Compliance guide
The Digital Product Passport and what it means for food and drink
The Digital Product Passport (DPP) is one of the most talked-about ideas in EU product regulation, and plenty of food and drink makers are asking whether they need one. The short, honest answer for 2026 is no: food and feed are outside the scope of the law that creates the DPP. This guide explains what the DPP actually is, why food sits outside it, and how getting your product and batch data structured now prepares you for the digital-transparency rules that do already touch food and drink.
Guidance only, not legal advice · Reviewed 2026 against Regulation (EU) 2024/1781 (ESPR) on EUR-Lex and the European Commission Ecodesign for Sustainable Products pages.
What the Digital Product Passport actually is
The Digital Product Passport is introduced by the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, which entered into force on 18 July 2024. It is a structured, machine-readable record of a product carrying information such as materials, durability, repairability, recycled content and supply-chain data.
Practically, a DPP is a data carrier printed on or attached to the product, such as a QR code or a digital watermark, that links to a standardised set of product information held in a registry and made available through a public web portal. Scanning the carrier lets buyers, repairers, recyclers and authorities see the same trusted data.
The DPP is not switched on for everything at once. The ESPR sets the framework, and detailed requirements are rolled out product group by product group through delegated acts. Early priority groups include textiles, furniture, iron and steel, aluminium, tyres and certain electronics, each with its own timeline and its own required data fields.
Does the Digital Product Passport apply to food and drink?
No. As of 2026, food and drink are outside the scope of the ESPR, so no DPP is currently mandated for food, beverages, or animal feed. This is not an oversight or a delay you are waiting on; it is written into the law.
Recital 13 of Regulation (EU) 2024/1781 states that the regulation should not apply to food and feed as defined in Regulation (EC) No 178/2002, because those products are already governed by their own dedicated frameworks. The exclusion is also set out in the regulation's scope provisions, and Ecodesign requirements are simply not designed for edible products.
What this means in plain terms:
- If you make beer, wine, cheese, bread, ferments, spirits, sauces or any other food or drink, the ESPR Digital Product Passport does not require anything of you today.
- You do not need to buy a DPP solution or register your products in the ESPR product-passport registry.
- Be sceptical of vendors implying that a mandatory food DPP already exists; it does not.
- This could change in future through separate legislation, which is exactly why structured data is worth building now rather than later.
The digital-transparency rules that do affect food and drink
While the DPP itself does not reach food, the wider move toward digital, scannable, data-backed product transparency very much does. Several rules already ask food and drink producers to structure and disclose product information, and more are on the way.
Rules already in force or scheduled:
- Wine e-labelling: Regulation (EU) 2021/2117 requires wine products to carry a full ingredient list and nutrition declaration, which may be provided digitally via a QR code e-label. It has applied since 8 December 2023, with wine produced before that date allowed to be sold until existing stocks are exhausted.
- EU Deforestation Regulation (EUDR): Regulation (EU) 2023/1115 covers commodities including coffee, cocoa, cattle, palm oil, soy, rubber and wood, plus derived products such as chocolate, requiring geolocation and due-diligence data. After a further delay adopted in December 2025, it applies from 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small enterprises.
- General food traceability: Regulation (EC) No 178/2002 already requires one-step-back, one-step-forward traceability, so you can identify who supplied an ingredient and who received your product.
- QR-based labelling in general: even where not mandatory, scannable links to ingredients, origin and batch information are becoming a baseline consumer expectation.
QR codes and e-labels: what they must and must not do
The wine e-label rules are the closest existing analogue to a DPP for drink producers, and they set useful expectations for any scannable label you build. Mandatory safety information stays on the physical label while detail can move to a scannable page.
Wine e-label expectations worth copying:
- Allergens (for example, contains sulfites) and the energy value must remain on the physical label, not hidden behind a QR code.
- The ingredient list and full nutrition declaration may be delivered via the QR e-label.
- The page the QR code opens must be neutral: no marketing content, no advertising, and no user tracking or analytics cookies.
- Each product needs its own unique link; a single generic QR code shared across different products is not acceptable.
The lesson for any maker is that a good digital label separates trustworthy, neutral product data from marketing, and ties each link to a specific product and, ideally, a specific batch.
How to get ready now without over-investing
You do not need a Digital Product Passport for food today, but you do benefit from having clean, structured product and batch data. That single foundation satisfies wine e-labelling, supports EUDR due diligence, strengthens traceability, and would make any future food-specific transparency scheme far easier to adopt.
- Give every product a stable identifier and keep a single source of truth for its recipe, ingredients, allergens and nutrition data.
- Record data at batch level, so each production run links to its inputs, suppliers, quantities and dates.
- Capture supplier and origin details for ingredients, especially any EUDR commodities such as cocoa, coffee or palm oil.
- Keep ingredient and nutrition information in a structured, exportable form rather than only inside label artwork.
- If you sell wine, publish a compliant, neutral e-label page and link it from a per-product QR code.
- Review your data annually so that when a new rule or scannable-label expectation lands, you can respond by exporting rather than rebuilding.
How fermt helps
fermt keeps your products, recipes and production batches in one EU-hosted system, so the underlying data that any digital-transparency rule asks for is already structured and traceable. Because every batch links back to its inputs, suppliers and quantities, you can trace one step back and one step forward without digging through spreadsheets or paper.
That means you are ready for the transparency trend the DPP is part of, from wine e-labels to EUDR due diligence, and well positioned for whatever food-specific rules may follow, all from the batch and production data you already record to run your business.
- Single source of truth for each product's recipe, ingredients, allergens and nutrition data
- Batch-level records that link every production run to its inputs, suppliers, dates and quantities
- One-step-back, one-step-forward traceability aligned with EU general food law expectations
- Exportable, structured product and batch data ready for QR e-labels and supplier due-diligence requests
Frequently asked questions
Do I need a Digital Product Passport for my food or drink product?
No. As of 2026, food and feed are outside the scope of the ESPR, Regulation (EU) 2024/1781, which creates the Digital Product Passport. No DPP is currently mandated for food or drink, so there is nothing to register or buy for that specific requirement today.
Why is food excluded from the Digital Product Passport?
Recital 13 of Regulation (EU) 2024/1781 states the regulation should not apply to food and feed as defined in Regulation (EC) No 178/2002, because those products already have their own dedicated regulatory frameworks. Ecodesign requirements are simply not designed for edible products.
What is a Digital Product Passport in simple terms?
It is a structured digital record of a product's key information, such as materials, durability and supply chain, reached through a data carrier like a QR code or watermark on the product. It is being rolled out product group by product group, starting with categories such as textiles, aluminium and steel, not food.
Which digital rules actually affect food and drink producers now?
The most relevant are wine e-labelling under Regulation (EU) 2021/2117, the EU Deforestation Regulation (EU) 2023/1115 for commodities such as coffee, cocoa and palm oil, and general food traceability under Regulation (EC) No 178/2002. Together they push makers toward structured, scannable, data-backed transparency.
If wine needs a QR e-label, is that a Digital Product Passport?
No. The wine e-label under Regulation (EU) 2021/2117 is a separate requirement for ingredients and nutrition information and is not the ESPR Digital Product Passport. It is a useful preview of the same trend, though: a scannable link to neutral, per-product data.
Should I prepare for a food Digital Product Passport anyway?
Preparing your data is worthwhile, even though the passport itself is not required. Keeping structured product and batch records now satisfies existing rules like wine e-labels and EUDR, improves traceability, and would make adopting any future food-specific transparency scheme a straightforward export rather than a rebuild.