Digital product records: UK call for evidence and EU DPP update

On 27 July 2026, the UK Department for Business, Innovation, Science and Trade opened a call for evidence on a digital product record ("DPR") policy, seeking stakeholders’ views on whether and how the UK builds its own framework for providing product information digitally. Responses must be submitted by 21 September 2026.

A DPR - such as the EU's Digital Product Passport (the "DPP") - is a digital record that stores product information so that it is easily accessible and updated across a product's lifecycle. The information ranges from manufacturing location and materials to environmental impact, repairability and recyclability. The government's stated aim is to explore whether a DPR could streamline how businesses provide product information, while improving transparency and traceability for consumers and market surveillance authorities. The DPP will apply to obligated products placed on the Northern Irish market due to the Windsor Framework.

This is an opportunity to influence a framework that could reshape how environmental, sustainability and compliance information moves through supply chains and reduce compliance burden through avoiding differing requirements between the EU and Northern Ireland and Great Britain. Businesses are actively encouraged to respond. 

Background and developments: UK DPRs and EU DPPs

DPRs are set to become an increasingly significant part of the global regulatory landscape for products. The UN has created a transparency protocol and in April 2025, UNECE and ISO launched a joint Digital Product Passport initiative aimed at creating a globally applicable framework and improving interoperability between different systems and jurisdictions.

In the EU, the Ecodesign for Sustainable Products Regulation ("ESPR") establishes the framework for DPPs and entered into force in the EU and Northern Ireland in July 2024. DPPs under the ESPR are not yet operational, but the DPP Registry is now open and accessible in a testing environment. This means businesses exporting to the EU, and Northern Ireland, will need to comply with its requirements. Sector-specific obligations are already being layered on for batteries, toys, construction products, surfactants and detergents.  

The timing matters. The first mandatory DPP requirements enter into force for batteries and construction products in 2027, which is why the government regards this as an important moment to explore the UK's own approach. Monitoring the parallel consultations on toys, construction products and batteries is also advisable.

Overview of the call for evidence

The call for evidence is deliberately focused on the merits of the underlying DPR architecture - the framework for providing product information digitally - rather than the individual information requirements that will apply to specific sectors and are likely to vary and evolve over time. Product-specific requirements will be handled through separate, more targeted engagements on batteries, construction products, toys and low carbon industrial products. 

The UK has signaled a clear appetite for digitalisation as part of wider efforts to reduce regulatory burden, announcing labelling reforms that will allow information such as the UKCA marking and importer details to be provided digitally, and setting an ambition for product labelling to be "digital by default", with physical labelling required only by exception or on demand. This call for evidence sits alongside a cluster of related workstreams, including the toy safety regulations call for evidence running until 6 October 2026, the construction products reform consultations that closed on 20 May 2026, work on an Embodied Emissions Reporting Framework focused initially on steel, cement and concrete, and a Defra-led review of producer responsibility rules for batteries. A central question posed to respondents is whether any future system should be interoperable with the EU and Northern Ireland regimes - for example through a single data carrier - or tailored specifically to the Great Britain market. 

EU comparison

On the EU side, the picture is one of phased implementation. Requirements begin with batteries in February 2027, with further sector-specific detail — including identifiers, data carriers and access rights — to follow through delegated acts covering areas such as iron and steel, aluminium, electronics and ICT, textiles and apparel, furniture and mattresses, detergents and construction products. Obligations may fall on a broad range of supply chain actors, including manufacturers, importers, distributors, recyclers and refurbishers.  

Implications for businesses 

The most significant impacts for businesses depend on whether the outcome is divergence between the UK (GB) and the EU, or further alignment. The call for evidence expressly seeks views on the impacts businesses would face if separate rules governed DPRs in Great Britain, Northern Ireland and the EU. Businesses selling across those markets could find themselves managing parallel information and labelling requirements, with the risk of dual compliance burden. Cost is a related concern: the consultation anticipates both one-off transition costs, such as staff training, IT system changes, data collection and labelling, and ongoing costs for data management and supplier engagement. There is also a data-readiness dimension, as many businesses may not currently collect or create the product and supply chain information a DPR would require, and some may struggle to obtain it from suppliers. 

There are real potential benefits to DPR adoption. The UK government points to reduced time spent gathering supplier information, improved compliance assurance, more efficient cross-border compliance, faster product recalls, better end-of-life management and greater supply chain transparency.  At the same time, respondents are invited to identify drawbacks such as higher reporting costs, integration challenges and risks to commercially sensitive information. 

Recommendations

Given the open question over interoperability, businesses trading across the GB, Northern Ireland and EU markets should form a view on whether a divergent or aligned GB regime would serve them better, as this is precisely the kind of evidence the government is seeking. Responding to the call for evidence is an opportunity to shape the outcome.