The EU’s Packaging & Packaging Waste Regulation (PPWR) and the Digital Product Passport (DPP) under the ESPR introduce strict requirements for how packaging data must be structured, disclosed, verified, and accessed.
Every packaging product will require a digital passport containing:
accurate composition data
substances of concern
environmental performance
circularity characteristics
supply-chain traceability
evidence for all claims
machine-readable access and versioning
Pickler’s Digital Product Passport is designed around these legal requirements and already follows the expected EU DPP structure.
Below is a complete mapping of how each passport section aligns with PPWR and ESPR obligations.
1. Unique identification and full traceability
Legislation: ESPR, Regulation (EU) 2024/1781, Article 9 & Annex III
The EU requires every product to have a unique digital identity that can be traced throughout its lifecycle. This includes a persistent ID, data holder details, QR-code access, and version history showing when information was last updated.
How Pickler’s Product Passport covers this
Product name & description
Unique Passport ID
Version history & last-updated timestamp
Data holder identity
QR code linking to the live passport
2. Full transparency on what packaging is made of
Legislation:
The EU requires detailed disclosure of packaging composition and substances. This includes all materials and percentages, recycled and biobased content, certified wood, PFAS levels, heavy metals, and other substances of concern. All claims must be backed by verifiable evidence.
How Pickler’s Product Passport covers this
Full material breakdown
Recycled, biobased, and certified wood shares
PFAS and heavy metals
Substances of concern
Evidence attached to every claim
3. Lifecycle-based environmental performance
The EU requires environmental performance information based on a recognised lifecycle methodology. Indicators must reflect the full environmental footprint of the product.
How Pickler’s Product Passport covers this
Total environmental impact (eco-costs)
Carbon footprint
Impact per lifecycle stage
Impact per category (nature, health, scarcity, climate)
Eco-score
ISO 14040/44–aligned, independently verified LCA
4. Clear circularity and end-of-life information
Legislation:
Packaging must disclose its reuse potential, recyclability grade, compostability status, minimisation efforts, and disposal instructions. All circularity-related claims must be supported by evidence.
How Pickler’s Product Passport covers this
Reuse attributes (when applicable)
Recyclability grade
Compostability indicators
Minimisation documentation
Consumer disposal instructions
Evidence badges linked to certificates or test reports
5. Supply-chain and transport traceability
The DPP must include the relevant supply-chain steps behind the environmental performance. This means showing where components are processed and the transport routes involved.
How Pickler’s Product Passport covers this
Processing locations
Transport legs, distances, and modes
End-of-life region
6. Proof and documentation for every claim
Legislation:
Both regulations require that all sustainability-related claims — such as recycled content, absence of substances of concern, certifications, recyclability, or biodegradability — are backed by verifiable documentation.
This documentation must exist and be available on request to customers, auditors, or market authorities.
How Pickler’s Product Passport covers this
Central Evidence & documentation section
Evidence badges inside each relevant passport block
Clear indication that certificates, declarations, lab tests, or recyclability assessments are available from the data holder
7. Clear responsibility for passport data
The passport must show who is responsible for the data and for updating it.
How Pickler’s Product Passport covers this
“About data holder” section with company identity
Company profile and description
Versioning and timestamps
8. Machine-readable access and real-time updates
Legislation: https://eur-lex.europa.eu/eli/reg/2024/1781/oj
The DPP must be accessible via a QR code, structured in a machine-readable format, and always show the most recent version of the data.
How Pickler’s Product Passport covers this
QR code as the passport entry point
Structured, machine-readable data fields
Automatic version updates whenever product data changes
Product passport and evolving legislation
Pickler’s passport already reflects the required structure of the EU DPP and includes all PPWR-required packaging information. However, the EU’s DPP ecosystem is still under development.
Over the next years, the Commission will release:
machine-readable DPP schemas
product-group–specific DPP requirements
harmonised test methods for PFAS, recyclability, and compostability
clearer enforcement and minimisation guidelines
interoperability rules for registries and external systems
Because of this, the main compliance risks relate not to Pickler’s approach but to:
evolving EU requirements
variations in national enforcement
stricter evidence expectations
supplier data quality
future technical interoperability standards
Pickler’s structured and evidence-backed design ensures you are well positioned — but ongoing alignment will be needed as EU legislation continues to mature.