How to Create a DPP: Step-by-Step Guide for Manufacturers
Step-by-step guide to creating a Digital Product Passport. From GTIN registration to QR code labels. ESPR compliance for manufacturers and importers.
From Zero to Compliant: Your DPP Implementation Roadmap
You know what a Digital Product Passport (DPP) is. You understand the penalties for non-compliance. Now it’s time for the practical part: how do you actually create one?
This step-by-step guide walks you through the entire DPP implementation process — from registering your first product identifier to printing QR codes on labels. Whether you’re a manufacturer, importer, or brand owner placing products on the EU market, these steps apply to you.
Before You Start: What You Need
Before creating your first DPP, make sure you have:
- ✅ Your product catalogue — a list of all SKUs (stock keeping units) you sell on the EU market
- ✅ Product data — material composition, origin, sustainability certifications, care instructions
- ✅ Company data — legal entity name, EU address, VAT number
- ✅ Budget for GS1 membership — varies by country, typically €50–300/year for SMEs
- ✅ Access to packaging/label design files — you’ll need to add QR codes
Don’t worry if your product data isn’t perfect yet — the guide shows you how to gather and organise it step by step.
Step 1: Register with GS1 and Obtain GTINs
The Global Trade Item Number (GTIN) is the product identifier explicitly referenced in ESPR Annex III (via ISO/IEC 15459-6). It’s the same numbering system behind every barcode you see in retail — and in the context of DPP, it serves as the unique anchor linking your physical product to its digital passport.
⚠️ Regulatory note: The ESPR references GTIN via the ISO/IEC 15459 standard series, with an “or equivalent” clause. While the final technical specifications for DPP identifiers and data carriers are still being developed (through harmonised standards and Commission implementing acts), GTIN is the most widely adopted identifier globally and is explicitly named in Annex III. Registering with GS1 now is a practical, low-risk step for DPP readiness.
What is a GTIN?
A GTIN is a globally unique numeric code that identifies your product. It comes in several formats:
| Format | Digits | Use case |
|---|---|---|
| GTIN-13 (EAN) | 13 | Most common in Europe — consumer products |
| GTIN-14 | 14 | Outer cases, shipping cartons |
| GTIN-12 (UPC) | 12 | Common in North America |
| GTIN-8 | 8 | Small products with limited label space |
For DPP purposes, GTIN-13 is the standard choice for most EU manufacturers.
How to get GTINs
- Find your national GS1 office — visit gs1.org/contact and select your country
- Apply for a GS1 Company Prefix — this is your unique company code (typically 7–10 digits)
- Assign GTINs to your products — you combine your prefix with product-specific numbers
- Verify your GTINs — use Verified by GS1 to check validity
How many GTINs do you need?
The ESPR and its delegated acts define three possible levels of DPP granularity:
| Level | GTIN scope | When to use | Example |
|---|---|---|---|
| Model | 1 GTIN per product model | Default for most categories | ”Blue cotton t-shirt, size M” |
| Batch | 1 GTIN + batch/lot number | When required by delegated act | ”Production batch March 2026” |
| Item | 1 GTIN + serial number | Required for batteries (Art. 77 Battery Regulation) | “Battery unit SN-2026-04817” |
Key ESPR reference: Article 9(1) states that the DPP shall be linked to a “unique product identifier” — ESPR Annex III references GTIN (via ISO/IEC 15459-6) as one of the conformant identifiers. For most product categories, this will be at model level. The Battery Regulation (EU) 2023/1542, Article 77, specifically requires item-level DPPs for each individual battery.
💡 Tip: If you already sell through retailers or on Amazon, you likely already have GTINs (EAN codes). Check your existing barcodes — you may be closer to DPP readiness than you think.
Step 2: Gather Your Product Data
The DPP is only as good as the data behind it. The ESPR framework (Articles 9–12) and product-specific delegated acts define what information must be included.
Universal DPP data fields (all product categories)
Based on ESPR Annex III and the framework regulation, every DPP must contain:
| Category | Required data | Where to find it |
|---|---|---|
| Product identity | Product name, model, GTIN, manufacturer name and address | Your product catalogue |
| Legal compliance | EU Declaration of Conformity, CE marking reference | Your compliance department |
| Manufacturer info | Legal name, registered address, contact details | Company registration |
| Place of manufacture | Country and, where applicable, facility | Production records |
| Product composition | Materials and substances (by percentage) | Bill of Materials (BOM) |
| Sustainability | Carbon footprint, recycled content %, environmental certifications | LCA data, supplier certificates |
| Circularity | Recyclability score, disassembly instructions, end-of-life guidance | Product engineering team |
| Durability | Expected lifespan, warranty information | Product specifications |
Category-specific additional fields
Each delegated act adds category-specific requirements. Here are the key ones:
🔋 Batteries (mandatory from Feb 2027):
- State of health (SoH) data — capacity, internal resistance, remaining cycles
- Carbon footprint declaration per kWh
- Recycled cobalt, lithium, nickel, and lead content (%)
- Due diligence report on raw materials (supply chain)
- Collection and recycling information with responsible operator
🧵 Textiles (delegated acts expected ~2028):
- Fibre composition with exact percentages
- Country of each manufacturing step (spinning, weaving, dyeing, assembly)
- Presence of microplastic-releasing fibres
- Care and repair instructions
- Durability testing results (pilling, colour fastness, dimensional change)
🪑 Furniture (DPP expected ~2030):
- Wood species and certification (FSC, PEFC)
- Formaldehyde emission class
- Durability and structural test results
- Disassembly instructions for recycling
- Flame retardant information
🏗️ Iron, Steel & Aluminium (DPP expected ~2029):
- Carbon footprint per tonne (Scope 1, 2, and 3)
- Recycled content percentage
- Origin of raw materials
- CBAM-relevant data (Carbon Border Adjustment Mechanism alignment)
- Alloy composition and grade
How to organise your data
Most manufacturers already have 60–80% of the required data scattered across different departments. The challenge is consolidation:
- Create a DPP data template — one spreadsheet per product category with all required fields
- Assign data owners — who in your organisation is responsible for each data point?
- Identify gaps — which fields are empty? What data needs to be collected from suppliers?
- Set a data collection timeline — start with your earliest-deadline products
- Establish a supplier data workflow — send standardised data requests to your material suppliers
💡 Tip: Don’t aim for perfection on day one. Create your DPP with the data you have, then iteratively improve it. A DPP with 90% of required data is infinitely better than no DPP at all — and platform tools like OriginPass help you identify exactly which fields are missing.
Step 3: Choose a DPP Platform
You need software to create, host, and manage your Digital Product Passports. The ESPR doesn’t mandate a specific platform, but the technical requirements (Articles 10–12) effectively require a system that can:
- ✅ Store structured product data in a machine-readable format
- ✅ Generate unique product URLs in GS1 Digital Link format for each product
- ✅ Serve DPP data via an accessible web endpoint (URL)
- ✅ Produce scannable QR codes meeting ISO/IEC 18004
- ✅ Support multiple languages (the DPP must be available in the language of the Member State where the product is sold)
- ✅ Provide role-based access (different data for consumers, authorities, recyclers)
- ✅ Maintain data for the product’s entire lifecycle (including after end of production)
Platform options
| Option | Pros | Cons | Best for |
|---|---|---|---|
| Self-service SaaS platform (e.g., OriginPass) | Fast setup, low cost, automatic compliance updates | Less customisation | SMEs, brands with fewer than 10,000 SKUs |
| Enterprise DPP solution | Full customisation, ERP integration, API access | High cost, long implementation | Large manufacturers, 10,000+ SKUs |
| Custom development | Complete control | Extremely expensive, regulatory risk | Only if you have a dedicated compliance IT team |
| Industry consortium | Shared costs, sector-specific features | Slower rollout, less flexibility | Trade associations |
What to look for in a DPP platform
- GS1 Digital Link support — the platform should generate URLs in GS1 Digital Link format
- Delegated act coverage — does it support your product category’s specific data requirements?
- Multi-language support — the platform should support the languages required in the markets where you sell
- Data export/portability — you must be able to export your data (avoid vendor lock-in)
- Uptime guarantee — if the DPP endpoint goes down, your products are technically non-compliant
- GDPR compliance — the platform processes product data that may include supply chain information
Step 4: Create Your First Digital Product Passport
With GTINs registered, data gathered, and platform chosen — it’s time to create your first DPP.
The process (using a self-service platform)
- Log in to your DPP platform and create a new product
- Enter or import your GTIN — the platform links this to a GS1 Digital Link URL
- Fill in product data — use the category-specific template
- Upload supporting documents — certificates, test reports, Declaration of Conformity
- Set access levels — define what consumers, authorities, and recyclers can see
- Preview the DPP — verify all data is displayed correctly
- Publish — the DPP goes live at its unique URL
The GS1 Digital Link URL
When you create a DPP, the platform generates a unique URL. The leading approach follows the GS1 Digital Link standard — a URL syntax standard that defines how product identifiers (e.g. GTIN) should be structured within a web address (syntax v1.6.0, April 2025). This URL is what gets encoded in the QR code:
https://dpp.example.com/01/05901234123457Breaking this down:
https://dpp.example.com— the resolver domain (your DPP platform)/01/— GS1 Application Identifier for GTIN05901234123457— your product’s GTIN (zero-padded to 14 digits in the URL)
For batch-level DPPs, the URL includes the lot number:
https://dpp.example.com/01/05901234123457/10/BATCH2026-03For item-level DPPs (batteries), it includes the serial number:
https://dpp.example.com/01/05901234123457/21/SN-2026-04817How it works: The QR code always encodes the same URL. The resolver server at that URL determines what content to return based on HTTP request headers — a mechanism called content negotiation. A consumer scanning with their phone sees a human-readable HTML passport page. An authority’s automated system, sending a machine-readable request, receives structured JSON-LD data. This logic is handled by the GS1-Conformant Resolver standard (v1.2.0, January 2026).
⚠️ Note: The ESPR does not mandate GS1 Digital Link by name. However, the GS1 Digital Link URI syntax (v1.6.0, April 2025) and GS1-Conformant Resolver standard (v1.2.0, January 2026) are widely expected to form the basis of future harmonised standards. Most DPP platform providers are building on GS1 Digital Link to ensure forward compatibility.
Step 5: Generate and Apply QR Codes
The QR code is the physical bridge between your product and its digital passport. ESPR Article 11 defines the requirements for the “data carrier” — the scannable element on the product.
QR code technical requirements
| Requirement | Specification | ESPR reference |
|---|---|---|
| Symbology | QR Code (ISO/IEC 18004) or Data Matrix (ISO/IEC 16022) | Art. 11(1) |
| Content | URL with unique product identifier (GS1 Digital Link syntax) | Art. 10 + Art. 11 |
| Error correction | Level M (15%) or higher recommended | GS1 best practice |
| Minimum size | Must be scannable from reasonable distance; minimum 10×10 mm recommended | Art. 11(4) |
| Durability | Must remain scannable throughout product’s expected lifetime | Art. 11(4) |
| Placement | On the product, packaging, or accompanying documentation | Art. 11(3) |
| Human-readable | GTIN must be printed in human-readable form near the QR code | GS1 standard |
Design best practices
- Contrast — dark modules on light background; avoid colour QR codes for reliability
- Quiet zone — leave at least 4 modules of white space around the QR code
- Testing — scan the QR code with at least 3 different smartphone models before printing
- Material — for textiles, consider woven labels with QR; for batteries, laser-etched or high-durability print
- Placement — visible without opening packaging; adjacent to existing barcodes where possible
Integrating QR into your label workflow
Most DPP platforms provide QR codes in multiple formats:
- SVG — scalable vector for print design software (Adobe Illustrator, Figma)
- PNG — raster format for web and digital use (300+ DPI for print)
- PDF — ready-to-print templates for label printers
- ZPL — Zebra Programming Language for industrial thermal printers
- API — automated QR generation for integration with your ERP/PLM system
💡 Tip: Don’t wait until your packaging is redesigned. Many manufacturers start with a sticker phase — printing QR code stickers that can be applied to existing packaging while a full redesign is planned. This is a valid compliance approach and gets you started immediately.
Step 6: Test the End-to-End Flow
Before going live with your DPP, conduct thorough testing:
Testing checklist
| Test | What to verify | Tool |
|---|---|---|
| QR scan test | QR code resolves to correct DPP URL | 3+ smartphone models |
| Data completeness | All required fields are populated | Platform validation or ESPR checklist |
| Language test | DPP displays correctly in all relevant EU languages | Manual check |
| Machine readability | Structured data (JSON-LD) is accessible for authorities | Schema validator tool |
| Load test | DPP endpoint responds within 3 seconds | Browser dev tools |
| Offline QR | QR code scans correctly on printed labels (not just screens) | Printed sample |
| Resolver test | GS1 Digital Link resolver correctly redirects based on user agent | GS1 resolver test tools |
Common pitfalls to avoid
- QR too small — printed QR codes below 10mm often fail to scan, especially on curved surfaces
- Dynamic URLs — don’t hardcode session-specific URLs; use permanent GS1 Digital Link URLs
- Missing GTIN — the human-readable GTIN must be visible near the QR code
- Stale data — verify the live DPP reflects your latest product data, not a cached version
- Single language — if you sell in France, Germany, and Spain, your DPP must be accessible in French, German, and Spanish
Step 7: Prepare for the EU DPP Registry
ESPR Article 12 establishes an EU-level DPP Registry, but its exact data scope and technical architecture are still being specified by the Commission. The safe reading today is that the registry will cover at least product identifiers and other elements defined later in implementing acts and technical specifications.
What the registry will require
Based on the ESPR text and the Commission’s technical preparation, manufacturers should expect at least:
- Registration of the product identifier and core metadata — the final scope will be defined by the Commission
- Interoperability requirements — identifiers and data structures will need to follow common technical schemas
- Update workflows — significant DPP changes will likely need to be synchronised with EU infrastructure
- Additional technical rules — full integration requirements are still to be published
What to do now
While the registry infrastructure is being built:
- Ensure your DPP platform supports registry integration — ask your platform provider about their registry readiness
- Follow the Commission’s implementation updates — via the Ecodesign Forum
- Maintain clean, structured data — registry submission will be automated, so your data must be machine-readable from day one
Step 8: Train Your Team and Establish Processes
DPP is not a one-off project — it’s an ongoing compliance obligation. Set up the right processes now:
Who needs training?
| Role | What they need to know |
|---|---|
| Product managers | How to fill in DPP data, what each field means, where to source data |
| Quality/Compliance | ESPR requirements, delegated act specifics, audit preparation |
| Procurement | How to request DPP-relevant data from suppliers (materials, certifications) |
| Label/Packaging design | QR code placement, sizing, print specifications |
| IT/ERP | Platform integration, data sync, API connections |
| Customer service | How to explain DPP to customers and B2B partners |
Ongoing processes to establish
- New product launch → DPP must be created before the product is placed on the EU market
- Product change → any change in composition, sourcing, or certifications triggers a DPP update
- Annual review → review all DPPs for accuracy at least once per year
- Supplier onboarding → include DPP data requirements in supplier contracts and onboarding checklists
- Regulatory monitoring → assign someone to track delegated act updates and Commission publications
Step 9: Scale to Your Full Catalogue
Once your first DPP is live and tested, scale systematically:
Prioritisation strategy
- Start with your highest-risk products — closest deadline, highest volume, or products sold in the most EU markets
- Then your highest-value products — flagship products where DPP also adds marketing value
- Then long-tail SKUs — use bulk import/template features in your platform for efficiency
- Finally, custom/made-to-order products — these may need batch-level or item-level DPPs
Scaling tips
- Bulk CSV/Excel import — most platforms support importing hundreds of products at once
- ERP integration — connect your enterprise system to auto-populate DPP fields
- Template products — create one DPP per product family, then clone and adjust per variant
- Supplier portal — invite suppliers to input their data directly into your DPP platform
Timeline: When to Do What
Here’s a realistic implementation timeline mapped to ESPR deadlines:
| If your deadline is… | Start DPP project by… | GTINs ready by… | First DPP live by… |
|---|---|---|---|
| Feb 2027 (battery categories covered by battery passport rules) | ⚠️ NOW | Already done | Q3 2026 |
| ~2028 (textiles) | Q2 2026 | Q4 2026 | Q2 2027 |
| ~2029 (iron/steel) | Q1 2027 | Q3 2027 | Q1 2028 |
| Jan 2030 (furniture) | Q2 2027 | Q4 2027 | Q2 2028 |
🔴 Critical: If your products fall within the battery passport scope of Regulation (EU) 2023/1542, your implementation window is closing. Don’t underestimate the time needed for GS1 registration (2–4 weeks), supplier data collection (2–3 months), and label redesign (1–2 months). Start now on OriginPass — the free plan covers everything you need to begin.
Cost Overview
A realistic cost breakdown for DPP implementation:
| Cost item | Range | Notes |
|---|---|---|
| GS1 membership + GTINs | €50–500/year | Depends on country and company size |
| DPP platform (SaaS) | €0–200/month | Free plans available for small catalogues |
| Label redesign/printing | €200–5,000 | One-time; depends on number of SKUs |
| Data collection/LCA | €500–10,000 | If you need external sustainability assessments |
| Staff training | €0–2,000 | In-house or workshop-based |
| Total (typical SME) | €1,000–15,000 | One-time setup + ongoing platform fee |
Compare this to the potential penalties for non-compliance: fines starting at €10,000 for moderate violations, product withdrawal costs, and lost revenue. DPP compliance is the rational economic choice.
Official Sources
- ESPR Regulation (EU) 2024/1781
- Battery Regulation (EU) 2023/1542
- European Commission ESPR Working Plan 2025–2030
- Ecodesign / Green Forum implementation updates
Quick Reference: The 9-Step DPP Checklist
| Step | Action | Status |
|---|---|---|
| 1️⃣ | Register with GS1, obtain GTINs | ☐ |
| 2️⃣ | Gather product data (composition, sustainability, lifecycle) | ☐ |
| 3️⃣ | Choose a DPP platform | ☐ |
| 4️⃣ | Create your first DPP | ☐ |
| 5️⃣ | Generate and apply QR codes to labels | ☐ |
| 6️⃣ | Test end-to-end (scan → view → verify) | ☐ |
| 7️⃣ | Prepare for EU DPP Registry | ☐ |
| 8️⃣ | Train your team and establish processes | ☐ |
| 9️⃣ | Scale to full product catalogue | ☐ |
Ready to create your first Digital Product Passport? Start free on OriginPass.eu — generate compliant DPPs with QR codes in minutes. No credit card required.