The Digital Product Passport (DPP) is one of the most discussed - and most misunderstood - topics in packaging compliance. A good deal of what is said about it attaches the DPP to the Packaging and Packaging Waste Regulation, and that is not where it comes from. Getting the legal basis right matters, because it changes which deadline you are actually working to.
Where the DPP comes from, and whether packaging is in scope
The Digital Product Passport is created by the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781. It is not a PPWR instrument. ESPR sets the framework and then applies it to specific product groups through delegated acts, each of which sets its own data requirements and its own dates.
Packaging is not one of those product groups. There is currently no DPP obligation on packaging as such, and no date on which one starts. Anyone quoting you a firm DPP deadline for packaging is quoting something that does not exist yet.
Where packaging and the DPP do meet is indirect but real. If you sell a product that falls within an ESPR product group, that product will need a DPP, and the information it carries can include information about the packaging it is sold in. So the question is not "when does packaging need a DPP", it is "are my products in ESPR scope, and will their passports need to describe my packaging".
What PPWR requires instead
PPWR has its own digital requirement, and this is the one with a date attached. Article 12 requires packaging placed on the EU market to carry a harmonised label, and that label carries a data carrier - a QR code in practice - resolving to information about the packaging.
It applies from 12 August 2028, or 24 months after the labelling implementing acts enter force, whichever is later. Those implementing acts were due by 12 August 2026 and have not been adopted, so the date is firm in the regulation but the runway depends on when the specifications land.
The information behind the carrier is what a DPP would carry for packaging in all but name:
- Material composition mapped to the PP01-PP12 coding system
- Recyclability assessment and grade
- Recycled content percentage
- Substances of concern
- Reuse information where applicable
- Sorting instructions - the harmonised sorting label (Article 12)
Neither one is a new data capture exercise
This is the part worth holding on to, and it is true whichever obligation catches you first. Both the PPWR data carrier and a product DPP that describes its packaging are outputs from data you already need for something else.
Consider what either would carry: material composition, which you need for EPR declarations and the PPWR Declaration of Conformity; recyclability assessment, which you need for eco-modulated fees; recycled content, which you need for Plastic Packaging Tax and the Article 7 targets; and the sorting label, which is derived from your component attributes under Article 12.
If your packaging data is already structured at component level with material codes, weights, recyclability assessments and recycled content figures, you already hold the substance of it. What is left is a mapping and a carrier, not a collection exercise.
The technical shape of it
Beyond the data itself, a digital link on packaging has two parts, and a third if an ESPR product passport is in play:
First, the data carrier. This is the physical link - a QR code in most implementations - encoding a URL that resolves to the information. It has to be durable and scannable through the packaging's life.
Second, the endpoint. The URL has to resolve to structured data in whatever format the specifications require. In practice that means a JSON API conforming to a published schema.
Third, and only where an ESPR product group applies, registration in the EU registry that ESPR establishes. That registry went live in 2026, but it serves ESPR product passports - packaging is not registered in it today, and claims that every packaging unit will need a registry entry are getting ahead of the law.
What is still pending
For PPWR, the implementing acts specifying the label and the digital material identification methodology were due by 12 August 2026 and have not been adopted. Until they are, the precise machine-readable schema - field names, enumerated values, the structure behind the QR code - is not locked. The PPWR text and the JRC technical proposals tell you what information is in scope; they do not yet tell you its exact format.
For the DPP, what is pending is more fundamental: whether packaging is ever designated an ESPR product group at all, and if so on what timetable.
Neither is a reason to wait, because neither uncertainty touches the data requirements. The fields are knowable now. A business with structured component data faces a mapping exercise when the schema lands. A business starting from scratch at that point faces the data project and the integration at once.
How Merchant Packaging supports this
Merchant Packaging holds the data either route needs: material composition coded to PP01-PP12, a recyclability grade per component, recycled content with the null-versus-zero distinction preserved, and the sorting label derived from component attributes. All of it is exposed via JSON API.
When the PPWR implementing acts specify the label and its carrier, we will map the existing API output to the mandated format and support QR code generation. If your products fall in an ESPR product group and their passports need to describe your packaging, the same records answer that too. What we will not do is invent a packaging DPP deadline in order to sell against it.