely useful. It already contains life-cycle data that can feed into your DPP's environmental fields. But it's a separate legal object from the DoPC declaration CPR asks for, and it doesn't make your product compliant with a DPP requirement on its own. We go through the full comparison, including why the two are expected to coexist rather than replace each other, in EPD vs DPP.

The Digital Product Passport deadline is the same for every construction product.

Not true: DPP and GWP-declaration obligations roll out product category by product category through separate delegated acts, and no official EU source has yet named a fixed, confirmed date for construction materials specifically.

The European Commission's own DPP roadmap lists an indicative milestone, a delegated act for construction materials under CPR targeted for Q2 2027, but the Commission itself labels this subject to change, not a committed deadline. Treating any single date as fixed for "construction" as a whole misreads how the rollout actually works. We cover the mechanism, and why there's no official priority order yet, in our piece on delegated acts.

Whoever enters the product data is automatically responsible for its accuracy.

Not true: EU law assigns accuracy obligations to the "economic operator" as a legal role, not to whichever employee happens to type the numbers in, and which internal department actually owns that responsibility is left entirely to each company to decide.

"Economic operator" is a defined legal term, not an org-chart title. It carries real data-accuracy obligations under ESPR, but the regulation doesn't say whether that's quality, sustainability, product management, or IT in your specific company, and lifecycle-update responsibility is still being deferred to future delegated acts. We go through why this is a genuine, confirmed gap, not just an open question, in who owns product data.

Once you've published a Digital Product Passport, the work is done.

Not true: lifecycle-update obligations are still being defined through future delegated acts, and the indicator set a DPP must report is set to expand on a fixed schedule, GWP only from 2026, more by 2030, a full life-cycle assessment by 2032.

A DPP isn't a filing you complete and file away. The scope of what it has to report is scheduled to grow over the next six years, and any change to the underlying product, materials, or supply chain is expected to be reflected in it. Treating publication as the finish line is how passports go stale before the next compliance check.

Frequently asked questions