One passport, four readers, four different views

A digital product passport (DPP) is not a page. It is one record that presents a different slice to each party entitled to see it, and the four groups want genuinely different things.

Designing for the consumer view alone is the most common way to build a passport that fails its first serious check.

The economic operator

The manufacturer, authorised representative, importer, distributor, dealer or fulfilment service provider. They carry the primary responsibility: compiling the data in the structure the legislation requires, registering the passport in the EU registry, ensuring a physical carrier is attached to the product, its packaging or its documentation, and maintaining data accuracy across the product's lifecycle.

Registration is mandatory for placing the product on the single market, which is what makes this a market access question rather than a reporting one.

The consumer

Before purchase, a scan gives information that supports comparison between products, and the EU web portal allows searching and comparing across products. After purchase, the passport can hold manuals, maintenance guidance and end-of-life instructions.

Access has to be free of charge and easy. Online marketplaces will be required to make the passport accessible on the product page.

The consumer view is the one most companies build first, because it looks like marketing. It is also the least demanding of the four.

Public authorities

Two different checks, described in full in who enforces the DPP.

Customs, at the point of entry, can search the registry electronically to verify that a passport has been registered, enabling automated screening of imports. Market surveillance authorities can scan the carrier to reach documentation and run targeted searches for non-compliant products.

What they need is machine-readable structure and evidence, not narrative.

Repairers, refurbishers and recyclers

The group that gets forgotten, and the reason the regulation exists at all.

Where the delegated act requires it, professional repairers and refurbishers can access disassembly instructions, lists of compatible spare parts and the tools required, and diagnostic information to identify faults. Recyclers can access material composition, letting them identify quantities and types of valuable materials for recovery, and know which components contain substances of concern that must be safely removed.

These readers arrive years after the sale, when your commercial relationship with the product is over. That is precisely why persistence matters.

What follows for the design

Four consequences, and they are all cheaper to handle at the start.

The record needs layers with access rules, not one public page. The restricted layer is where supplier identity and commercially sensitive composition data live.

It needs to be machine-readable, because two of the four readers are systems.

It needs to persist far beyond the sale, because the recycler is the last reader and the most distant.

And it needs one source of truth, because four views maintained separately become four different answers.

Sources

• European Commission, *Digital Product Passport: Frequently Asked Questions*, January 2026 update,
• questions 3, 12, 13 and 14.
• Regulation (EU) 2024/1781 (ESPR).