and the Detergent Regulation to name a few. They also complement broader frameworks such as the Waste Framework Directive, the Corporate Sustainability Reporting Directive (CSRD), and initiatives on critical raw materials. These regulations collectively aim to reduce waste, improve resource efficiency, and enable green procurement practices. On this latter point for example, procurement policies may set thresholds for sustainability performance, influencing tender outcomes.
However, as sector-specific legislation evolves, there is a risk of fragmentation. Without harmonised standards, each product category could develop its own approach to DPP implementation, creating complexity for manufacturers operating across multiple sectors. Standardisation, both in data structure and IT architecture, will therefore be critical to success.
Scope of application
The initial work plan under ESPR identifies a broad range of priority product groups for Digital Product Passport implementation such as textiles, tires and furniture to name a few. Intermediate products are also in scope, such as iron, steel and aluminium. These specific groups were identified following a consultation process and will be worked on during 2025–2030. For our industry, lubricants have been identified as a product category under consideration but have been excluded from the first work package so efforts will most likely begin in subsequent work packages from 2030. That said, the building out of infrastructure and processes for DPPs in general should be monitored to stay updated on what is likely to be in place for lubricants. Additionally, a product group called chemicals was highly ranked by the consultation but was also acknowledged to be complex. A study on chemicals is expected to begin by the end of 2025 to determine it’s future scope and inclusion into working plans. This development strongly suggests that lubricants and related products will be incorporated in future phases, making early preparation essential for industry stakeholders.
Data requirements and granularity The precise data requirements for Digital Product Passports will be determined through specific product-group legislation, but the ESPR already outlines three fundamental categories. The first
14 LUBE MAGAZINE NO.190 DECEMBER 2025
category addresses performance requirements, which include attributes such as durability, reliability, upgradeability, and repairability. The second category focuses on environmental indicators, encompassing energy and water efficiency, resource utilisation, recyclability, and the presence of substances of concern. The third category relates to circularity aspects, such as the potential for remanufacturing, refurbishment, and material recovery.
In addition to these categories, the level of detail required for each passport will vary according to product complexity. For standardised products, a model-level approach may suffice, while production runs with minor variations could require batch-level granularity. High-value or safety-critical goods, on the other hand, are likely to demand item-level detail to ensure complete traceability and compliance.
Technical architecture: The “what” and the “how”
The DPP framework consists of two interdependent components: the “What” and the “How.” The “What” refers to product-specific data requirements, which will be defined through legislation for each product group. The “How” relates to the IT infrastructure enabling data exchange, including a searchable web portal, APIs for lifecycle management, and standards for interoperability. The system will likely adopt a decentralised storage model, with EU central services providing governance and access control. Market surveillance authorities will have restricted access to sensitive data, while consumers will view sustainability and performance metrics relevant to purchasing decisions.
Challenges for implementation While the benefits of DPPs are clear, practical challenges remain, particularly for complex products such as lubricants. Questions arise about how passports will function once lubricants are in use, especially in closed systems like engines. There are also concerns about how DPPs will apply to large containers or blended batches, and how data will support recycling and disposal processes for used oils. Additionally, the lubricant supply chain involves multiple intermediaries, from additive suppliers to OEMs. Collecting upstream data and ensuring consistency across stakeholders will require robust collaboration and digital infrastructure.
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