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Comparison guide

You have EPDs. That does not make you DPP-compliant.

If your products already carry Environmental Product Declarations, it is tempting to assume the Digital Product Passport is more of the same paperwork under a new name. It is not. An EPD is a voluntary, third-party-verified report on environmental impacts, built on a life-cycle assessment. A DPP is a mandatory, machine-readable regulatory record required by EU law, product group by product group. They answer different questions for different audiences — and the good news is that your EPD work gives you a genuine head start on the passport.

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In one line: an EPD is a voluntary environmental disclosure verified by a third party; a DPP is a mandatory regulatory data record under EU law — an EPD can serve as evidence inside a DPP, but it can never replace one.

What an EPD is — and what it is not

An Environmental Product Declaration is a Type III environmental declaration under ISO 14025: a standardised report of a product's environmental impacts across its life cycle, derived from a life-cycle assessment (LCA) and verified by an independent third party. In construction — where EPDs are most established — they follow EN 15804, are published through programme operators, and are routinely requested in procurement and green-building assessments.

What an EPD is not: a compliance record. It is largely a market-driven instrument — you produce one because buyers, tenders or certification schemes ask for it. It typically describes a product type or family rather than identifying individual items, it is a document rather than a structured machine-readable dataset, and it is not carried on the product by a regulated data carrier. Nothing in an EPD registers you with an EU authority or satisfies a legal placing-on-the-market condition.

What the DPP is

The Digital Product Passport is a regulatory data record created by the Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781, in force since July 2024). There is no single go-live date: obligations phase in per product group through delegated acts, with company duties biting roughly 18 months after a delegated act enters into force. The first working plan (April 2025) prioritises textiles, furniture including mattresses, and tyres as final products, plus iron & steel and aluminium as intermediates.

Structurally, a DPP is the opposite of a PDF report: a machine-readable record with content defined by law, carried on the product via a GS1 Digital Link QR code or Data Matrix, registered in the EU DPP Registry (open for registration from 19 July 2026), and kept accessible for the product's regulated lifetime. Once the delegated act for your product group applies, a product without a compliant passport cannot lawfully be placed on the EU market. Batteries have their own parallel regime under Regulation (EU) 2023/1542, mandatory from 18 February 2027 for EV, LMT and larger industrial batteries.

Side by side

How they work together

The instruments are complementary, and the direction of travel is clear: an EPD is excellent evidence inside a DPP. The LCA behind your EPD is exactly the kind of verified source material that environmental data points in a passport should draw on, and the discipline of maintaining EPDs means your data collection is already half-organised.

Two notes for construction specifically. First, construction products get their own passport regime: the revised Construction Products Regulation introduces a digital product passport for construction products alongside ESPR — see our construction products guide. Second, the ESPR working plan targets iron & steel and aluminium as intermediates, so upstream suppliers to construction are in the first wave regardless. PassPer's AI extraction reads the documents you already hold — EPDs, LCA reports, certificates, supplier declarations — and maps them into the passport structure with human review, so EPD-mature manufacturers start from strength, not from zero.

Frequently asked questions

We have EPDs for our whole range. Do we still need a DPP?
Yes, if and when your product group is covered by a delegated act under the ESPR (or by the Batteries Regulation). An EPD is a voluntary environmental declaration; the DPP is a legal condition for placing the product on the EU market. Your EPDs do not exempt you — but they are strong source material for the passport's environmental fields.
Can we reuse our EPD and LCA data in the passport?
Largely yes. The LCA behind an EPD is verified, structured environmental data — exactly what passport fields on environmental performance should be built from. The exact fields depend on your product group's delegated act, but EPD holders typically have far less new data to gather than manufacturers starting cold.
Will the DPP replace EPDs?
No. EPDs remain the instrument procurement teams and green-building schemes ask for, with third-party verification the DPP does not provide in the same way. Expect to maintain both: the EPD for market demand, the DPP for legal market access — with the EPD feeding the DPP rather than competing with it.
We manufacture construction products. Which passport rules apply to us?
Potentially two regimes: the revised Construction Products Regulation introduces its own digital product passport for construction products, and the ESPR covers intermediates such as iron & steel and aluminium in its first working plan. Which applies to a given product depends on how it is classified — worth checking early, because the data preparation overlaps heavily.

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