Passports identify people, proclaiming their country of origin so customs and border officials know who is attempting to gain entry into their countries. But starting in 2028, consumer products heading in and out of Europe will require their own version of a passport so consumers know what they’re getting.

On July 18, 2024, the European Union adopted the Ecodesign for Sustainable Products Regulation (ESPR), a new framework for sustainable design requirements in consumer products (excluding food and medicine). As part of this legislation, each item imported into or manufactured in the EU will soon require a digital product passport in the form of a QR code that proves the product is legitimate, and provides consumers with information like how and where it was produced and what its carbon footprint looks like.

Green movement
Both of these initiatives are part of a wider European Green Deal that was approved by the EU in 2020. The overarching goal is to make Europe a net-zero emitter of greenhouse gases by 2050 through regulating industries such as farming, biodiversity and building renovations, and promoting a circular economy that reuses, refurbishes and recycles resources.

The first working draft of this ESPR plan is expected to be ready by the end of Q2 2025, and it will outline all of the mandated data for building a DPP in each product category. Early iterations After rolling the dice on an early DPP for Products of Change, UK consultancy Fabacus is now helping Hasbro, Activision Blizzard, Paramount Global and Ubisoft do the same have listed several requirements that both licensors and manufacturers must provide for products aimed at kids, including toys, games and apparel. These specs include information about product composition, sustainability, repair instructions and recycling.

The Green Deal’s policies are ushering in a transformative era of transparency and accountability for the consumer products industry, says Helena Mansell Stopher, CEO and founder of the sustainable nonprofit organization Products of Change (POC).

“DPPs are meant to communicate to consumers the environmental impact of a product, but the core challenge comes when a majority of companies don’t have that information or know who’s responsible for delivering it to them up the value chain,” she says. “There’s no existing infrastructure or systems in place to collect data at this scope; everyone is essentially starting from scratch.”

These new laws will impact all parts of the supply chain, from where factories source their materials, to retailer liability for selling products that aren’t compliant with ESPR standards. In particular, toycos will need to outline the full life cycle of each product, including putting infrastructure in place to recycle, reuse or resell used goods.

Failure to include this info will result in licensed manufacturers being taxed. Under the Extended Producer Responsibility legislation, companies are required to report their total waste from electrical/electronic equipment, packaging and single-use plastics twice a year—and each product’s creator is now responsible for 100% of the net costs for collecting and treating this waste, instead of sharing the responsibility with each link in the supply chain.

“These aren’t even all of the regulations getting moved forward,” says Mansell Stopher. “There are almost 60 pieces of legislation that will hit the global consumer products industry by 2030, and most of them will come into effect in 2026.

Filing in the gaps
Products of Change developed one of the first digital passports in November 2023, partnering with English ceramic manufacturer Pure Table Top to design a new mug for its POC Sustainability Conference in London. By scanning the QR code attached to the price tag or the bottom of the mug itself, readers can see the product’s full manufacturing journey, including which factory in China assembled all of the pieces, and a complete carbon-footprint report—right down to its specific tariff codes and certificates.

But POC and Pure Table couldn’t pull this off alone. Early on in production, the partners teamed up with Amsterdam-based impact measurement firm Dayrize and UK data consultancy Fabacus to construct the mug’s DPP together.

Dayrize CEO Austin Simms says the experience was a great way to show conference attendees the data-collection process and demonstrate how Dayrize’s AI-powered tools can help toycos and game developers begin to create an internal sustainability database.

“There’s just a natural symbiotic relationship between Fabacus and us, because they get the product data from the company, and then our tool turns that data into impact information,” Simms explains. “So now, you’ve actually got not just the story about the product and where it’s been, but where it will be at each stage of its life cycle.”

Simms adds that every organization Dayrize works with—including Google and the Retail Council of Canada—is missing data in its supply chain, which means his firm has to collect as much info as possible from a company, and then leverage Dayrize’s internal data spanning more than 30 million SKUs to fill in the missing gaps.

For example, Simms says Dayrize’s software can accurately assess the environmental impact of a kids graphic hoodie just by knowing that its 200 grams of cotton came from Bangladesh. The tool can then predict which factory produced it and how much energy was used to process the cotton into a new garment. This results in a rating of how much energy was generated from fossil fuels versus solar.

Even digital products like video games from major developers like Ubisoft and Activision Blizzard will need DPPs to track each title’s carbon footprint and energy consumption.

“Tools like this are really important to companies, because if we had to wait for everyone to have perfect data, no one would be able to do a digital product passport” or include data from five years back or more in the mandatory reports, says Simms.

He adds that today’s sustainability talking points—such as packaging and last-mile delivery—only account for 10% of a product’s overall impact on the environment. In reality, this impact starts far earlier, when decisions are made about things such as material type and how many design iterations are needed prior to full production.

Once Fabacus has collected all of that impact data, it assembles the pieces into a DPP. And while this technology is at an early stage of development until mandates are ironed out, partners such as Hasbro, Activision Blizzard, Paramount Global and Ubisoft are quickly jumping on board with multi-year deals to ensure their business operations are compliant and as up-to-date as possible.

An added benefit of adopting DPPs is that digital verification and traceable data points can serve as a first line of defense against counterfeit products, which cost the global industry US$2 trillion a year, says Fabacus founder and CEO Andrew Xeni.

While the system is not yet fully developed, DPPs can also be paired with additional applications like near-field communication technology to improve effectiveness and mitigate the risk of consumers getting taken in by counterfeit goods at retail or fraudulent listings online.

“This is important for brands with high IP value because counterfeiting dilutes brand value and can raise safety and quality concerns, particularly in the toy industry,” says Xeni. “As more companies see the value of DPPs in connecting with consumers and regulators, demand for digital transparency tools in this sector is likely to expand, shaping how brands manage and report on their product ecosystems.”

This story originally appeared in Kidscreen‘s Q1 2025 magazine issue.