UK Consultation on Digital Product Records
On 27 July 2026, the Department for Business and Trade, alongside the Department for Business, Innovation, Science and Trade, opened a call for evidence to gather views on Digital Product Record (DPR) policy for the UK. The consultation closes on 21 September 2026 and could see a system similar to the EU Digital Product Passport (DPP) concept extended to the UK.
What are Digital Product Passports?
Digital Product Passports… We’ve heard talk of them in recent years, since they were included in the EU’s proposal for the Ecodesign Regulation (ESPR) in 2022. But what are they, and what do they mean for businesses?
DPPs are digital records of a product’s information which stays with the product and is updated throughout its life. They were established in the EU under the ESPR, but also included in other legislation, such as EU Batteries Regulation (EUBR), EU Construction Products Regulation (CPR), and the EU’s Toy Safety Regulation.
The information contained in DPPs has two main purposes:
To establish an easy to access record of compliance and traceability for market-surveillance and customs authorities, improving the efficiency and effectiveness of product checks and customs controls. This should help to facilitate compliance across the EU’s single market.
To strengthen supply chain transparency and provide greater clarity of product information; supporting consumers in making more informed choices about the products they are buying, keeping goods in use for longer, and helping transition to a more circular economy.
We already know products covered by the three regulations listed above will require DPPs in the near future but, for ESPR, this is slightly different: Products will only require DPPs once they are covered by specific, horizontal legislation, such as what we are expecting for textiles, steel and aluminium, tyres, furniture, ICT products, and products covered by the EU Energy Labelling Framework Regulation.
What information will be included in DPPs?
While we don’t know the specifics of what information is to be included in DPPs under ESPR, as this will be confirmed in relevant secondary legislation and will vary by product type, we know they might include:
Product identity and manufacture details
Materials, component composition, and country of origin
Environmental performance data
Repair and maintenance information
Disassembly instructions
Information on hazardous substances
Recycled content
Durability or expected lifetime
End-of-life, reuse and recycling information
Some of this information will be available to different actors in the supply chain. With compliance information available to market or customs authorities, the consumer will be able to see product information such as energy-use, durability and repair information. Repairers will be able to access technical information and parts data, and recyclers able to identify materials or substances that could affect end-of-life or recycling.
I’m not in the EU, why does this affect me?
DPRs are now being explored internationally as a means of providing product information and sustainability data across supply chains.
For the UK, due to the Windsor Framework, EU DPPs will apply in Northern Ireland, meaning that UK companies supplying into Northern Ireland will need to ensure their products are accompanied by a DPP where required.
Due to this international focus and global nature of DPRs, it is important we have a system that is interoperable across nations and continents.
While European Committee for Standardization (CEN) and European Committee for Electrotechnical Standardization (CENELEC) are working on harmonised technical standards that will underpin the EU’s DPP system, with six standards already published.
In 2026, International Organization for Standardization (ISO) and International Electrotechnical Commission (IEC) established a Joint Technical Committee to bridge the gap between the EU and global standardisation, with their first project, ISO 25534-1, to cover terminology, principles, governance, trust and data categories.
What's happening in the UK?
The consultation is the first clear step towards deciding whether Great Britain should develop its own DPR systems and how closely it should align with the EU DPP.
This is also closely connected to wider UK product-law reform, with the government already proposing a broad ‘digital-by-default’ approach to product information under its new product safety framework. DPR policy in the UK therefore needs to be designed to complement these initiatives rather than having two separate systems.
With wider changes to the circular economy landscape, as in the EU, DPR could be used to identify repair, reuse, improved end-of-life management, product sustainability and resource-efficiency impacts.
What’s the bottom line?
As circular economy and sustainability regulation continues to evolve, we are seeing design choices, supply chain traceability, and the ability for a company to efficiently gather and store data either become a substantial compliance cost, or competitive advantage.
Companies in the UK have already been assessing their supply chains and data capabilities from recent regulatory changes, such as UK packaging Extended Producer Responsibility (pEPR). This consultation, alongside indication that the UK is looking at further alignment with the EU, is a signal that companies should be examining their data readiness now.
Final thoughts…
From a circular-economy perspective, I think the important question is whether DPRs become merely a ‘digital-by-design’ compliance tool, or instead help companies develop more circular products while increasing transparency and traceability for consumers; supporting repair, refurbishment, reuse, and recycling.
I’m 100% in support of DPRs in theory. I am that person that looks at the labels on clothes to check for material composition and GOTS certification; I read food labels to work out countries of origin; I look at energy-labelling to ensure I’m buying energy efficient electrical goods.
So, while this may not be the most positive note to end on, I did find the following finding particularly interesting…
In the EU’s Joint Research Committee's (JRC) technical proposal for harmonised labels under EU Packaging & Packaging Waste Regulation (PPWR), behavioural experiments explored the likelihood a consumer would scan a QR code to access packaging recyclability information. Out of 11,096 participants… only 4 people scanned the test QR code.
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