The Digital Product Passport, Built for Compliance and Anti-Counterfeiting

The Digital Product Passport is a structured, machine-readable record of a product's sustainability and lifecycle data, reachable through a data carrier (a QR code or an NFC tag) placed on or inside the product. It is mandated by the ESPR, Regulation (EU) 2024/1781, which entered into force on 18 July 2024.

The ESPR replaces the earlier Ecodesign Directive and extends ecodesign requirements to almost every physical product category placed on the EU market. The DPP is its central information tool. Its purpose is to make verified data on materials, origin, durability, and recyclability available to everyone who needs it: consumers making informed choices, businesses along the value chain, repairers and recyclers, and market surveillance authorities.

Each product, batch, or model carries a unique identifier that resolves to its passport, and the data is expected to remain accessible for the product's full lifetime.

Yes, but not for every product at once. The ESPR is a framework regulation: it does not set a single deadline for all goods. The DPP obligation is switched on product group by product group, through delegated acts adopted by the European Commission. Each delegated act defines the exact data requirements, the data carrier, and the compliance date for its category.

Key milestones:

• ESPR in force: 18 July 2024
• ESPR working plan (2025-2030): sets the first priority product groups, including textiles and apparel, iron and steel, aluminium, furniture, and tyres
• Textiles: a first-priority category. A delegated act is expected around 2027, with the DPP obligation expected to apply from ~2028
• Batteries: the earliest passport obligation. Under the EU Battery Regulation (Regulation (EU) 2023/1542), a battery passport is required from 18 February 2027 for EV batteries, industrial batteries above 2 kWh, and light means of transport (LMT) batteries

Where a date is not yet fixed in a final delegated act, treat it as indicative. The direction is settled; the precise obligation dates per category are still being confirmed. Brands that structure their product data now avoid a compressed compliance window later.

The exact fields depend on the delegated act for each product group, but the ESPR sets out the categories of information a passport can be required to hold:

• Materials and composition: what the product is made of, including material shares and components
• Origin and supply chain: where key stages happened and which suppliers were involved
• Durability and repairability: expected lifetime, spare-part availability, repair information
• Substances of concern: hazardous or restricted substances present in the product, aligned with existing chemical reporting
• Recyclability and end-of-life: recycled content, disassembly and sorting guidance, recovery instructions

Not every data point is public. The ESPR names the actors who must be able to reach the passport, among them customers, professional repairers, refurbishers, recyclers, market-surveillance authorities and customs authorities (Article 11(b)), and leaves it to each product group's delegated act to say which field goes to which audience. No such act is published yet. All of it must be reachable through a data carrier placed on the product, its packaging, or its documentation.

The ESPR is technology-neutral on the carrier: it requires a data carrier linked to a unique identifier, and both QR codes and NFC tags qualify. The trade-off matters most for brands that also care about authentication.

• QR code: cheap to print, works with any camera app, easy to add to labels and packaging. It is a printed link. A QR code can be copied, screenshotted, or reprinted, so on its own it proves that a passport exists, not that the physical item is genuine.
• NFC (NTAG 424 DNA): a secure chip embedded in or on the product. Each tap generates a fresh cryptographic signature (SUN, Secure Unique NFC message) that a server verifies. It cannot be cloned by copying the URL, and it binds the passport to that specific physical item.

For DPP compliance alone, a QR code can be enough. For brands that also need to prove authenticity and fight counterfeiting, NFC with the NTAG 424 DNA chip provides a tamper-resistant identity that carries the passport and verifies the item at the same time. SealTrust supports both carriers, so the choice can differ from one product line to the next.

The DPP market is young, and vendors range from label printers that add a QR link to full product-identity platforms. The differences are easy to miss at demo stage and expensive to discover after rollout. When evaluating digital product passport providers, assess six things:

• Verifiable data whose integrity is provable: can the passport data be trusted and shown to be unaltered? SealTrust anchors records on-chain (Base L2), giving each passport an independent integrity proof.
• Interoperability (GS1 + JSON-LD): the EU DPP system requires open standards and interoperable data. Ask for GS1 Web Vocabulary mapping and JSON-LD export so your data stays portable to the EU registry and other systems, not locked in a proprietary format.
• Per-field access control: the passport must serve public, business, and authority audiences from the same record. Look for field-level access tiers, not just one public page.
• Anti-counterfeiting built in: a passport that also authenticates the item protects the brand, not only the compliance file. Secure NFC (NTAG 424 DNA) does both.
• Per-vertical playbooks: textiles, batteries, and electronics have different data requirements. A provider with compliance playbooks per category shortens implementation.
• Resale and lifecycle support: the DPP follows the product through ownership changes, repair, and recycling. The identity and passport must persist across the item's whole life.

A provider that only prints QR codes covers the carrier, but not verifiability, access control, or authentication. Buyers choosing for the long term weigh all six.

SealTrust gives each product one verifiable identity that does two jobs at once: it carries the EU Digital Product Passport for compliance, and it authenticates the physical item to fight counterfeiting.

• One identity: a single secure NFC tag (NTAG 424 DNA) or QR code links to the product's passport and confirms the item is genuine on every scan.
• Verifiable data: every published passport version has its SHA-256 fingerprint anchored on Base L2 automatically, and a unit's membership of an anchored batch is provable, independent integrity proofs that do not require trusting us.
• Structured DPP model: materials, suppliers, and components are captured in a data model built around the ESPR's information categories.
• Interoperable by design: passports export as JSON-LD and map to the GS1 Web Vocabulary, keeping data portable to the EU DPP system and downstream partners.
• Controlled access: six per-field profiles (public, consumer, repairer, recycler, upstream supplier, authority) serve everyone from one record. The three trade profiles are peers, not levels: none of them sees what the other two see.

Compliance and brand protection are delivered from the same identity, not two separate projects.

SealTrust ships compliance playbooks for the categories where the DPP matters most:

• Fashion and textiles: a first-priority ESPR category: composition, origin, and care/repair data, plus anti-counterfeiting
• Luxury goods: proof of authenticity and provenance, with resale and lifecycle traceability
• Batteries: the earliest passport obligation (from February 2027) for EV, industrial (over 2 kWh), and LMT batteries
• Electronics: durability, repairability, substances of concern, and recycled content
• Construction products: declaration of performance, CE marking data, and substances, under the CPR (EU) 2024/3110
• Cosmetics and fragrance: per-item authentication and ingredient transparency, on the general passport model. No named DPP obligation today, and no dedicated playbook.

Each vertical that has a playbook starts from it rather than from a blank form, so the data model matches the category from day one.