Digital Product Passport (DPP)

A Digital Product Passport (DPP) is a structured digital record linked to a physical product via a unique data carrier (QR code, NFC tag, or RFID chip). When scanned, the carrier retrieves the product's passport data from a connected digital system, giving consumers, repairers, recyclers, and regulators access to information about a product's materials, origin, environmental footprint, and end-of-life instructions. The EU is mandating DPPs under the Ecodesign Regulation (ESPR) as a central mechanism for making product supply chains transparent and for enforcing circularity objectives. The EU Central DPP Registry went live 20 July 2026 (as-of 2026-07-20).

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Legal basis and scope

The governing regulation is Ecodesign Regulation (ESPR) (Regulation (EU) 2024/1781), which entered into force on 18 July 2024 and replaced the energy-only Ecodesign Directive 2009/125/EC. (Inriver, 2026-05; TÜV SÜD webinar, 2025-08-26)

The ESPR is a framework regulation: it mandates DPPs in principle but delegates the specific data requirements, formats, and timelines to per-product-group delegated acts that are still being developed. (Reach Law Talks, 2024-04-26; TÜV SÜD, 2025-08-26) The governing plan for which product groups are tackled and in what order is the ESPR Working Plan 2025–2030, adopted 16 April 2025. (PassportCraft, reviewed 2026-06-16)

Who must comply: The compliance obligation sits with the "economic operator" placing the product on the EU market — typically the manufacturer or importer — regardless of where the company is headquartered. For non-EU brands, the manufacturer or importer targeting EU customers is responsible. (Retraced, updated 2026-04-27; TÜV SÜD, 2025-08-26) A 2025 EU Omnibus simplification package streamlined CSRD and CSDDD obligations but left ESPR/DPP unchanged. (PassportCraft, reviewed 2026-06-16)

Scope: In principle, all physical products placed on the EU market fall under ESPR unless explicitly excluded (food, pharmaceuticals, living organisms are out). (Inriver, 2026-05; Reach Law Talks, 2024-04-26)

Beyond ESPR: Four other EU regulations also mandate DPPs independently:

• Battery Regulation (EU 2023/1542) — EV + LMT batteries + industrial batteries >2 kWh (mandatory from 18 Feb 2027)
• Construction Products Regulation (EU) 2024/3110 — most provisions January 2026
• Critical Raw Materials Act (EU) 2024/1252 — products with permanent magnets, from May 2027
• Toy Safety Regulation (EU) 2025/2509 — August 2030

(PassportCraft, reviewed 2026-06-16)

DPP is not optional — it is enforced via market access: no compliant passport means no EU customs clearance for affected product categories once their deadlines apply. (TylkoTALK, 2026-01-07; EC DPP Registry, 2026-07-20)

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How it works mechanically

Data carrier

The physical product (or its packaging) carries a data carrier — most likely a dynamic QR code, but NFC or RFID are also options under ESPR Article 10. The carrier links to a unique persistent identifier (UID) that resolves to the product's passport data. CEN/CENELEC standard EN 18220:2026 specifies data carrier requirements: symbology, format, error correction codes, encoding methods, printing/production quality, and durability. (PassportCraft, reviewed 2026-06-16; standards.iteh.ai, 2026)

GS1 Digital Link is the globally standardised URL-based QR format that embeds a product's GTIN (/01/<GTIN>) and serial number (/21/) and is recognised by all major EU retail scanning infrastructure. The GS1 Sunrise transition in 2027 means retail checkout infrastructure will begin supporting QR codes at point of sale — enabling a single QR code to serve both retail checkout scanning and DPP data access simultaneously. (Supercode, 2026-03-19; PassportCraft, reviewed 2026-06-16)

Reddit practitioners note that GS1 Digital Link looks like the frontrunner for DPP data carriers but is not mandated, and that GS1 membership and GTIN registration costs create an additional barrier for small brands. (r/sustainability, 2025-01)

Dynamic vs static QR: Dynamic QR codes (where the destination URL can be updated without reprinting labels) are strongly recommended because regulatory data requirements will evolve across the multi-year delegated-act rollout. (Supercode, 2026-03-19)

QR durability concern: Practitioners (r/circulareconomy, 2025-01) note the physical QR code or NFC tag may not survive a garment's lifetime through washing and wear — raising questions about how DPP data reaches recyclers at end-of-life.

Data storage architecture

The DPP system is designed as decentralised: each economic operator manages their own passport data (or delegates to a "DPP Service Provider" — a new regulated actor category formally defined in Commission Implementing Regulation (EU) 2026/1778, Art. 3.f). There is no single central EU database holding passport content; the EU Central DPP Registry (live 20 July 2026) stores only unique identifiers and proof of registration. (Traceable Digital, 2026-07-17; Arianee, 2026; EC DPP Registry, 2026-07-20)

The EC DPP Registry is governed by Commission Implementing Regulation (EU) 2026/1778, adopted 16 July 2026, in force 6 August 2026. Its components: secure website interface; API for registering and retrieving DPPs; verification platform; scheme for generating unique registration identifiers (UIDs); storage for identifiers and customs commodity codes; public list of verified DPP service providers; semantic repository; log system. (Traceable Digital, 2026-07-17)

How the Registry works: Economic operators submit a DPP via the API or UI. The Registry automatically checks semantic conformity, correct granularity (model/batch/item), commodity code validity, and the link to hosted passport data, then issues a unique registration identifier. This automated check is not proof of substantive regulatory compliance — that remains a market-surveillance function. (Traceable Digital, 2026-07-17) The Registry retains proof of registration for 10 years with timestamping under eIDAS guarantees. (Arianee, 2026)

Verification of economic operators: To register a DPP, an operator must first become a "verified economic operator" under Art. 4 via a qualified electronic signature (sole traders) or qualified electronic seal from a qualified trust service provider under eIDAS Regulation EU 910/2014; verified status lasts up to three years before renewal. (Traceable Digital, 2026-07-17)

Battery DPP registration becomes mandatory 18 February 2027 — a separate timeline from the Registry's July 2026 go-live; on that same date, every EU Member State must appoint a national administrator. (Traceable Digital, 2026-07-17; EC DPP hub, 2026-07-17)

DPP Web Portal (separate from the Registry): not yet operational as of July 2026; when live, consumers, businesses, and authorities will be able to search and compare product information. (EC DPP Registry, 2026-07-20)

Data must be structured in open, machine-readable formats (JSON-LD; EPCIS 2.0 for supply chain data exchange) to ensure interoperability and prevent vendor lock-in. (Traceable Digital, 2026-07-17; TylkoTALK, 2026-01-07)

Technical standards

CEN/CENELEC published 6 of 8 harmonised DPP interoperability standards approximately May 2026 — missing an informal March 2026 target by ~2 months; two standards remain in draft. (PassportCraft, reviewed 2026-06-16; EC DPP Registry, 2026-07-20)

Standard	Covers
EN 18216	Unique identifiers
EN 18219	Interoperability requirements
EN 18220:2026	Physical data carriers (QR, NFC) — symbology, format, durability
EN 18221	Data exchange protocols
EN 18222:2026	API specifications — lifecycle management, searchability, security
EN 18223	Data storage requirements
prEN 18239	(draft)
prEN 18246	(draft)

(PassportCraft, 2026-06-16; Arianee, 2026; standards.iteh.ai, 2026)

Three-tier access model

Tier	Who	What they see
Consumer / public	Anyone scanning the QR	Sustainability attributes (durability, recyclability, materials, care)
Business / repair / recycling	Authorised repairers, recyclers	Design, material, dismantling information, spare parts
Regulatory authority	Customs, Commission, notified bodies	Full compliance data, test reports, substances of concern

Some data may be restricted as trade secrets. (TÜV SÜD, 2025-08-26; Retail TouchPoints, 2025-11-26) Companies are addressing IP protection through "data fidelity not data visibility" — sharing only required final metrics without revealing the proprietary calculation methodology. (TylkoTALK, 2026-01-07)

Reddit practitioners note that the access tiering is "technically complex" and "most DPP vendors haven't solved this properly yet" (as-of 2025-05). (r/sustainability, 2025-01)

Item-level vs product-level

The granularity of DPP data — item-level, batch-level, or product-model-level — is set by delegated acts per product group. The Registry supports all three granularity levels and verifies correct granularity during registration. (Traceable Digital, 2026-07-17; Reach Law Talks, 2024-04-26)

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Data requirements

Core data categories expected across product groups (exact fields set by delegated acts, not yet adopted for most groups as-of 2026-07-22):

• Product identification: name, model, batch, manufacturing date, warranty
• Material and component data: raw material origins, responsible sourcing, supplier details
• Sustainability data: carbon footprint, energy use, emissions
• Repair details: repairability information, replacement components, service events
• Substances of concern (broader than REACH SVHC — covers any substance that negatively affects recycling or reuse)
• Unique identifiers for product / operator / manufacturing facility
• Certification information; DPP service provider details

(Inriver, 2026-05; TÜV SÜD, 2025-08-26; Retraced, 2026-04-27)

Textile/apparel DPP — JRC May 2026 specification (consultation closed 26 June 2026, as-of 2026-07-22): The Joint Research Centre published a first DPP content specification for textiles in May 2026, covering 49 data points across 4 categories. This is a JRC proposal feeding the delegated act drafting process — not yet confirmed in a final delegated act. Indicative textile data requirements:

• Fibre composition (primary confirmed field)
• Country of manufacture
• REACH chemical compliance
• Recycled content
• Certifications
• Care and end-of-life instructions
• Phase 2 (indicative): carbon footprint, water consumption

(EC primary citing Carbonfact, 2026; Retraced, 2026-04-27)

Retraced (updated 2026-04-27) notes that repairability, while initially expected as a DPP data field for textiles, has been flagged by the JRC as "not measurable for textiles at this stage" and is unlikely to appear as a standalone requirement.

ESPR establishes scored information disclosures rather than mandatory minimum performance thresholds based on current JRC signals — brands report and evidence sustainability dimensions rather than meet prescribed benchmarks. (Retraced, 2026-04-27)

Battery passport data (mandatory from 18 Feb 2027): minimum recycled content targets (6% recovered lithium/nickel by 2030), carbon footprint per kWh by model and manufacturing plant, real-time battery management system data (state of health, charging cycles), due diligence on cobalt/lithium/nickel with full chain of custody to mine level. (TylkoTALK, 2026-01-07; PassportCraft, reviewed 2026-06-16)

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Timeline (as-of 2026-07-22)

Date	Event	Status
18 Jul 2024	ESPR in force	Done
16 Apr 2025	ESPR Working Plan 2025–2030 adopted (textiles = 2027 priority)	Done
~May 2026	CEN/CENELEC publishes 6 of 8 harmonised DPP standards (EN 18216–18223)	Done
19 Jul 2026	Unsold goods destruction ban on apparel/footwear (large companies)	Done
20 Jul 2026	EU Central DPP Registry goes live (Impl. Reg. 2026/1778)	Done
27 Sep 2026	Empowering Consumers Directive (ECGT) bans unsubstantiated eco-claims	Upcoming
Q4 2026	Iron & Steel ESPR delegated act (indicative, EC primary)	Expected (volatile)
Q2 2027	Construction products + DPP service providers delegated acts (EC primary)	Expected (volatile)
Apr 2027	CIRPASS-2 pilot project concludes (13 pilots incl. textiles)	Expected
18 Feb 2027	Battery DPP mandatory — first legally required DPP	Confirmed
2027	GS1 Sunrise — barcode-to-QR transition reaches critical mass	Expected
Q3–Q4 2027	Textile/apparel delegated act adoption (EC primary, as-of 2026-07-17)	Expected (volatile)
Apr 2028	EU EPR for textiles operational (Extended Producer Responsibility (EPR))	Expected
2028	Furniture delegated act (EC primary, indicative)	Expected (volatile)
Early 2029	Textile DPP compliance (~18mo after Q3-Q4 2027 delegated act)	Indicative
Aug 2030	Toy Safety Regulation DPP mandatory	Confirmed
2030	Advanced textile DPP (EPRS phased recommendation)	Indicative
2033	Fully circular textile DPP (EPRS phased recommendation)	Indicative

(EC DPP hub 2026-07-17 PRIMARY; EC DPP Registry 2026-07-20 PRIMARY; PassportCraft, reviewed 2026-06-16; Inriver, 2026-05)

What has already slipped (as-of 2026-07-22): Battery carbon footprint methodology (due 2024) not yet adopted; battery due diligence delayed from August 2025 to August 2027 via Regulation 2025/1561; DPP service provider requirements (expected late 2025) are still pending after April 2025 consultation. CEN/CENELEC published May 2026, ~2 months after their March 2026 deadline. (PassportCraft, reviewed 2026-06-16)

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Fashion and ecommerce implications

What it means for fashion retailers:

• Apparel and clothing accessories confirmed in-scope under ESPR Working Plan — textile delegated act expected Q3-Q4 2027 with ~18-month compliance window (early 2029)
• Footwear treated separately; sustainability feasibility study expected by end 2027 (as-of 2026-07-22)
• The unsold goods destruction ban (large companies, 19 Jul 2026) is the first near-term ESPR obligation
• JRC May 2026 specification proposes 49 data points for textiles — the most concrete indication to date of what data brands must hold
• All brands placing products on the EU market are in scope, regardless of headquarters location (Retraced, updated 2026-04-27)

EU Empowering Consumers Directive (ECGT, from 27 September 2026): generic environmental claims ("eco-friendly", "green", "sustainable") without substantiation will be banned. DPP data becomes the evidence layer — brands must back all green claims with verified evidence. DPP data that contradicts marketing claims can be used as enforcement evidence. (PassportCraft, 2026-03-02; r/ecommerce, 2024-10)

Marketplace obligations: Online marketplaces must make DPPs accessible to EU customers and provide an interface for market surveillance authorities. DPP data must remain accessible for the product's expected lifetime plus 10 additional years. (TÜV SÜD, 2025-08-26; passtiq, 2026) Retail TouchPoints / Pimberly VP Tim Bodill states that "online platforms may be required to verify that goods carry DPPs" — meaning marketplaces face their own compliance exposure beyond brand-level obligations (as-of 2025-11; qualified — delegated act not yet published). (Retail TouchPoints, 2025-11-26)

GS1 Sunrise 2027: A single QR code on a garment will serve both retail checkout and DPP data access — infrastructure is converging. (PassportCraft, reviewed 2026-06-16)

UK brands: DPP does not apply for UK domestic market sales. EU sales still require compliance. Some UK brands are building one system for EU compliance on the assumption the UK will eventually align. (Stahls' UK & EU, 2026-03-09; r/fashion, 2025-04)

Shein/Temu as market access barrier: DPP is framed by EU MEPs as a de-facto market access barrier for ultra-fast-fashion brands lacking supply chain traceability — the political angle that helps insulate ESPR from rollback. (r/fashion, 2025-04; r/europeanunion, 2024-12)

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Consumer behaviour and UX implications

Active QR code scanning by consumers is "quite low" — the DPP functions better as background assurance: knowing a brand is legally required to be transparent strengthens brand trust even without scanning. (TylkoTALK, 2026-01-07)

A consumer survey on clothing labels found that consumers are twice as likely to care about durability and care instructions as about environmental footprint — the EU built a framework for environmental transparency, but consumers use it primarily to assess longevity. (TylkoTALK, 2026-01-07; volatile, survey methodology not detailed)

Presenting consumers with extensive data (material composition, supply chain maps, water usage, carbon reports) creates decision fatigue and can stop them from buying; brands must tailor DPP communication rather than surface raw data. (TylkoTALK, 2026-01-07)

Three consumer profiles for DPP UX design (TylkoTALK, 2026-01-07):

• Rationalist planner — needs practical facts, repair logs, cost-justification
• Aspirational idealist — needs brand storytelling and values-based emotional connection
• Convenience seeker — needs seamless choices, traffic-light visuals, minimal friction

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Commercial opportunities

Early movers are using DPP as competitive advantage beyond compliance (TylkoTALK, 2026-01-07; volatile, self-reported cases):

• Bergens of Norway (outdoor brand): QR links to repair and rental services specific to that garment's history
• Lok (premium footwear) and Line Rossette (furniture): DPP as digital certificate of provenance to fight counterfeiting
• Fabocus / Tesco: testing "durability gauges" — traffic-light system giving consumers an immediate product quality signal at point of purchase
• EPAM + Institute of Digital Fashion (IoDF): DPP framework launched 2025 going beyond compliance to enable brand storytelling — editorial history, notable individuals who wore a garment, "an authentic brand-customer loop" (EPAM Systems, 2025-10-29)

Bain & Company / eBay (2025-06-25 — gated report): 90% of brands view DPP as a regulatory burden; identified fashion lifetime value doubling potential when DPP data enables authenticated resale. (report-radar, surfaced 2026-07-22)

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Implementation challenges

The hard part is upstream data, not the QR code. Material composition must come from suppliers; carbon footprint requires lifecycle assessment methodology or third-party data; chemical substance declarations require verified supplier documentation. (Supercode, 2026-03-19; Retraced, 2026-04-27)

The core challenge is not a lack of data but a lack of master data — companies rely on disconnected ERPs and siloed spreadsheets. Compliance requires integrating ERP, PLM, and traceability systems. Cross-team alignment (ESG, procurement, IT, compliance) is mandatory. (TylkoTALK, 2026-01-07; Retraced, 2026-04-27)

PIM as compliance infrastructure: PIM (Product Lifecycle Management (PLM)) systems are shifting from marketing tools to essential compliance infrastructure — the foundational data governance layer for DPP compliance. (TylkoTALK, 2026-01-07; Retail TouchPoints, 2025-11-26)

DPP implementation preparation timeline (Retraced recommendation, 2026-04-27):

• 2025: Assess internal readiness, map product and supplier data
• 2025–2026: Fill data gaps, start tracing
• 2026–2028: Run pilots
• 2028–2030: Scale DPPs through portfolio

Realistic compliance lead time: Industry consensus is 12–18 months from delegated act adoption. (Supercode, 2026-03-19)

Vendor landscape (as-of 2026): Renoon (2026-02-04) lists leading DPP providers for fashion as Renoon (self-listed first), TrusTrace, Retraced, Fairly Made, and EON. Arianee reports 3.4M+ DPPs deployed across 50+ brands in 40+ markets since 2018, with registry-ready APIs (self-reported, 2026). Pimberly (PIM platform) positions as the foundational data layer. Circularise specialises in secure selective disclosure of sustainability data. CIRPASS-2 is the EU-funded DPP pilot project; ends April 2027. (Renoon, 2026-02-04; Arianee, 2026; Retail TouchPoints, 2025-11-26; Renoon, 2026-02-04)

Cost benchmarks (as-of 2025-04, volatile): Small brands quoted €15,000–€50,000/yr for DPP software implementation; lighter-touch solutions at €3–8k/yr exist but do not resolve the data collection problem. (r/sustainability, 2025-04)

Four major hurdles from battery passport pilot (TylkoTALK, 2026-01-07):

1. Data silos and confidentiality — competitive reluctance to share supply chain data
2. Interoperability — thousands of global players using hundreds of different software systems
3. Liability handoff — unclear who updates a passport when a product changes hands/lifecycle stage
4. Data reliability — validating carbon footprint figures across different energy grids

Tier 2/3 supplier gap: Reddit practitioners (r/supplychain, 2025-03, 287 upvotes) report Tier 2 and 3 suppliers "have no idea this is coming and many of them will never be able to provide the data you need." Many companies still lack visibility beyond Tier 1; DPP may require multi-tier traceability across entire supply chains. (10 Min For Supply Chain, 2026-05-27)

Procurement transformation: Procurement will increasingly evaluate suppliers on sustainability reporting and data transparency, not just price. (10 Min For Supply Chain, 2026-05-27)

Supply chain agility trade-off: Reddit practitioners (r/supplychain, 2025-03, 212 upvotes) note DPP creates strong incentives to reduce supplier switching, because re-collecting verified data for new suppliers is expensive — described as "a genuine unintended consequence nobody has modeled."

SME considerations: Requirements are the same for SMEs and large companies; the Commission is considering simplified procedures, guidance, and financial incentives. (TÜV SÜD, 2025-08-26)

Brand continuity / bankruptcy gap: If a brand goes bankrupt, who maintains the passport? "Not clearly solved" in the regulation. (r/circulareconomy, 2025-01)

Blockchain skepticism: Reddit practitioners (r/sustainability, 2025-05, 167 upvotes): "What you need is data integrity, access control, and auditability. You can get all of that with a conventional database and proper governance."

QR durability concern: Physical QR code or NFC tag may not survive a garment's lifetime through washing and wear. (r/circulareconomy, 2025-01)

Product data maintenance burden: The DPP is not static — must be updated when regulations change, supply chain changes, or product is repaired. Described as "a living document for every SKU, forever." (r/sustainability, 2025-05)

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The battery passport as a DPP pilot

The Digital Battery Passport (mandatory 18 Feb 2027) is explicitly described as the "pilot program" and "blueprint" for the wider ESPR DPP system — the tiered data access, unique identifier infrastructure, and lifecycle transparency mechanisms developed for batteries will be adapted for textiles, electronics, and other product groups. (TÜV SÜD, 2025-08-26)

The battery passport demonstrates the "Brussels effect": compliance required for EU market access regardless of company origin, effectively establishing a new global standard. (TÜV SÜD, 2025-08-26)

Battery sector implementation lessons (r/sustainability, 2024-11, 267 upvotes):

• Supplier data collection took 3× longer than expected even starting 18 months out
• QR update burden is operationally complex when product data changes
• Third-party audits are "much more intensive than self-certification"

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Regulatory interaction

The DPP intersects with:

• GDPR — data subject rights, data storage obligations for passport content
• Green Claims Directive / Empowering Consumers Directive (ECGT, Sep 2026) — passport data can substantiate or contradict marketing claims
• EU Deforestation Regulation (EUDR) — supply chain traceability overlap
• Carbon Border Adjustment Mechanism (CBAM) — carbon footprint disclosure overlap
• Extended Producer Responsibility (EPR) — EPR for textiles operational April 2028
• Packaging and Packaging Waste Regulation (PPWR) — QR codes on all packaging by 2030 for recycling/material data
• Ecodesign Regulation (ESPR) — parent framework

Practitioners note that brands are managing overlapping EU sustainability regulations (DPP, EPR, Green Claims, CSRD, CBAM) with no integrated compliance framework, resulting in separate systems for each. (r/circulareconomy, 2025-04)

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Sustainability vs greenwashing debate

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Key terms

Term	Meaning
DPP	Digital Product Passport — the regulated digital record
ESPR	Ecodesign for Sustainable Products Regulation (EU 2024/1781) — the enabling framework
Delegated act	A Commission regulation specifying requirements for a specific product group
UID	Unique digital identifier linked to the data carrier
GS1 Digital Link	URL-based QR standard embedding GTIN; compatible with retail checkout scanning
DPP Service Provider	New regulated actor category (Implementing Regulation 2026/1778, Art. 3.f) — creates, hosts, registers DPPs on behalf of economic operators
Substances of concern	ESPR category broader than REACH SVHC; includes recycling-impeding substances
CIRPASS-2	EU-funded DPP piloting project running to April 2027
GS1 Sunrise	2027 global retail transition from 1D barcodes to QR codes at point of sale
Brussels effect	A regulation's tendency to become a global de-facto standard by making EU market access conditional
eIDAS	EU electronic signature regulation governing economic operator verification for the DPP Registry

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Frontier links (not yet pages)

GS1 Digital Link · Extended Producer Responsibility (EPR) · Green Claims Directive · Empowering Consumers Directive (ECGT) · CIRPASS-2 · Traceability · Battery Regulation (EU 2023/1542) · Substances of Concern · Packaging and Packaging Waste Regulation (PPWR) · Carbon Border Adjustment Mechanism (CBAM) · Product Lifecycle Management (PLM) · REACH · GS1 Sunrise