Depiction of New study examines the cost of implementing Digital Product Passports in the EU ahead of mandatory requirements from early 2027

New study examines the cost of implementing Digital Product Passports in the EU ahead of mandatory requirements from early 2027

Today, Oxera released a new study commissioned by Amazon, examining the costs businesses are likely to face when implementing and operating Digital Product Passports (DPPs) in the EU. The study identifies the factors that influence these costs, how policymakers can reduce the burden on firms and how businesses can ready themselves.

DPPs are a scannable digital record that gives consumers instant, verified information on factors such as a product’s origin, repairability, and environmental impact. Under the EU’s Ecodesign for Sustainable Products Regulation (ESPR), DPP requirements will be introduced in stages from 18 February 2027. The first mandatory requirements will apply to batteries, followed by other sectors including toys, detergents and textiles. DPPs are expected to be rolled out in other sectors at a later date.

The study follows a previous Oxera report, commissioned by Amazon, to assess the benefits of DPPs, and sheds new light on how implementation and ongoing costs could vary across firms and sectors. Factors including firm size, digital maturity, product range, supply-chain complexity and existing sector regulation influence the costs firms face. SMEs and less digitally mature businesses are likely to face relatively higher costs, however, the study sets out practical steps that businesses can take to manage these costs, including using existing digital systems, third-party solutions and shared industry infrastructure.

DPPs can deliver net benefits, but the balance between costs and benefits will depend on how requirements are designed and implemented. In the European Commission’s impact assessment for toy DPPs, Oxera estimates that each €1 spent on implementing DPPs could generate €1.60 in benefits. If variable costs for DPPs are 20% higher than expected, this would fall to €1.30, showing how higher implementation costs could affect value for money.

David Jevons, Partner at Oxera, said: ‘Our analysis shows that the costs of implementing Digital Product Passports are likely to vary significantly across businesses. Requirements that are manageable for larger, digitally mature firms may place a greater burden on SMEs. Proportionate requirements and interoperable standards are important to ensure DPPs deliver maximum value for money.’

Amber Bechrouri, Director of Consumer, Product and Sustainability Policy at Amazon, said: ‘Amazon supports the EU’s Digital Product Passports initiative. Clear requirements and common standards will give businesses greater certainty as they prepare for the transition.’ Oxera’s study recommends that the European Commission takes account of differences in firm size and digital maturity when designing DPP requirements and implementation timelines. It also highlights the importance of proportionate requirements, timely regulatory clarity and consistency across product categories to help ensure that DPPs deliver strong value for money.

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