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Digital Product Passport for Food — Requirements, Timeline and Preparation

Digital Product Passport for the food industry: What the EU regulation means for food manufacturers. ESPR requirements, traceability, sustainability data, and the expected timeline for food products.

Author: myDPP Team

Digital Product Passport for Food — Requirements, Timeline and Preparation

The food industry faces a new transparency push from the EU. With the ESPR (Ecodesign for Sustainable Products Regulation), the European Commission is creating the framework for Digital Product Passports (DPP) across virtually all product categories — food and beverages included. For an industry already subject to strict labelling and traceability requirements, the DPP adds a new dimension: digital, machine-readable and lifecycle-spanning product data.

This article explains what the Digital Product Passport means for the food industry, what data requirements are emerging, when the obligation is expected, and how manufacturers, processors and retailers can prepare.

For a general introduction to DPP: Digital Product Passport in 15 Minutes.

Why Food Is Relevant for the DPP

The food industry is the EU’s largest manufacturing sector, with over €300 billion in annual revenue. At the same time, it sits at the centre of environmental and societal debates:

  • Environmental impact — Food production accounts for roughly 26% of global greenhouse gas emissions. Consumers and regulators increasingly demand transparency on the carbon footprint of food products.
  • Supply chain complexity — Raw materials pass through numerous processing stages and cross borders multiple times. Farm-to-fork traceability remains a central challenge.
  • Food waste — Approximately 59 million tonnes of food are wasted annually in the EU. Better data on shelf life, storage conditions and packaging can make a meaningful contribution.
  • Packaging intensity — Food packaging accounts for a significant share of packaging waste. The EU Packaging and Packaging Waste Regulation (PPWR) already sets new requirements here.
  • Greenwashing risks — Terms like “natural”, “regional” or “sustainably produced” are frequently used without verifiable data to back them up.

The DPP aims to create transparency across all these areas: not through marketing claims, but through verifiable, structured data at product level.

Regulatory Framework — ESPR and Food Law

The regulatory landscape for food is already complex. The DPP adds an additional layer and will likely be governed by the ESPR (Regulation (EU) 2024/1781).

At the same time, numerous existing regulations will influence the DPP:

  • EU Food Information Regulation (FIR, Regulation (EU) No 1169/2011) — governs food labelling (ingredients, allergens, nutrition). The DPP will complement these obligations digitally.
  • General Food Law (Regulation (EC) No 178/2002) — already requires one-step-back, one-step-forward traceability. The DPP could extend traceability across the entire chain.
  • Farm to Fork Strategy — the EU strategy for sustainable food systems explicitly calls for better consumer information and digitalisation.
  • Packaging and Packaging Waste Regulation (PPWR) — sets requirements for packaging data that will flow directly into the DPP.
  • Green Claims Directive — will regulate environmental claims and could establish direct links to the DPP.

What Data Will the Food DPP Contain?

The final data requirements depend on the delegated acts. Based on the ESPR framework, existing food regulation and the sustainability agenda, the probable data requirements can be outlined:

Composition and Ingredients

  • Complete ingredient list in machine-readable format
  • Allergens and intolerances (per FIR Annex II)
  • Nutrition declaration in structured form
  • Information on substances of concern (pesticide residues, contaminants)
  • Origin of main ingredients (primary ingredient origin per Implementing Regulation (EU) 2018/775)

Environmental and Sustainability Data

  • Carbon footprint (Product Carbon Footprint)
  • Water consumption in production (Water Footprint)
  • Land use and biodiversity impacts
  • PEF indicators (Product Environmental Footprint), once methodology is defined
  • Share of organically produced ingredients

Packaging Data

  • Material composition of packaging (primary and secondary)
  • Recyclability per PPWR criteria
  • Share of recycled materials
  • Weight ratio of packaging to product content
  • Disposal instructions per packaging component

Shelf Life and Storage

  • Best-before date or use-by date
  • Recommended storage conditions (temperature, humidity)
  • Shelf life after opening
  • Tips for reducing food waste

Traceability and Identification

  • Unique product identifier (likely GS1-based, GTIN + batch identifier)
  • Batch number linked to the production batch
  • Country of origin and processing location
  • Data carrier (QR code or GS1 Digital Link) on packaging

Certifications and Compliance

  • Organic certifications (EU organic label, Demeter, Soil Association)
  • Sustainability certificates (Rainforest Alliance, Fairtrade, MSC, ASC)
  • EU compliance information
  • Protected designations of origin (PDO, PGI)

Timeline — When Will the Food DPP Arrive?

Unlike the battery passport, which has a defined timeline, there is no binding deadline for food yet. A realistic assessment:

  • 2025–2027 — The Commission develops delegated acts for the first product categories (textiles, iron/steel, aluminium). Food is not in the first wave.
  • 2027–2029 — Development of delegated acts for food categories, industry consultations and impact assessments.
  • 2029–2031 — Likely entry into force of DPP obligations for selected food categories.

The food sector will likely not be in the first ESPR wave, as the boundary with existing food legislation is complex. However, the Farm to Fork Strategy clearly signals that transparency in the food chain is a core political priority.

Companies that wait until the delegated act is published will face significant time pressure. Experience from the Battery Regulation shows that lead times can be short.

Sector-Specific Considerations

Existing Traceability as a Starting Point

The food industry has an advantage over many other sectors: the General Food Law has required traceability since 2005 across the entire food chain. Many companies have established batch tracking systems. The challenge lies in supplementing this data with environmental and sustainability information in a standardised format.

High Production Volumes and Short Lifecycles

Food manufacturers often produce millions of units per day with very short product lifecycles (days to months). A DPP process must be extremely efficient and automated. Manual data entry per batch is not feasible.

Seasonality and Variable Composition

Many food products are subject to seasonal variations in composition. Fruit and vegetables vary by origin and harvest time. The DPP must handle this variability.

Private Label and Contract Manufacturing

A significant share of food production is private label for retail brands. Manufacturers and retailers must clarify who bears DPP responsibility and how data exchange is organised.

Consumer Proximity and Trust Building

Food is the most consumer-facing product segment. The DPP offers a significant opportunity: transparent data on origin, sustainability and quality can strengthen consumer trust and differentiate brands.

Preparation — 5 Steps for Food Companies

1. Audit existing data

Identify which expected DPP data is already available in your systems. FIR-compliant labelling data, batch tracking and supplier data form a solid foundation. Typical gaps exist in environmental data (carbon footprint, water consumption) and detailed packaging data.

2. Deepen supply chain data

Go beyond one-step-back, one-step-forward traceability. Start requesting structured data from suppliers on origin, farming methods, environmental metrics and certifications.

3. Digitise packaging data

The PPWR will impose packaging data requirements independently of the DPP. Capture packaging data (material composition, recyclability, weight) systematically and in a structured format.

4. Assess IT infrastructure

Evaluate whether your existing systems (ERP, inventory management, QM system) can accommodate DPP data. Solutions like myDPP are designed to aggregate data from multiple sources and generate compliant Digital Product Passports.

5. Start a pilot project

Select 3–5 representative products and create a pilot DPP. This process reveals data gaps and shows how much effort scaling will require.

Frequently Asked Questions

Does the DPP replace existing food labelling (ingredient list, nutrition)?

No. The DPP does not replace the physical labelling on packaging per the Food Information Regulation. It supplements it with a digital, machine-readable dimension and enriches it with environmental and sustainability data that cannot fit on the physical packaging.

Will the DPP apply to unprocessed foods (fruit, vegetables, meat)?

The exact product categories will be defined in the delegated acts. It is likely that the DPP obligation will initially be introduced for processed foods with standardised packaging. Fresh produce and unprocessed products may follow in later waves or with simplified requirements.

Does every batch need its own DPP?

The DPP will likely be created at batch level or at trade unit (SKU) level. For products with identical composition, batches may share a DPP, with batch-specific data (production date, best-before date, raw material origin for that batch) added as variable fields.

Further Reading

Sources

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