THE EU DIGITAL
PRODUCT PASSPORT
Implications for Logistics, ITAD, Reuse and Secondary Markets
A briefing paper for ITADA and industry stakeholders
October 2026
| CORE IDEA The DPP is not merely a digital label. It is emerging as infrastructure for persistent product identity and standardized product information across a product lifecycle. For logistics and ITAD, the strategic issue is what happens to that identity and information after the first sale. |
Executive Summary
HOW TO READ THIS PAPER
| CURRENT REQUIREMENT | INDICATIVE DEVELOPMENT | ITADA RECOMMENDATION |
| Established in legislation or adopted implementing measures. | Identified in Commission planning or guidance; subject to future measures and transition periods. | Industry preparedness or positioning proposed by this paper; not presented as EU law. |
The European Union Digital Product Passport (DPP) is a digital container for products, components and materials that stores information intended to support sustainability, circularity and legal compliance. The European Commission says it is designed to make reliable product information available in a more transparent and standardized digital form to businesses, consumers, repairers, recyclers and public authorities. The legal foundation is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. [1]
For logistics, reverse logistics and IT asset disposition (ITAD), the DPP is important because it establishes a regulatory framework in which a physical product can remain connected to a persistent digital identifier and structured information as it moves through the value chain. ESPR requires DPP data to use open standards and interoperable formats and to be transferable through an open interoperable data-exchange network without vendor lock-in. [2]
| WHY THIS MATTERS TO ITADA ITAD companies operate at the point where custody, condition, configuration, ownership and intended use often change. That makes the downstream industry a natural consumer of product information and a potential producer of new lifecycle information about repaired, refurbished, resold and recycled assets. |
The regulations do not create one universal compliance date. Requirements are being introduced progressively through two routes. Some will be established through ESPR delegated acts for product groups such as iron and steel, textiles, tyres, aluminium, furniture, mattresses and ICT products. Others, including batteries and construction products, arise under separate EU legislation that uses the broader DPP technical system. From 18 February 2027, each electric-vehicle battery, each light-means-of-transport battery and each industrial battery with a capacity greater than 2 kWh that is placed on the market or put into service must have a battery passport. [4]
ITADA’s strategic interpretation is that the deeper industry issue is interoperability. A technology asset can move from an OEM to a distributor, an enterprise, a logistics provider, an ITAD, a refurbisher, a secondary-market buyer and ultimately a recycler. These organizations normally operate independent systems. This paper therefore recommends exploring mechanisms that preserve product identity and trustworthy information across organizational and system boundaries.
ISO 20435 is relevant to that question, but its status and role must be stated carefully. As of 19 October 2026, ISO listed ISO 20435, “Framework for representing physical assets using tokens,” at stage 60.00, “International Standard under publication,” while its overall status remained “under development.” ISO’s draft online content includes a Digital Product Passport use case and addresses resolution of decentralized identifiers across multiple independent registries. [5][6] According to OBADA’s description of its standards work, the intended purpose includes management and interoperability of physical assets across supply-chain and enterprise systems using verifiable digital information. [7]
| POSITIONING DISCIPLINE ISO 20435/OBADA should not be described as an EU-mandated DPP standard. A stronger and more accurate position is that it may provide a complementary interoperability framework for physical-asset identity and lifecycle records, while EU law and product-specific delegated acts determine DPP compliance obligations. |
1. What the Digital Product Passport Is
The DPP should be understood as an information architecture rather than as a single QR-code scheme or central database. The Commission describes it as a digital container that may hold information such as safety, origin, materials, repairability, environmental performance, reuse and recycling, depending on the product group. [1]
Under ESPR, a DPP must be connected through a data carrier to a persistent unique product identifier. The applicable delegated act determines whether the data carrier sits on the product, packaging or accompanying documentation, and whether the DPP operates at model, batch or individual-item level. [2] The EU DPP Registry is principally an indexing and registration service containing unique identifiers, registration data and high-level metadata; detailed DPP information generally remains decentralized under the responsibility of the relevant economic operator or its DPP service provider. [8][11]
The DPP framework is also role-sensitive: access rights can differ depending on the stakeholder and product-specific rules. This makes the concept relevant both to public product information and to controlled information needed by economic operators or authorities. [2]
| Layer | What it does | Why logistics / ITAD should care |
| Physical product | The asset, component or material in the supply chain. | The identifier must stay associated with the actual object through handling and lifecycle changes. |
| Data carrier | Connects the physical object to its DPP; product rules specify the carrier and placement. | Receiving, warehousing, returns and ITAD intake may become points where the carrier is read. |
| Persistent identifier | Provides the digital reference associated with the product. | Helps independent parties refer to the same asset. |
| DPP data | Product-specific structured information defined by applicable law. | Can support downstream decisions involving repair, reuse and recycling. |
| Access / registry | Access rights are product-specific; the EU also operates a DPP Registry. | Compliance and lifecycle data do not need to reside in one shared proprietary system. |
2. Who Carries the Obligation?
Working definition — Economic operator: A regulated participant in the supply chain, such as a manufacturer, importer, authorized representative, distributor or another role identified in the applicable product legislation. The relevant roles vary by product and legal instrument.
Responsibility depends on the applicable product legislation and the role performed by the organization. In general, primary responsibility for creating the DPP and ensuring the accuracy of its required data rests with the relevant economic operator placing the covered product on the EU market, subject to the applicable product legislation. Depending on the product group and legislation, relevant roles may include manufacturers, importers, authorized representatives, distributors, dealers and fulfilment service providers. Manufacturers, importers and distributors then have distinct conformity, documentation, verification and corrective-action responsibilities under ESPR and the applicable product rules. [2][9]
For logistics providers, the distinction between acting only as a carrier or service provider and performing a regulated economic-operator role can matter. The specific legal position should be evaluated against the applicable product legislation and the company’s actual activities. A logistics company should not assume either that moving a product alone makes it responsible for creating a DPP or that every logistics-related activity falls outside the legislation.
| PRACTICAL DISTINCTION The DPP obligation generally follows the regulated economic-operator role and applicable product legislation, not every company that touches the asset. Logistics and ITAD organizations should nevertheless evaluate how they preserve identifier continuity, use DPP information available to them and determine whether particular activities place them within a regulated role. |
3. Timeline: A Rolling Regulatory Program
There is no single “DPP deadline.” The ESPR is a framework and product-specific obligations are phased in through delegated acts or other EU legislation. The Commission’s current ESPR Working Plan provides indicative target years for developing measures concerning iron and steel, energy-related products, textiles, tyres, aluminium, furniture, mattresses and ICT products. Following adoption of an ESPR delegated act, economic operators will generally have a transition period of at least 18 months. [1][9]
| Indicative regulatory milestone | Current position | Relevance |
| 20 July 2026 | EU DPP Registry became operational. [8] | Core infrastructure is moving from design to operation. |
| 18 February 2027 | Battery passport required for each EV battery, each light-means-of-transport battery and each industrial battery above 2 kWh placed on the market or put into service. [4] | First major operational DPP regime; relevant to many technology and mobility supply chains. |
| 2027 | Indicative target for developing measures concerning textiles, tyres and aluminium. [1][9] | Demonstrates progressive sector expansion. |
| 2028 | Indicative target for developing measures concerning furniture. [1][9] | Illustrates continued product-by-product rollout. |
| 2029 | Indicative target for developing measures concerning mattresses and ICT products; not a universal compliance date. [1][9] | Directly relevant to ITADA and electronics stakeholders. |
Because the Working Plan dates are indicative and compliance dates follow the applicable legal act and transition period, companies should manage DPP as a regulatory watch program rather than planning around a single assumed go-live date.
4. What Data and Architecture Will Be Required?
Product-specific delegated acts determine the actual DPP dataset. ESPR specifies that those acts may define the data to be included, data carrier, carrier layout and positioning, granularity at model/batch/item level, customer accessibility before sale, and applicable access rights. [2]
The common system principles are already significant: the passport connects to a persistent unique product identifier; data uses open standards and interoperable formats; information should be machine-readable, structured, searchable and transferable where appropriate; and access is governed according to applicable rights. [2]
For a logistics or ITAD operator, this points toward a technical readiness question: can existing systems preserve relationships between manufacturer identifiers, serial numbers, custody records, condition records and disposition outcomes without replacing external identity with an internal-only identifier? That is a recommended readiness test, not an EU-prescribed IT implementation procedure.
5. Why DPP Matters to Logistics
Logistics companies operate at many of the points where products change location, custody and system of record. The European Commission identifies traceability and transparency across value chains, improved accessibility and interoperability of product data, and better supply-chain performance among the expected benefits of DPP. [1][9]
For logistics, the practical significance is that product movement may increasingly involve products linked to persistent digital identifiers and structured product information accessible through the DPP framework. A covered product can be linked through a data carrier to a unique product identifier, while the applicable product rules determine the required information, access rights and whether the DPP operates at model, batch or individual-item level. [2]
| Logistics touchpoint | Why DPP may matter |
| Inbound receiving | The data carrier and product identifier may provide access to permitted product information and help receiving operations refer to the same product identity used upstream. |
| Warehousing and distribution | DPP can support product traceability across value chains, while product-specific rules determine what information is available and to whom. [1] |
| Returns and reverse logistics | Returned products may enter repair, refurbishment, reuse, remanufacturing, resale or recycling flows. The regulatory treatment of those activities can differ, reinforcing the importance of maintaining reliable product identity through reverse-logistics processes. [2] |
| Cross-border movement | For covered imported products, the DPP Registry supports customs verification of DPP registration; the precise requirements depend on the applicable product legislation. [8][9] |
| ITAD and downstream disposition | Logistics often connects the original owner with ITADs, refurbishers, resellers and recyclers, each of which may use different systems and identifiers. |
DPP does not make every carrier, warehouse operator or transport provider responsible for creating a passport. Responsibility depends on the product legislation and the role the organization performs. The Commission states that relevant economic operators can include manufacturers, importers, authorized representatives, distributors, dealers and fulfilment service providers; in general, primary responsibility for DPP creation and accuracy rests with the relevant economic operator placing the covered product on the EU market, subject to the applicable product legislation. [9]
Logistics companies should therefore distinguish between two questions: whether the company performs a regulated economic-operator role, and whether its operational processes preserve the relationship between the physical product, its data carrier and externally meaningful identifiers. The first is a legal-role question. The second is an ITADA preparedness recommendation intended to improve product-identity continuity across logistics and downstream workflows; it is not presented as a universal EU requirement.
| LOGISTICS READINESS QUESTION Can receiving, warehousing, transport, returns and reverse-logistics processes preserve the link between the physical product and its externally meaningful identity as the product moves among organizations and systems? This is a recommended readiness test, not an EU-prescribed operating procedure. |
6. Electronics and IT Assets
The Commission’s current indicative ESPR timeline places measures concerning ICT products in 2029. [1][9] This is not a universal 2029 DPP compliance date for all ICT equipment. The applicable scope, DPP requirements, transition period and compliance dates will depend on the measures ultimately adopted.
The relevance to electronics is nevertheless clear. The Commission says DPP information may include repairability, environmental performance, reuse and recycling. [1] These are precisely the issues encountered when technology assets leave their first owner and enter repair, remarketing, reuse or recycling channels.
| ITAD LENS The most useful way for an ITAD to view DPP is as a potential source of structured upstream product information created under applicable regulatory requirements. The opportunity is strongest where the product’s identity remains associated with the physical asset across changes in owner, location, condition and system of record. |
7. The Battery Passport: First Operational Model
Batteries provide the clearest near-term model. The Commission states that certain battery categories are the first product group for which a DPP becomes mandatory. The battery passport is being implemented using the common DPP technical framework established under ESPR, is linked through a QR code, and operates through a decentralized system in which detailed information is maintained by the responsible economic operator. [3]
The Commission identifies information categories that may include battery identification and technical characteristics, manufacturer/economic-operator information, performance and durability, information supporting repair, reuse and recycling, and sustainability/circularity information. [3]
For ITADA members, batteries are important not because battery rules can simply be copied to all electronics, but because they provide the first operational EU model showing how persistent identity, data carriers, structured information and downstream stakeholder access can be combined in a regulatory passport.
The Batteries Regulation also provides an important example of how downstream activity can create new regulatory responsibilities. Economic operators that carry out preparation for reuse, preparation for repurposing, repurposing or remanufacturing and then place the resulting battery on the market or put it into service are treated as manufacturers for purposes of the Regulation. This battery-specific rule should not be generalized to all future DPP-covered electronics, but it demonstrates why downstream operators need to examine whether their activities can change their regulatory role. [4]
8. Repair, Reuse, Refurbishment and Resale
The DPP’s policy logic extends beyond first sale. The Commission expressly identifies repairers and recyclers as intended users and lists support for circular business models, traceability and accessibility/interoperability of product data among DPP benefits. [1]
This creates a natural intersection with ITAD. An ITAD receiving a retired server or network appliance may perform intake identification, diagnostics, data sanitization, component replacement, repair, grading, refurbishment, remarketing, parts harvesting or recycling. Those processes create information that can be valuable to later owners and processors.
EU sources reviewed for this paper do not establish that every such ITAD event must be written back into every future DPP. That will depend on the applicable product rules. ITADA’s strategic observation is that circular-market participants can benefit when an asset’s identity and trustworthy information remain usable after the first ownership transition.
| LIFECYCLE VIEW OEM / MANUFACTURER -> DISTRIBUTION -> ENTERPRISE USE -> REVERSE LOGISTICS -> ITAD INTAKE -> REPAIR / REFURBISHMENT -> RESALE / REDEPLOYMENT -> RECYCLING |
9. Where ISO 20435 and OBADA Fit
As of 19 October 2026, ISO listed ISO 20435, “Framework for representing physical assets using tokens,” at stage 60.00, “International Standard under publication,” while its overall status remained “under development.” It should not yet be described as a published International Standard. [5] The ISO draft’s table of contents expressly includes “Use case – digital product passport (DPP),” a decentralized-identifier registry framework, and resolution of a DID across multiple independent DID registries. [6]
According to OBADA’s published description of its standards work, the intended purpose is to create a DLT-agnostic approach for representing physical assets and to support management and interoperability across supply-chain and enterprise systems using verifiable digital information. [7] OBADA is an industry and standards-proponent source; ISO materials are the primary source for the standard’s formal status and published scope.
This creates a potentially useful conceptual fit with the downstream DPP problem. EU DPP rules define regulatory requirements for product information, identifiers and access. ISO 20435 may address a complementary interoperability question: how independent systems represent the same physical asset and resolve identity across registries. The reviewed sources do not establish that ISO 20435 satisfies ESPR Articles 10 and 11, is incorporated into the EU DPP Registry architecture, or is an ESPR harmonized standard. Separate European harmonized DPP standards have already been cited under Commission Implementing Decision (EU) 2026/1736. Conformity with those cited standards creates a presumption of conformity with the corresponding ESPR Articles 10 and 11 requirements covered by them. [10]
| RECOMMENDED ITADA POSITION Do not claim that ISO 20435/OBADA is an EU-mandated or ESPR-harmonized DPP standard. Position it as a potentially complementary framework for physical-asset identity and cross-system interoperability, subject to validation against adopted EU DPP requirements and harmonized standards. | ||
10. Strategic Implications by Industry Role
ITADA PREPAREDNESS RECOMMENDATIONS — NOT UNIVERSAL DPP REQUIREMENTS
Logistics and reverse logistics: Evaluate processes for preserving the connection between a physical asset and external identifiers as products move, return and change custody.
ITAD providers: Treat DPP as a potential upstream information source and assess how downstream condition and disposition records could remain associated with persistent asset identity.
Refurbishers and repairers: Prepare for more structured repairability and lifecycle information while monitoring which product rules, if any, require downstream updates.
Secondary-market resellers: Persistent identity and reliable product information can support transparency across ownership transitions.
Recyclers: DPP is expressly intended to improve access to product information relevant to recycling and circularity. [1]
ITAD software providers: Consider support for external identifiers and interoperable exchange rather than assuming an internal asset ID will always be the only durable identity.
11. Recommended Actions for ITADA and Its Members
| Action | Purpose | |
| 1 | Establish a DPP regulatory watch | Track the European Commission DPP pages, product-specific delegated acts and battery implementation rather than relying on a single predicted deadline. |
| 2 | Map asset identity across systems | Document how OEM identifiers, serial numbers and internal asset IDs survive receiving, warehousing, ITAD intake, refurbishment, resale and recycling. |
| 3 | Inventory lifecycle data already created | Identify condition, testing, repair, sanitization, grading, resale and recycling records that could become valuable in an interoperable lifecycle record. |
| 4 | Protect identifier continuity | Avoid processes that sever the link between the physical item and externally meaningful identity when equipment is relabeled, reconfigured or transferred. |
| 5 | Test interoperability use cases | Use real multi-party workflows involving an OEM or owner, logistics provider, ITAD/refurbisher and downstream buyer or recycler. |
| 6 | Position ISO 20435 carefully | Promote it as a potential cross-system physical-asset interoperability framework while clearly distinguishing it from EU compliance requirements. |
| 7 | Engage in the standards conversation | Represent the operational realities of reuse, refurbishment, resale and recycling so that downstream asset lifecycles are not treated as an afterthought. |
Conclusion
The EU Digital Product Passport is more consequential to logistics and ITAD than a conventional environmental label. It establishes a framework in which covered physical products are connected to persistent digital identifiers and interoperable product information, with access determined by applicable law and stakeholder role. [1][2]
For the downstream technology market, the challenge is maintaining continuity when the product leaves the systems and control of its original manufacturer and owner. That is where ITAD, logistics, repair, refurbishment, reuse, resale and recycling become central to the discussion.
ISO 20435/OBADA does not replace the EU DPP framework and should not be represented as an EU-mandated or ESPR-harmonized DPP standard. Its potential strategic relevance is different: the draft addresses representation of physical assets, decentralized identifiers and identity resolution across independent registries and systems. [5][6] OBADA’s broader interoperability positioning is an industry-proponent interpretation. [7]
| THE STRATEGIC QUESTION FOR ITADA Can the industry develop and validate an interoperability approach that helps the identity and useful lifecycle information associated with a technology asset remain usable across organizational and system boundaries, from manufacture through logistics, enterprise use, ITAD, refurbishment, resale and recycling? If so, DPP could become an important use case for ITADA’s broader standards strategy. |
Referenced Sources
1. European Commission, Digital Product Passport. Open source
2. Regulation (EU) 2024/1781, Ecodesign for Sustainable Products Regulation (ESPR). Open source
3. European Commission, Digital Product Passport for Batteries. Open source
4. Regulation (EU) 2023/1542 concerning batteries and waste batteries. Open source
5. ISO, ISO 20435 – Framework for representing physical assets using tokens. Open source
6. ISO Online Browsing Platform search result for ISO/DIS 20435, draft table of contents (accessed 19 October 2026). Open ISO OBP; locate ISO/DIS 20435
7. OBADA Foundation, ISO 20435 Standard. Open source
8. European Commission, The DPP Registry. Open source
9. European Commission, DPP for Economic Operators. Open source
10. Commission Implementing Decision (EU) 2026/1736 on harmonised standards for digital product passports. Open source
11. Commission Implementing Regulation (EU) 2026/1778 laying down implementation arrangements for the DPP Registry. Open source
Additional Resources
CIRPASS-2, Digital Product Passport research, pilots and project results. Open source
European Commission, DPP Resources and Documentation. Open source
Note: This briefing is an industry analysis, not legal advice. Product-specific DPP obligations depend on the applicable EU legislation and delegated acts in force for the relevant product category and date.