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Active Steward™ for Digital Product Passports

Digital Product Passports you can stand behind

Under the EU Ecodesign for Sustainable Products Regulation (ESPR), publishing a passport is the easy part. Proving the data behind it is not. Active Steward™ builds one governed, evidence-backed record for every product, so every passport you publish is one you can defend.

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Who's it for

Built for the sectors where passports come first

Batteries and EV

Battery passports are mandatory from February 2027. Get your material, carbon footprint and due diligence data ready now.

Detergents and cleaning products

The new Detergents Regulation brings digital labelling and a product passport. Make sure your formulation data is ready.

Toys

New EU toy safety rules bring a passport focused on chemical safety. Show what is in your products, and prove it.

Construction products

The revised Construction Products Regulation moves product information into digital form. Keep performance and substance data in one place.

Textiles

Textiles are a priority group under ESPR. Build fibre, substance and supply chain data before the rules arrive.

Chemical suppliers

Your customers will need your data for their passports. Become the supplier that makes it easy.

Digital Product Passports are no longer coming. They are here.

ESPR (Regulation (EU) 2024/1781) makes the Digital Product Passport the standard way to share product data across the EU. Each product group gets its own requirements and deadlines. The first ones are already set.

Battery passports: 3 months to go

  • Confirmed
  • Expected
  • Today

  1. July 2024 Next
    ESPR (Regulation (EU) 2024/1781) enters into force, setting the framework for Digital Product Passports. All sectors · Confirmed Details

    ESPR replaced the Ecodesign Directive. It lets the Commission set ecodesign and passport requirements product group by product group, through delegated acts.

    Regulation (EU) 2024/1781 (ESPR)
  2. 20 July 2026 Next
    The EU Digital Product Passport Registry goes live. All sectors · Confirmed Details

    The Registry holds each passport's unique identifier so customs and market surveillance authorities can find it. How it works is set out in Implementing Regulation (EU) 2026/1778.

    Implementing Regulation (EU) 2026/1778
  4. November 2026 Next
    The final DPP technical standards are adopted. All sectors · Expected Details

    Six harmonised standards covering identifiers, data carriers, APIs and data exchange were referenced under Implementing Decision (EU) 2026/1736 in July 2026. The remaining standards are expected to follow.

    Implementing Decision (EU) 2026/1736
  5. Q4 2026 Next
    First ESPR product rules adopted, for iron and steel. Steel · Expected Details

    Steel and aluminium are priority products in the Commission's ESPR working plan 2025–2030. The iron and steel rules are expected to be the first to set passport requirements under ESPR.

    ESPR working plan 2025–2030
  6. 18 February 2027 Next
    Battery passports become mandatory for EV, light means of transport and industrial batteries. Batteries · Confirmed Details

    Applies under Article 77 of the Batteries Regulation to EV batteries, light means of transport batteries and industrial batteries over 2 kWh placed on the EU market.

    Regulation (EU) 2023/1542 (Batteries)
  7. Q2 2027 Next
    Passport rules for construction products under the Construction Products Regulation. Construction · Expected Details

    The new Construction Products Regulation introduces a passport for construction products. Requirements will be phased in product family by product family through delegated acts.

    Regulation (EU) 2024/3110 (CPR)
  8. Q3–Q4 2027 Next
    ESPR product rules for textiles, tyres and aluminium. Textiles, Tyres, Metals · Expected Details

    Textiles (with a focus on apparel), tyres and aluminium are priority products in the ESPR working plan. Their delegated acts will set the ecodesign and passport requirements.

    ESPR working plan 2025–2030
  9. 2028 Next
    ESPR product rules for furniture. Steel passports likely to apply from around this point. Furniture, Steel · Expected Details

    Furniture is a priority product in the ESPR working plan. Steel passports are expected to apply once the iron and steel rules take effect.

    ESPR working plan 2025–2030
  10. 23 September 2029 Next
    The Detergents Regulation (EU) 2026/405 applies, including a passport for detergents and surfactants. Detergents · Confirmed Details

    Every detergent and surfactant placed on the EU market will need a Digital Product Passport. Manufacturers outside the EU must appoint an EU-based representative.

    Regulation (EU) 2026/405 (Detergents)
  11. 2029 Next
    ESPR rules for mattresses, recycled content and electronics recyclability. Furniture, Electronics · Expected Details

    Mattresses are a priority product in the ESPR working plan, alongside horizontal rules on repairability and on the recyclability of electrical and electronic equipment.

    ESPR working plan 2025–2030
  12. 1 August 2030 Next
    The Toy Safety Regulation (EU) 2025/2509 applies. Every toy needs a passport before it goes on sale. Toys · Confirmed Details

    The passport replaces the EU declaration of conformity for toys. Its unique identifier must be registered before the toy is placed on the market.

    Regulation (EU) 2025/2509 (Toy Safety)

ESPR product rules apply at least 18 months after adoption. Dates marked expected are indicative and may change.

If your product data is not ready, your passport will not be either. Starting early is the lowest-risk route.

Not sure which dates apply to you?

Find out now

The Challenge

The passport is only as good as the data behind it

A Digital Product Passport has to be accurate, current and traceable. For most businesses, the data it needs is spread across safety data sheets, supplier declarations, formulation records, test reports and ERP systems. Some of it is incomplete, some is out of date, and much of it is hard to trace back to a source.

That creates three risks:

  • Data you can't prove. Regulators, customers and recyclers will rely on what your passport says. If you can't show where a value came from, you can't defend it.

  • Data that drifts. Formulations change, suppliers change and regulations change. A passport that was right at launch can be wrong six months later.

  • Effort that doesn't scale. Building passports by hand, product by product, uses up time your team doesn't have.

Our Approach

Active Steward™ starts with the data, not the document.

It gathers product information from your existing documents, supplier data, formulation records and enterprise systems. Then it structures that information into one governed product record.

Every data point carries its source, its evidence, its approval status and its version history. So when someone asks where a value came from, you have the answer.

From that one record, you can produce:

  • Digital Product Passports

  • Declarations of Conformity

  • Supplier declarations

  • Customer attestations

  • Regulatory risk reports

Each audience sees only the data it should see.

What Active Steward™ Does

The capabilities that turn trusted product data into compliant, reusable outputs.

Turns regulation into a readiness picture

Turns regulation into a readiness picture

See which products meet which requirements, and where the gaps are, in one view.
Uses AI to speed up data gathering

Uses AI to speed up data gathering

AI pulls data from documents and supplier files. Your experts review and approve it before it is used.
Manages by exception

Manages by exception

Your team focuses on the gaps and conflicts, not on re-checking data that is already sound.
Keeps product data current

Keeps product data current

When a formulation, supplier or regulation changes, the affected records and passports are flagged.
Discloses the right data to the right audience

Discloses the right data to the right audience

Control what regulators, customers, recyclers and the public can see.
Closes data gaps at the source

Closes data gaps at the source

Request missing information from suppliers and track it until it arrives.

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Why Penman Consulting? 

Built by regulatory experts, not just software developers 

Most DPP platforms are built to publish passports. Ours is built by a team that has spent years helping businesses prove their compliance.

Penman Consulting is a specialist chemical regulatory consultancy. Our scientists and regulatory specialists work every day with substance data, formulations, REACH, SVHCs, safety data sheets and IUCLID dossiers. That is the data a credible passport depends on. 

So you don't just get software. You get people who understand what the regulation asks for, and why. 

  • Regulatory knowledge built in. We follow ESPR, its delegated acts and the product rules that sit alongside it, and build that into Active Steward™. 

  • Chemical data expertise. Substances of concern, composition and hazard data are where many passports will be tested. That is our home ground. 

  • Software and services together. Use Active Steward™ on its own, or with our scientific and regulatory teams helping you fill gaps and review data. 

The Outcomes

Greater confidence, less manual effort and passports you can defend.

Passports you can defend

Passports you can defend

Every value traces back to its source and evidence.
A live view of readiness

A live view of readiness

Know which products are ready and what is still missing.
Less manual effort

Less manual effort

AI-assisted gathering and management by exception cut the hours spent on each product.
Control over disclosure

Control over disclosure

Share the right data with each audience, and nothing more.
Ready for what's next

Ready for what's next

As new delegated acts arrive, your governed record is already in place.
Trust as a feature

Trust as a feature

Give customers, regulators and recyclers data they can rely on.

Product passports and material passports: how they fit together

A Digital Product Passport describes a finished product. But many products are made from chemicals and materials, and their passports depend on data from further up the supply chain. That is where the Digital Material Passport (DMP) comes in.

Digital Product Passport (DPP)

Digital Material Passport (DMP)

What it covers

A finished product, such as a battery, toy, textile or detergent

The chemicals and materials that go into that product

Who sets it

EU law: ESPR and product rules such as the Batteries, Toy Safety and Detergents Regulations

The chemical industry, through the Chem-X guidelines

Is it required?

Yes, for each product group from its set date

Not a legal requirement in itself, but customers will increasingly ask for it

Typical data

Composition, substances of concern, carbon footprint, repair and recycling

Material identity, verification, product declaration, environmental footprint, circularity

Who needs it

Brands and manufacturers placing products on the EU market

Chemical and material suppliers feeding those products

The two work as a chain. Good material passports make product passports easier and more credible. Active Steward™ helps you manage the data for both, from one governed record.

FAQs

Digital Product Passports: your questions answered

What is a Digital Product Passport?

A Digital Product Passport (DPP) is a digital record of a product's key information, including materials, substances of concern, sustainability data, repair guidance and end-of-life instructions. It is reached through a QR code, NFC tag or other data carrier on the product.

Which regulation requires Digital Product Passports?

The main framework is the EU Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. Product-specific rules also include passports, such as the Batteries Regulation and the new Detergents Regulation. 

When do I need one?

It depends on your product group. Battery passports apply from February 2027. Other groups will follow as the EU adopts delegated acts under ESPR. We can help you map your products to the dates that apply.

What data goes into a passport?

Typically composition, substances of concern, origin, carbon footprint, repair and recycling information, and compliance documents. The exact list is set for each product group.

How is a passport different from a safety data sheet?

A safety data sheet covers hazards and safe handling for a chemical. A passport covers a product's whole lifecycle and goes to a wider audience. Much of the same substance data feeds both, which is why governing it in one place matters. 

My products don't need a passport. Does this affect me?

It may. If you supply chemicals, materials or components, your customers will ask you for the data their passports need. 

Can Active Steward™ work with our existing systems?

Yes. It gathers data from your existing documents, supplier files and enterprise systems, so you don't have to start again.

Start with the data, not the document

The businesses that get their product data in order now will find every passport after that easier. Talk to our team about where you stand today and what you need to be ready.

Book a consultation

More on Digital Product Passports

Guides, events and brochures to help you prepare

Brochure

Digital Product Passport Solution Brochure

Digital Product Passports are becoming mandatory under the EU’s ESPR. This brochure shows how Active Steward™ turns scattered product data into one governed record, so you can publish passports you can prove.

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