The Digital Product Passports and Packaging

The story behind PPWR, ESPR, and the rise of packaging data inside Digital Product Passports

A year ago, Circular Analytics dropped something that should be on every fashion brand’s radar: a deep dive into the Packaging and Packaging Waste Regulation (PPWR) and how it plays with the Ecodesign for Sustainable Products Regulation (ESPR). If you’re working with Digital Product Passports (DPPs), this isn’t just regulation—it’s your new product playbook.

Fashion brands are already preparing for ESPR because it brings sustainability into the product DNA—from materials and design to repairability and reuse. But here’s the twist: now, packaging isn’t just the box your blouse ships in. Under PPWR, it’s part of your brand’s sustainability story, and soon, part of your DPP.

Let’s break down how this changes the game—and what your brand needs to know.

Phase 1: ESPR puts your product under the spotlight

ESPR (Regulation EU 2024/1781) is the EU’s way of pushing all physical goods toward a circular future. That includes fashion. It demands transparency on things like:

• What your product is made of
  
  
• How long it lasts
  
  
• How easy it is to repair, recycle, or reuse
  
  
• What impact it has from cradle to grave
  
  

Digital Product Passports are the tool brands will use to deliver this transparency—essentially digital records connected to each item, accessible via QR code, NFC, or online.

Phase 2: PPWR gives packaging its moment

If ESPR is about your product, PPWR is about the packaging it comes in. As of 2030, all packaging placed on the EU market must be recyclable. By 2035, it must also be recycled at scale.

What that means in practice:

• You’ll need to meet strict design-for-recycling criteria
  
  
• Labels and adhesives? Those count too.
  
  
• You'll be responsible for packaging throughout its full lifecycle (thanks to Extended Producer Responsibility)
  
  
• You’ll need to inform customers clearly on how to dispose of your packaging
  
  

If you’ve been treating packaging as an afterthought, that era is over.

Phase 3: ESPR and PPWR join forces in DPPs

Here’s where things get interesting.

When your product falls under ESPR and requires a DPP, the packaging data must be included inside that passport. That means your DPP might soon carry:

• The type of packaging
  
  
• Its recyclability rating
  
  
• How much of it is recycled content
  
  
• Its weight and volume
  
  
• Your product-to-packaging ratio
  
  

Fashion brands working with DPPs now need to plan for both product and packaging data. This makes DPPs a one-stop source for compliance and customer transparency.

FAQs Fashion Brands Are Asking

Is all packaging now part of DPPs?
Not yet. But if your product is in scope for ESPR, your packaging likely is too—at least the data about it.

What does this mean for my next collection?
It means that both your silk slip dress and its compostable shipping pouch need a sustainability story—one that’s trackable, verifiable, and ready for the EU market.

Will this be complex to manage?
Only if you wait too long. The sooner you integrate packaging data into your DPP creation workflows, the easier it’ll be to stay compliant.

What Should Fashion Brands Do Next?

1. Audit your packaging. Is it recyclable? How much is post-consumer material? What adhesives or labels are used?
   
   
2. Prepare to embed packaging data into your DPPs—even if it’s not mandatory yet.
   
   
3. Talk to your tech partners (like SmartDPP) about how to streamline this data collection and integration.
   
   

TL;DR
ESPR and PPWR are shaping a future where packaging is just as important as the product. For fashion brands, that means the box, the bag, the tag—all of it needs to be smart, circular, and digitally trackable. DPPs are how we get there.

Start now. The brands that adapt early won’t just comply—they’ll lead.