The EU Ecodesign for Sustainable Products Regulation (ESPR) establishes a digital product passport framework; this does not mean every product or transport package carries a passport today. Obligations depend on the relevant product-group provision and application schedule.
If someone claims a DPP is required for a product or package, verify the ESPR article, product-group measure, economic-operator role and application date in the EUR-Lex text. The PPWR regulates packaging separately; do not combine PPWR and ESPR as if they were the same obligation.
You can build an optional data file now: product or packaging model, materials and weight, repairable parts, maintenance/repair history, use and end-of-life guidance. Link each claim to its evidence source, date and identity. Collecting data does not mean every item is legally required.
For a reusable-container fleet, linking movement records to item identity can show actual rotations and repair history. When requesting technical sheets and material declarations, request model/configuration, data version and substantiation too. If a buyer requests a data format, record separately whether it is contractual or an applicable legal provision.
