You may add data beyond the minimum, with one condition

Once a company understands what its digital product passport (DPP) must contain, the next question is usually whether it can contain more. Certifications the brand is proud of, provenance detail, craft and process information, warranty terms.

The answer is yes, with a condition that matters more than it first appears.

What the regulation allows

Additional voluntary data points may be included, provided that data accuracy, interoperability and the passport's functionality are not compromised. And the voluntary data points must be clearly distinguished from the mandatory ones.

That second clause is the one to design around.

Why the separation is the whole rule

A passport is read by systems as well as by people. A market surveillance authority querying a required field needs to get the required field, not a marketing claim occupying the same space. A recycler parsing material composition needs the regulated composition data, not a supplier's narrative about it.

Mixing the two degrades the record for everyone reading it and creates a compliance problem for you: if an authority cannot tell which claims you are making under the regulation and which you are volunteering, every claim is treated as the former.

So voluntary data is an opportunity that comes with an architectural requirement. The record needs two clearly separated zones from the beginning, and retrofitting that separation once data is mixed is painful.

Where the opportunity actually is

Three cases where voluntary data earns its place.

Claims you already make elsewhere. Certifications, standards, testing results that already appear on your website or your packaging. Putting them in the passport, in the voluntary zone, means they arrive with the product rather than requiring the buyer to find your site.

Data a buyer asks for repeatedly. If the same question appears in every tender questionnaire, answering it once in the passport turns a recurring manual task into a lookup.

Provenance and craft. For premium products this is genuinely valuable and the passport is a better vehicle than a hangtag, since it cannot be separated from the item and can be updated.

Two cautions

Every voluntary claim is still a public claim. The accuracy condition applies to it. Adding a sustainability assertion you cannot evidence does not become safer because the field was optional, and consumers can claim compensation for damages caused by non-compliant products regardless of which zone a claim sits in.

Volume is not value. A passport crowded with optional fields is harder for every reader to use, and the required data is what determines whether the product can be sold. Get the mandatory zone right and evidenced first.

The practical approach

Design the record with the two zones separated from day one, even if you start with nothing in the voluntary one. Then treat the voluntary zone as a product decision with an owner, rather than a place where any team can add a field, and hold it to the same evidence standard as the mandatory one.

Sources

• European Commission, *Digital Product Passport: Frequently Asked Questions*, January 2026 update,
• question 22 on voluntary data points, question 30 on consumer compensation rights.