Your packaging data is already most of the DPP
The Digital Product Passport comes from the Ecodesign Regulation (EU) 2024/1781, and packaging is not a product group in its scope - so there is no packaging DPP deadline to work to. What is coming for packaging is the PPWR Article 12 data carrier, from 12 August 2028. Both draw on the same component data, and if you are already managing it for EPR the work is a mapping, not a rebuild.
What the DPP is, and what PPWR asks for
A Digital Product Passport is a structured, machine-readable data set reached through a data carrier - a QR code in practice. Under the Ecodesign Regulation it attaches to designated product groups, and packaging is not one of them. PPWR's own digital requirement is the Article 12 data carrier behind the harmonised label, which from 12 August 2028 resolves to:
- Material composition (mapped to PP01-PP12)
- Recyclability assessment and grade
- Recycled content percentage
- Reuse information where applicable
- Sorting instructions (harmonised sorting label)
The PPWR labelling implementing acts, which will specify the label and the digital material identification methodology, were due by 12 August 2026 and have not been adopted. The fields are knowable now; the exact machine-readable format is not yet locked.
How Merchant Packaging gets you there
Merchant Packaging already captures and structures the data either route needs:
- Material composition at component level, coded to PP01-PP12
- Recyclability assessment per component
- Recycled content as a nullable value, distinguishing "not recorded" from "zero"
- Sorting label derived from component attributes (Article 12)
- All data exposed via JSON API
When the implementing acts specify the label and its data carrier, we will map our existing API output to the mandated format and support QR code generation. The underlying data is already there.
Why the data is worth having now
There is no packaging DPP deadline, and we are not going to invent one. The dated obligation is the PPWR Article 12 data carrier on 12 August 2028, and the ESPR passport reaches your packaging only if your products are themselves in an ESPR product group. Either way the requirement is accurate, structured, component-level packaging data - and that is the part that takes months rather than weeks.
So the argument for acting now is not a countdown. It is that the same component records answer your EPR declarations today, the Article 12 carrier in 2028, and a product passport if one ever reaches your packaging - and you only build them once.
One data set, every digital requirement
Tell us what you report now and we will show you how much of a Digital Product Passport it already covers.
Southampton SO14 3TG, UK