The Digital Product Passport (DPP) represents one of the key instruments of the European Union’s new regulatory framework aimed at promoting the circular economy and sustainable products. The concept aims to ensure that every product placed on the EU market has a digital record containing information on the origin of raw materials, composition, emissions, repairability, recyclability, and overall environmental impact. Although the first phase of implementation will focus on sectors such as batteries, textiles, electronics, and construction products, the model is expected to gradually expand to an increasing number of product categories. For SMEs in Bosnia and Herzegovina, this means that the ability to collect, verify, and structure product data will become a direct requirement for market access and cooperation with EU buyers, reflecting the broader trend in which sustainability is increasingly becoming part of business reliability and standard market expectations.
In practice, the Digital Product Passport requires companies to maintain structured data on the materials embedded in a product, the suppliers of those materials, relevant characteristics of the production process, energy consumption, and any chemicals or substances used in manufacturing. This information will no longer remain solely internal documentation but will be accessible to buyers, distributors, authorities, and often end users through digital platforms, typically connected to a QR code or similar identifier on the product. As a result, transparency is no longer an added value but a standard requirement, and companies that lack organized data flows risk slower negotiations, additional verification procedures, or even loss of business opportunities.
For SMEs, the greatest challenge, beyond adopting appropriate technologies, will be organizing data and responsibilities: determining who collects which data, from which sources, how the data is updated, who approves it, and how its credibility is verified. Companies that already maintain basic records on resource consumption, suppliers, and production processes will have an advantage, as they will be better positioned to translate existing practices into the formats required by the market. In this sense, the DPP builds on digital traceability, well-organized technical documentation, and a minimum set of internal procedures that can be consistently applied.
An important aspect of the discussion is also the timeline for implementation. The ESPR entered into force in 2024, but the mandatory application of the Digital Product Passport will be introduced gradually, sector by sector, through delegated acts that define specific data requirements and deadlines. The first obligations are expected from 2026 for certain product categories, starting with specific categories of industrial and EV batteries, followed by textiles, electronics, construction products, and other products with a high environmental impact between 2026 and 2030. For this reason, it is crucial for SMEs to establish at least a basic system for data collection and management early on, as such requirements often first appear as commercial conditions imposed by buyers before becoming formal regulatory obligations.
Regarding the scope of application, the Digital Product Passport will apply to products placed on the European Union market, regardless of whether they are produced within or outside the EU. Responsibility primarily lies with the entity placing the product on the EU market for the first time (either the manufacturer or the importer, depending on the business model), but in practice the requirements extend across the entire supply chain. EU importers and distributors will request accurate and structured data from suppliers in Bosnia and Herzegovina before products are placed on the market. In this sense, the Digital Product Passport represents not only a regulatory change but also a market transformation: product information is becoming almost as important as the product itself. SMEs that organize their data, traceability systems, and internal responsibilities in a timely manner will be able to demonstrate compliance, quality, and sustainability more quickly, thereby maintaining and expanding their presence on the EU market.
