From Regulation to Implementation: a holistic view on ESPR, PPWR and DPP

For decades, sustainability in manufacturing was often framed as a voluntary initiative and the regular approach was more or less linear. Companies introduced recycling targets, reduced packaging weight or improved energy efficiency. Important steps, certainly — but largely self-directed.

That era is ending.

The European Union is now introducing a new generation of regulations that fundamentally redefine how products are designed, packaged, sold and ultimately recycled. At the center of this transformation are two major legislative frameworks:

Packaging and Packaging Waste Regulation (PPWR)

Ecodesign for Sustainable Products Regulation (ESPR)

At first glance, both regulations seem to pursue the same goal: making products more sustainable and enabling a circular economy. But their scope and mechanisms differ significantly.

The PPWR focuses specifically on packaging — how it is designed, how much of it is used, and how effectively it can be reused or recycled.

The ESPR, in contrast, targets the product itself. It introduces sustainability requirements across a wide range of product categories, covering aspects such as durability, repairability, recyclability and resource efficiency.

Yet both regulations share a critical common denominator:

Transparency.

To enforce sustainability requirements across global supply chains, regulators need verifiable information. Authorities must be able to determine what materials were used, how products were manufactured and whether recycling targets are met. Customer needs to have information regarding the recyclability, repairability and reusability of the products. The Manufacturer will have the obligation to provide this and more information.

This is where the third key element enters the picture:

The Digital Product Passport (DPP)

The DPP is designed to serve as a digital identity for products and materials. It connects physical goods to structured digital data, enabling traceability across their entire lifecycle.

But here lies a fundamental question that many companies underestimate: 

Before data can be collected, shared or verified, the product itself must carry a reliable identity. A machine-readable identifier must link the physical item to its digital record.

This is where direct product marking becomes strategically important. Permanent, machine-readable codes applied directly to products or packaging create the bridge between the physical and digital worlds.

Without that connection, even the most sophisticated digital infrastructure remains theoretical.

Packaging has always served a practical purpose: protecting products, enabling transport and communicating brand identity. For a long time, its environmental impact was treated as a secondary concern.

That perspective is rapidly changing.

With the introduction of the Packaging and Packaging Waste Regulation, the European Union is redefining packaging as a central element of the circular economy.

The numbers explain why.

Packaging accounts for one of the largest streams of municipal waste in Europe. Plastic packaging in particular has become a focal point of environmental policy.

The PPWR therefore establishes new rules that address several critical areas, e.g.:

• Reduction: Companies must minimize unnecessary packaging and reduce overall material use.
• Recyclability: All packaging placed on the EU market must be designed for recycling.
• Reuse targets: Certain packaging formats will need to support reuse systems.
• Material transparency: Packaging composition must be clearly documented and traceable.

These requirements represent a profound shift for manufacturers and brand owners. Compliance will no longer depend solely on internal documentation or supplier declarations. Authorities will increasingly require verifiable product-level data.

Once again, this raises a practical question:

The answer increasingly lies in machine-readable product identities. Unique identifiers applied directly to packaging enable automated tracking, sorting and reporting. They allow information about materials, recyclability and regulatory compliance to be accessed digitally. Direct product marking — through technologies such as laser coding, printing or permanent marking — becomes the entry point to this data ecosystem. Without a reliable code on the packaging itself, data cannot travel with the product through the supply chain, the retail environment and ultimately the recycling system.

However, packaging regulation alone is only part of the picture.

While PPWR governs what surrounds the product, another regulation addresses what the product itself must become. That regulation is the Ecodesign for Sustainable Products Regulation — and its implications go far beyond packaging. 

If the Packaging and Packaging Waste Regulation focuses on packaging, the Ecodesign for Sustainable Products Regulation aims at something even more fundamental:

The design of the product itself.

The ESPR expands the concept of ecodesign far beyond energy efficiency. It introduces a framework under which products sold in the EU must meet a range of sustainability requirements throughout their lifecycle.

These may include:

• durability
• repairability
• recyclability
• recycled material content
• resource efficiency
• environmental footprint
• Lifecycle performance

Rather than targeting one product category at a time, the ESPR establishes a horizontal framework. Specific product groups will gradually receive detailed requirements through delegated acts.

This approach effectively turns sustainability into a core design parameter — similar to safety, quality or performance.

For manufacturers, this has major implications.

Product development will increasingly require structured sustainability data. Companies must understand material composition, component origins and lifecycle characteristics at a much deeper level than before. But gathering data internally is not enough. Authorities, market surveillance bodies and potentially consumers will need access to reliable information about each product’s sustainability profile. This is precisely the role envisioned for the Digital Product Passport: the passport functions as a digital repository containing structured information about a product’s composition, sustainability attributes and lifecycle data.

However, a digital passport only works if the physical product can be unambiguously identified. A product without a reliable identifier is essentially invisible in the digital ecosystem.

Once again, the importance of direct product marking becomes clear: it provides the physical anchor for the digital identity of the product.

The Digital Product Passport is often described as the backbone of Europe’s emerging circular economy.

In simple terms, it provides a structured digital identity for products and materials. This digital identity can contain information such as:

• material composition
• recycled content
• repair instructions
• sustainability metrics
• ecycling guidance
• regulatory compliance data

By making this information accessible across the product lifecycle, the Digital Product Passport supports multiple stakeholders:

• manufacturers
• regulators
• repair providers
• recyclers
• and potentially consumers

For regulators, the DPP provides transparency and verification.For companies, it offers the possibility to manage sustainability data in a structured way.

But despite all its digital sophistication, the passport still depends on something surprisingly simple: A code on the product.

Without a physical identifier linking the item to its digital record, the passport cannot function. The digital file and the physical product would remain disconnected.This is why technologies such as QR codes, data matrix codes or other machine-readable identifiers are gaining importance. Currently the focus lies on the QR-Code. There are many reasons for this, but one of the most important is that it is readable with every Smartphone. That means it is very easy accessible for everyone…and that opens another Door à Digital Link for direct Consumer Engagement. See Article 6.

When such codes are applied through direct product marking, these identifiers become permanent elements of the product or packaging.They allow machines, logistics systems and digital platforms to retrieve relevant information instantly.

In other words: 

And that capability will soon become essential for regulatory compliance.

But beyond compliance, this infrastructure also creates something else — new opportunities for transparency, consumer interaction and data-driven services.