ESPR, DPP, and labeling: Why you should tackle this as a package now

Jenny Walther-Thoß
24. March 2026

The EU is gradually making sustainable products the standard. With the “ , Ecodesign for Sustainable Products” (ESPR) regulation, it is creating a framework for introducing product group-specific requirements. A key implementation tool is the Digital Product Passport (DPP). In our article, we’ll show you why ESPR will soon become relevant for packaging as well, how ESPR, DPP, and the EU regulation on harmonized labeling requirements are interconnected, what the timeline looks like, who will be affected first (mechanical engineering and metals), and how you should prepare. The bottom line: Anyone who tackles ESPR, DPP, and labeling regulations separately risks duplication of effort, inconsistencies, and costly retrofit waves. There are three top priorities for 2026.

 

Basics of the ESPR

With the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781), the EU is establishing a framework through which product-group-specific requirements will be introduced via delegated acts—ranging from energy and resource efficiency to durability/repairability and mandatory product information.

• The initial regulatory initiatives under the ESPR focus on textiles, furniture, tires, cleaning products, paints, lubricants, and information and communication technology (ICT) products. Energy-related products, such as electric motors, are also included. For these, implementing measures—i.e., concrete and binding regulations—are to be revised or newly established.
• The approach is taken on a “product-by-product” basis. Thus, requirements regarding the lifespan, reliability, reusability, upgradability, repairability, maintenance, (re)conditioning, and recycling of products will be established for specific products.
• Other proposed requirements include
  • additional restrictions on critical substances,
  • additional requirements for energy and resource efficiency,
  • the use of a mandatory proportion of recycled materials and/or the calculation of a CO2 and environmental footprint.

 

The Digital Product Passport (DPP) as a central implementation tool

The Digital Product Passport (DPP) is intended to become the central implementation tool of the ESPR by making it, depending on the product group, a prerequisite for placing products on the market and by making the required sustainability, material, and conformity data available electronically.

 

Crucial for the packaging industry

This scenario is crucial for the packaging industry because

• steel and aluminum are prioritized very early on as intermediate products in the initial work plan,
• DPP and data requirements have an immediate impact on packaging and filling chains, and
• the PPWR (Packaging and Packaging Waste Regulation) is simultaneously rolling out harmonized EU labeling (Art. 12/13). Those who address DPP and labeling requirements separately risk duplication of effort, inconsistencies, and costly retrofit waves.

Packaging machinery first

In practice, packaging machinery manufacturing will be affected early on. This is not so much because machines are “automatically” listed as a prioritized product group in the work plan, but because customers (brand owners, fillers, packaging manufacturers) must embed DPP- and PPWR-compliant processes into their facilities and production lines.

Already in the relatively short term, starting around 2027, machinery manufacturing will be directly affected by ESPR and DPP where revisions are made to existing implementing measures for energy-related products. This is expected to happen primarily for electric motors.

 

Three corresponding short-term consequences

1. “DPP-ready” becomes a standard requirement
2. Ecodesign readiness for machines
3. PPWR labeling as a production requirement

 

1. “DPP-ready” becomes a standard requirement

Four capabilities will quickly become a must for machine builders in tenders/retrofits:

• Carrier capability (QR/Data Matrix): Application, position, durability, readability, error handling (rejects/rework/reprint).
• Unique identification: Clear mapping of model/batch/item to packaging/product (serialization/batch logic).
• Data transfer: Standardized interfaces/exports to MES/ERP/PLM and to DPP ecosystems (interoperability).
• Audit trail: Traceability, versioning, roles/permissions (to ensure data is “authority-compliant”).

2. Eco-design readiness for machines: Considering energy efficiency & repairability

In packaging machinery manufacturing, too, “compliance by design” should now be embedded in product management. This involves, in particular:

• Making energy and resource efficiency measurable and verifiable (consumption, operating states, standby, benchmarks per product group if applicable).
• Ensuring repairability/upgradability (modularity, spare parts strategy, diagnostic/serviceability, update paths).
• Strengthening information capabilities (maintenance, repair, spare parts, and safety information—ideally as structured data, DPP-compatible where applicable).

3. PPWR labeling (Art. 12/13) as a production requirement

• For production lines, PPWR labeling means: more variants, more frequent label/artwork changes, material specifications, and consistency checks (label ↔ material master ↔ DPP data, if applicable).
• It is recommended to provide a “Label & Data Pack” as a retrofit kit (printing/marking + vision + data integration)—before customers are forced to retrofit under tight deadlines.

Quick checklist for 2026:

1. Define a standard “DPP/Carrier/ID” option for new installations and retrofits.
2. Define the data blueprint (which data is generated where—and how is it exported/validated).
3. Incorporate an efficiency and repairability roadmap into your product strategy.

 

 

Who else in the supply chain is particularly affected (and why)

In addition to the machinery sector, there is a relatively large group of companies in the packaging industry that should already be paying special attention to the complex issues of ESPR, DPP, and labeling.

These include aluminum and steel packaging, including the supply chain; the sector of paints, varnishes, printing inks, and coatings; and, as key drivers, brand owners, fillers, and packaging manufacturers.

1. Aluminum and steel packaging, including the supply chain

The 2025–2030 work plan prioritizes iron & steel (expected in 2026) and aluminum (expected in 2027) as intermediate products.

• This may entail requirements regarding material data, recyclate/footprint capability, recyclability, and information obligations,
• with a direct impact on cans, tubes, closures, films/composites, and components.
• It is important to structure material and supplier data in such a way that it can be used seamlessly in customer traceability chains (and later, if applicable, DPP/customs checks).

2. Paints, varnishes, printing inks, coatings (packaging coatings)

While “paints and varnishes” are recognized as a priority in the context of the ESPR, they were not included in the initial work plan. At the same time, studies are being prepared on chemicals, including polymers and plastics, an indication that this topic will come back into sharper focus in the medium term.

What is therefore worthwhile for manufacturers of coatings and paints right now:

• Expand data capabilities (composition, compliance, recyclability),
• Embed “Design for Recycling” criteria more firmly (in specifications and customer communication), and
• Prepare interfaces (toward DPP/material data models).

3. Brand Owners / Fillers / Packaging Manufacturers

Brand owners, fillers, and packaging manufacturers will drive these requirements into the value chain. This will be evident and have an impact, for example, in procurement (material data), production (carrier/ID), artwork (PPWR label), and compliance (documentation). Those who harmonize early will save on redesign cycles later.

 

The 2024-2030 Timeline: What Is Realistic and When

Important: The ESPR is already in force. Specific obligations will take effect on a product group-by-product group basis and only upon the adoption of the relevant delegated acts. The dates in the work plan are an estimated timeline! Applicability and transitions will be governed by the respective delegated act.

ESPR Milestones:

• July 18, 2024: ESPR enters into force.
• April 16, 2025: First ESPR/Energy Labeling Work Plan 2025–2030 published.
• By the end of 2025: Award of the study to identify potential measures for chemicals, including polymers/plastics.
• 2026 (expected): Iron & Steel (intermediate product).
• 2027 (expected): Aluminum (intermediate product).
• 2027 (planned): Horizontal requirements for reparability (cross-industry signal effect).

PPWR Milestones (Labeling Bridge):

• February 11, 2025: PPWR enters into force.
• August 12, 2026: PPWR becomes applicable; labeling system under Art. 12/13 effective August 2028

 

Recommendation: How to avoid duplication of effort

The Digital Product Passport (DPP) is the data backbone (supply chain/authorities/customs, if applicable).

PPWR labeling is the front-of-pack information for material composition and sorting.

 

The key to success: One data master – two output channels.

• Material/component master as the “single source of truth.”
• The artwork/labeling process (PPWR) accesses the same, verified classifications.
• Production data (carrier/ID) ensures assignment on the production line.

This ensures consistency between PPWR labels, customer requirements, and future DPP obligations.

 

Conclusion: Top 3 priorities for 2026

1. Prioritize machinery manufacturing: DPP/carrier/ID capability + data export + audit trail as a standard package.
2. Secure the metal traceability chain: Prepare supplier data & documentation for steel (2026) and aluminum (2027) for DPP/customer chains.
3. Link PPWR labeling with the DPP data model: Classify once, use multiple times – instead of waves of rework later on.

 

Sources

European Commission (ESPR overview, objectives, DPP, timelines):

• Ecodesign for Sustainable Products Regulation – Overview, Objectives (including reparability, energy/resource efficiency), DPP description, and timeline (entry into force July 18, 2024; working plan April 2025). (European Commission)

VDMA (Industry Assessment – Mechanical Engineering Affected Early On):

• “New Ecodesign Regulation and Digital Product Passport” (Mechanical engineering will be affected in the short term; DPP/Ecodesign classification). (vdma.org)

Work Plan 2025–2030 (uploaded document, timeline & scope):

• Adoption timeline for intermediate products (iron & steel 2026; aluminum 2027) and horizontal reparability 2027; notes on the chemicals/polymers study and the exclusion of “paints and coatings” from the first work plan. (EUR-Lex)

ESPR Regulation text (uploaded EU document, DPP basic logic; EUR-Lex)

 

PPWR (timeline & classification):

PPWR (Regulation (EU) 2025/40) – Entry into force 02/11/2025; Application from 08/12/2026. (Business Growth Service) (EUR-Lex)