DPP vs EPREL Product passport versus energy-labelling database

DPP is the ESPR mechanism for making product information available across the value chain. It is expected to improve access to relevant information, end-to-end traceability, and competent-authority work without exposing confidential business information beyond the access rights set for the product group.

EPREL is not described in the grounding as a general sustainability passport. It is the European Product Registry for Energy Labelling and is discussed as the product database/registry connected to energy labels.

Do not call an EPREL record a DPP unless the applicable ESPR delegated act and DPP technical requirements are also satisfied.

DPP requirements arise under ESPR information requirements for product groups. ESPR is broad and can cover sustainability, circularity, value retention, reuse, remanufacturing, recycling, and legal-compliance information depending on the product-specific rules.

EPREL is tied to energy-related products and energy labels under the Energy Labelling Regulation. ESPR expressly says Regulation (EU) 2017/1369 applies in parallel to ESPR for energy-related products.

Start by asking whether the product is covered by an ESPR delegated act requiring a DPP, whether it is energy-labelled, or both. The overlap is product-specific, not automatic.

DPP data is product-passport data. ESPR says the passport can be specific to the item, batch, or product model, with the level selected in the product-specific delegated act. ETSI describes DPP information as product-specific data conveyed through a unique identifier.

EPREL grounding is model-and-label oriented: energy labels identify a model and link via QR code to EPREL for additional technical specifications and information. The provided grounding does not support treating EPREL as an item-level lifecycle passport.

Map DPP data at the granularity required by the ESPR delegated act. Reuse EPREL model data only where the same attribute, product group, and access need are explicitly supported.

DPP access is role-based. ESPR names customers, manufacturers, importers, distributors, dealers, repairers, recyclers, market surveillance authorities, customs authorities, and others, but access is controlled by the rights set in the delegated act. Rights to introduce, modify, or update data are also restricted.

The grounding supports EPREL as an energy-label database that consumers can reach from a label QR code for additional technical specifications and information. It does not support broad claims about EPREL write permissions, restricted fields, or authority workflows.

For DPP, design access control and update authority as part of the passport architecture. For EPREL, keep claims to the energy-label/product-database function unless separate EPREL-specific source material is added.

DPP must be linked to a unique product identifier. Where appropriate it can also link to unique operator and facility identifiers. ESPR requires the passport to be accessible by scanning a data carrier such as a watermark or QR code, preferably on the product itself where possible.

EPREL appears in the grounding through energy-label QR access. The JRC label material describes QR codes on energy labels as links to EPREL; it does not establish EPREL as the DPP data carrier or passport identifier system.

A physical QR code can be involved in both user experiences, but the encoded target and identifier governance must be checked separately.

DPP is designed as a decentralised data system set up and managed by economic operators, with a Commission-managed registry storing at least unique identifiers and, for customs release, commodity codes. The Commission also has to provide a public web portal for searching and comparing passport data according to access rights.

EPREL is an existing Union database/tool that ESPR says the Commission should consider linking to the DPP where feasible. That makes EPREL a possible linked system, not the same as the DPP registry.

Architect integrations as links between systems. Do not collapse the DPP registry, DPP web portal, economic-operator passport data stores, and EPREL into one internal data model.

DPP has explicit customs mechanics in ESPR. Once the registry is operational, a person placing a covered product under release for free circulation must provide or make available the unique registration identifier, and customs checks the identifier and commodity code against registry data.

The provided EPREL grounding does not establish equivalent customs mechanics for EPREL. EPREL may remain relevant to market information for energy-labelled products, but customs-release claims should be tied to the DPP registry when relying on these sources.

Keep customs and border-control implementation on the DPP registry path unless separate EPREL-specific customs sources are added.

DPP can potentially reuse existing product information where the delegated act permits it and the data fits the required passport field, granularity, access level, freshness, and identifier mapping.

EPREL data may be a useful source for energy-label and model-level information, but the grounding does not support using EPREL as a complete DPP data source for circularity, repair, substances, lifecycle, supply-chain, or customs-registry fields.

Reuse EPREL data as a mapped input, not as a compliance shortcut. Keep a field-by-field trace showing the source, passport field, access rule, and update owner.

DPP can sit behind an ESPR label or other product information route. ESPR says labels can include data carriers or other means to access additional information, including the DPP.

EPREL is strongly tied to the energy label in the grounding: the JRC material describes energy labels with QR codes linking to EPREL, and ESPR says energy labels remain a successful instrument for energy-related products.

For an energy-related product, decide whether ESPR information can be supplementary information on the energy label, whether a separate ESPR label is needed, and whether DPP access belongs on or near that label.