Good morning Sustainability Managers,
As I mentioned in my last article, this newsletter is all about you and I have listened.
In fact, after this Q&A on EPDs, we will kick off a new season dedicated to ecodesign and sustainable product development (I'm not a fan of buzzwords, but we will use them for simplicity).
Bando alle ciance, let’s dive into today’s episode: 20 Questions, 21 Answers about the EPD-DPP evolution.
1. Is a Digital Product Passport just a digitized EPD?
No. An EPD is a static snapshot of a product’s environmental performance based on a Life Cycle Assessment. The DPP is a dynamic, trackable vehicle. While the EPD provides the environmental data, the DPP also houses circularity metrics, origin tracing, legal compliance and real-time lifecycle events (like repairs or recycling)
2. Can an EN 15804-compliant EPD automatically populate the environmental section of a DPP?
In theory, yes, if the data is machine-readable (e.g. ILCD format). However, the DPP framework under the Ecodesign for Sustainable Products Regulation (ESPR) will likely require specific APIs. Your PDF EPD won’t cut it; the underlying XML/JSON datasets will be the actual fuel for the DPP.
3. Do ISO 14040/44 LCA methodologies need to change to fit the DPP?
The core physics of LCA won’t change, but the resolution must. ISO 14040/44 allows for broad system boundaries and generic background data. The DPP demands granular, product-specific and sometimes batch-specific data. The methodology remains, but the data collection rigor scales up immensely.
4. EPDs are historically B2B. Is the DPP strictly B2C?
The DPP bridges B2B, B2C, and B2G (Business-to-Government). It acts as a B2B supply chain tracker, a B2C transparency tool (via QR codes), and a B2G compliance mechanism for market surveillance authorities.
5. How does the concept of a “Functional Unit” in an EPD translate to a serialized DPP?
EPDs use a representative functional unit (e.g. “1 ton of steel”). A DPP is often tied to a specific, serialized item (e.g. “Steel Beam #4920”). Companies will need to build scaling algorithms to translate the functional unit’s LCA impacts down to the specific mass/volume of the serialized item tracked by the DPP.
6. If an EPD has a 5-year validity, does the DPP expire too?
The DPP is a living ledger, it doesn’t “expire,” but it gets updated. However, the environmental claims inside the DPP (powered by the EPD) will still be subject to verification cycles. If your underlying LCA expires, your DPP’s environmental metrics become non-compliant.
7. Can the DPP handle multi-product “average” EPDs?
Regulators are moving away from industry averages. While sector EPDs are great for benchmarking, the ESPR mandates that a DPP reflects the specific model or batch. Average EPDs will struggle to meet the strict traceability requirements of a DPP.
8. How does the DPP integrate end-of-life (EoL) scenarios compared to EPD Module C?
In an EPD, Module C (End of Life) is a modeled, hypothetical scenario (e.g. “assuming 80% recycling”). The DPP changes this from a hypothesis to a recorded fact. When the product is actually recycled, the recycler can update the DPP, replacing the modeled Module C with primary EoL data.
9. Will the DPP require primary data for everything, killing secondary LCA databases?
Secondary databases (like Ecoinvent) aren’t dying, but their role is shifting to the deep background. You will still use them for upstream generic processes (like grid electricity), but the DPP will mandate primary, supplier-specific data for core materials and manufacturing.
10. How do Product Category Rules (PCRs) align with DPP delegated acts?
PCRs are currently managed by Program Operators (like Environdec or IBU). DPP data requirements will be dictated by European Commission Delegated Acts. Moving forward, PCRs will have to strictly align with these Delegated Acts or they will become legally irrelevant in the EU market.
11. Will the DPP make EPD Verification bodies obsolete?
Not obsolete, but their business model will change. Instead of verifying static 30-page PDFs, verifiers will need to audit automated LCA pipelines and API endpoints that continuously feed data into DPPs.
12. Can a DPP host an ISO 14021 (self-declared) claim instead of a verified Type III EPD?
Under the upcoming Green Claims Directive and ESPR, self-declared environmental claims are facing heavy restrictions. For a DPP to display carbon footprint or environmental impact, it will almost certainly require third-party verification (Type III), shutting the door on unchecked self-declarations.
13. Does the DPP solve the “comparability” issue that EPDs have historically struggled with?
Partially. Because the ESPR will define strict, unified rules for how data is calculated and presented per product group, the DPP will force a level of standardisation that fragmented PCRs never could.
14. What happens if an EPD is updated due to a manufacturing change, how does the DPP react?
For an EPD, you publish a new version. For a DPP, the product’s digital twin is updated via API. Products manufactured after the change will carry the new data; products manufactured before retain the historical data. The DPP handles this chronologically.
15. Will the DPP require sharing proprietary LCA foreground data?
This is the biggest fear in the industry. The DPP is designed with tiered access rights. Consumers will see the final impact scores (the “what”), while regulators or supply chain partners might have access to specific material inputs (the “how”), protected by strict intellectual property rules.
16. Are Scope 3 emissions calculated via LCA for an EPD the same as what the DPP requires?
Philosophically, yes; practically, no. EPDs focus on the product level (cradle-to-grave). Scope 3 corporate reporting (GHG Protocol) looks at the company level. The DPP will act as the ultimate bridge, allowing buyers to take the product-level LCA data from the DPP and plug it directly into their corporate Scope 3 inventories.
17. Will EPD software tools automatically become DPP generators?
The smart ones will. EPD generators already hold the parametric LCA models. By adding traceability modules and API outputs, these platforms will evolve into comprehensive DPP engines.
18. Can small-to-medium enterprises (SMEs) use EPDs as a shortcut to DPP compliance?
Yes. If an SME has already invested in generating a robust, digitized EPD, they have done 80% of the heavy lifting for the environmental requirements of the DPP. The remaining 20% is IT infrastructure and supply chain tracing.
19. What is the biggest risk for companies ignoring the EPD-to-DPP transition? Market lock-out. EPDs used to be a premium marketing tool, the DPP makes them a legal market-entry requirement in Europe. No DPP, no CE mark. No CE mark, no sales.
20. Will the DPP eventually kill the EPD?
Yes. The traditional EPD, a beautifully designed 30-page PDF document hosted on a program operator’s website, will become a relic. The market won’t have time to read PDFs, algorithms will just query the DPP’s data layer.
But also, No. The EPD isn’t dying, it’s shedding its skin. The strict, standardized, verified methodology of the EPD (ISO 14025, EN 15804) will become the invisible engine that calculates the environmental metrics inside the DPP. The EPD will stop being a document and start being a data protocol.
That’s all for today, If you have more questions about EDP-DPP, feel free to reach out to info@gianlucamanago.com
See you next week,
Gianluca
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