Does My Product Category Need a Digital Product Passport? Food, Cosmetics, Jewellery and Common Misstatements

Why "every product needs a DPP" is misleading

The Digital Product Passport is a regulatory architecture, not one universal deadline or checklist.

ESPR is a horizontal framework. It establishes how DPP requirements can work, but it does not automatically impose a passport on every product within its broad physical-product scope.

The European Commission's current DPP FAQ states this directly: under ESPR, there is no general obligation for a product to have a DPP. DPP requirements are introduced through a gradual product-by-product process using product-specific rules.⁹

ESPR also contains categorical exclusions. Food and feed are among them.¹

Other DPP regimes can also arise through separate sector legislation. Batteries, detergents and toys demonstrate that "DPP law" is not one single product rule copied across the economy.

This is why three questions must be kept separate:

1. Is the product within the scope of the horizontal framework?
2. Has an applicable product-specific DPP requirement actually been adopted?
3. What other sector law already requires product information even if it is not a DPP?

A market article that answers only the first question can easily overstate the legal position.

How EU DPP requirements are actually created

A useful working model is:

horizontal EU framework ↓ product scope and exclusions ↓ product-specific measure or separate sector law ↓ delegated and implementing acts where required ↓ existing sector-specific law ↓ standards and technical implementation ↓ actual product-data, identifier, carrier and access decisions

This does not mean EU Regulations are somehow optional or non-binding. Regulations can be directly binding.

The complexity comes from the fact that the DPP architecture is assembled through several legal and technical layers, with different layers doing different jobs.

Under ESPR, a product-specific delegated act can determine matters such as:

• whether a DPP is required for the product group
• the information to be included
• the data carrier
• the passport's model, batch or item level
• access arrangements
• other category-specific requirements.¹

That is why "ESPR exists" does not mean "every product already has a passport requirement".

Food

Does food need a Digital Product Passport?

There is no generic ESPR food DPP requirement.

ESPR expressly excludes food as defined in EU food law from its scope.¹

That is a strong legal statement about the ESPR framework.

It is not the same as saying:

Food has no digital product-information obligations.

It is also not the same as saying:

Food can never be subject to another digital information regime in the future.

The correct current statement is narrower:

Food is outside ESPR, so there is no generic ESPR food DPP requirement. Existing food-information and traceability law remains fully relevant.

Food already has substantial structured product information

Regulation (EU) No 1169/2011 on food information to consumers requires defined mandatory particulars for relevant foods.²

Those include, subject to the Regulation's detailed rules and exceptions:

• name of the food
• ingredients
• allergens
• quantity of certain ingredients
• net quantity
• durability or use-by information
• storage or use conditions
• name or business name and address of the responsible food business operator
• country of origin or place of provenance where the applicable rules require it
• other mandatory particulars depending on the food.

That is already a significant product-information architecture.

Traceability is another layer

Article 18 of the General Food Law requires traceability through production, processing and distribution and requires food and feed businesses to be able to identify suppliers and the businesses to which products have been supplied.³

That is a supply-chain control.

It is not a DPP.

Lot identification is another layer

Directive 2011/91/EU establishes rules for indicating or marking the lot to which a foodstuff belongs, subject to its scope and exceptions.⁴

It defines a lot in terms of a batch of sales units produced, manufactured or packaged under practically the same conditions.

Again, that is useful structured identity and traceability data.

It should not be relabelled "Food Digital Product Passport".

Practical food conclusion

A food business should not create a speculative ESPR passport solely because a generic article says all products need one.

It should be able to answer:

• What food law applies?
• Which mandatory particulars belong to this product?
• What traceability records exist?
• How is lot identity governed?
• Where do ingredient and allergen data come from?
• Which operator is responsible for the information?
• Which facts vary by market, recipe, pack size or production lot?

That is valuable product-data work whether or not a DPP is involved.

Cosmetics

Do cosmetics need a Digital Product Passport?

Current primary evidence does not establish one generic EU cosmetics DPP.

Cosmetics are a useful example of why "no generic DPP" must not be read as "no structured regulatory data".

Regulation (EC) No 1223/2009 on cosmetic products already creates a detailed information, safety and notification regime.⁵

The responsible person

Only cosmetic products for which a responsible person is designated in the EU framework may be placed on the market, and the responsible person carries defined compliance responsibilities.⁵

That means operator identity is already a controlled regulatory object.

The Product Information File

Article 11 requires the responsible person to keep a Product Information File, or PIF, for a cosmetic product.⁵

The PIF includes:

• a description enabling the file to be clearly attributed to the cosmetic product
• the cosmetic product safety report
• manufacturing method information and a statement on good manufacturing practice
• evidence supporting claimed effects where justified
• specified information about animal testing.

The PIF must be kept for ten years after the date on which the last batch was placed on the market and made readily accessible to the competent authority under the Regulation's conditions.⁵

This is a substantial governed product record.

It is not a generic DPP.

Electronic notification

Article 13 requires electronic notification to the Commission before the cosmetic product is placed on the market.⁵

The required notification includes defined product and responsible-person information, with additional information depending on the product.

Again, there is already digital regulatory information.

Calling that notification system "the cosmetics DPP" would be inaccurate.

Labelling, batch identity and ingredients

Article 19 requires defined labelling information. It includes:

• responsible-person name and address
• country of origin for imported cosmetic products
• nominal content
• durability information where applicable
• precautions
• batch number of manufacture or another product-identification reference
• product function where not clear from presentation
• a list of ingredients.⁵

This means a cosmetics business already has strong reasons to control:

• product identity
• formulation and ingredient data
• batch references
• responsible-person data
• safety evidence
• notification data
• labelling outputs
• change history.

The fact that those data may resemble information that could appear in a passport does not make them DPP requirements.

Practical cosmetics conclusion

Do not build a "mandatory cosmetics DPP" around a requirement that current evidence does not establish.

Do build clean mappings between:

product → formula/version → batch → responsible person → PIF → safety report → notification → label

where that structure reflects the business and applicable cosmetics law.

If a future EU measure creates a generic cosmetics DPP, a governed product-information foundation will be easier to map into it.

Jewellery and watches

Does jewellery need a Digital Product Passport?

Current primary evidence does not establish one generic EU jewellery or watches DPP.

That statement needs two qualifications.

First, "jewellery" covers a wide product range. A simple ring, a battery-powered watch and a connected smartwatch can sit within different combinations of product law.

Second, no generic jewellery DPP does not mean jewellery is lightly regulated.

Several adjacent regimes can matter.

General product safety and identification

The General Product Safety Regulation, Regulation (EU) 2023/988, sets manufacturer duties for consumer products within its scope.⁶

Article 9 includes, among other things:

• internal risk analysis and technical documentation
• procedures for series-produced products to remain safe
• a requirement for products to bear a type, batch or serial number or another element enabling product identification, subject to the Regulation's provisions where the size or nature of the product affects placement of that information.

For relevant jewellery and watches, that creates a real product-identification and evidence problem.

It is not a DPP requirement.

REACH substance restrictions

REACH can apply to substances in articles.

Jewellery is a particularly clear example because Annex XVII includes restrictions that specifically address jewellery or jewellery components in defined circumstances.⁷

For example, EU REACH rules include restrictions relating to substances such as lead and cadmium in defined jewellery uses, alongside other restrictions that may be relevant depending on material and use.

The correct operational conclusion is:

Know the material, the component, the applicable restriction and the evidence.

The incorrect conclusion is:

REACH means jewellery already has a DPP.

It does not.

Conflict-minerals due diligence is conditional

Regulation (EU) 2017/821 establishes supply-chain due-diligence obligations for Union importers of defined tin, tantalum, tungsten, their ores and gold, subject to the Regulation's scope and volume thresholds.⁸

That can be relevant to parts of the jewellery and watch supply chain.

It is not a universal product-level passport obligation imposed on every jewellery brand or every jewellery item.

The distinction between operator scope and product category matters.

Practical jewellery and watches conclusion

For a jewellery or watch business, useful structured information may include:

• product identity
• type, batch or serial identity where required
• manufacturer and relevant economic-operator information
• materials and components
• substance-restriction evidence
• test documentation
• supplier provenance
• conflict-minerals due-diligence records where the operator is within scope
• model and batch relationships
• safety documentation
• product change history.

Those are current compliance and readiness territories.

They are not evidence of a generic jewellery DPP.

Existing product-data obligations in these sectors

The three categories make the same strategic point in different ways.

The existence of useful overlap is exactly why product-data readiness should not be framed as "DPP or nothing".

Common misstatements

"Every product sold in the EU will need a DPP."

Status: false as stated.

ESPR does not create a general obligation for every product to have a DPP. Product-specific rules determine whether the requirement applies. ESPR also contains categorical exclusions, including food and feed.¹⁹

A future policy programme could expand digital information requirements. That does not make the universal claim true today.

"All consumer goods need a DPP by 2030."

Status: false as stated.

There is no single 2030 deadline covering all consumer goods.

Different adopted and developing regimes have different dates. Some product groups remain under development. Food is outside ESPR. Cosmetics and jewellery do not have a confirmed generic DPP date in current evidence.

A date associated with one regime or work programme should not be converted into a universal compliance deadline.

"Food needs a Digital Product Passport."

Status: false if presented as a generic ESPR requirement.

Food is expressly excluded from ESPR.¹

Food businesses still have extensive information, traceability and lot-identification obligations under other law.²³⁴

"Cosmetics are next."

Status: not established as a generic DPP proposition.

Cosmetics already have substantial product-information requirements. Current primary evidence does not establish a generic EU cosmetics DPP or a confirmed generic application date.

If a market article means "cosmetics may face future digital product-information change", that is a forecast and should be labelled as such.

"Jewellery DPPs are mandatory."

Status: not established as a generic EU jewellery proposition.

Jewellery can be subject to product-safety, chemical and defined supply-chain duties. Those are adjacent obligations, not proof of a generic jewellery DPP.⁶⁷⁸

"If you don't need a DPP, you don't need structured product data."

Status: false.

Food, cosmetics and jewellery demonstrate the opposite.

Current law can already require product identity, operator data, traceability, ingredients, safety evidence, batch information, notification or substance evidence without calling the resulting system a DPP.

What "Not established" means

ActivateDigital uses Not established carefully.

It means:

The current evidence reviewed for the proposition does not establish it as an adopted or confirmed requirement.

It does not mean:

• impossible
• rejected forever
• regulator has promised not to do it
• no adjacent law applies
• no preparation is useful.

That distinction matters most in boundary categories.

If there is no adopted generic cosmetics DPP, the right status is Not established.

Do not replace it with "No cosmetics DPP will happen".

If there is no adopted generic jewellery DPP, the right status is Not established.

Do not replace it with "Jewellery is exempt forever".

Why "No generic DPP today" does not mean "never"

EU product regulation changes.

Work programmes change.

Product categories can be prioritised later.

Sector legislation can create digital information systems outside ESPR.

Existing frameworks can be amended.

New legislation can be adopted.

That is why a current-status article should answer two separate questions:

What is legally true today?

and:

What evidence should trigger a recheck?

It should not try to predict indefinitely.

What businesses should prepare

The preparation should match the category's real legal position.

If your category has an adopted DPP regime

Prepare against the adopted requirements and their actual dates.

Do not substitute a generic DPP checklist for the applicable law.

If your category is in official DPP development

Build low-regret capabilities:

• governed product identity
• product hierarchy
• operator identity
• existing regulated product information
• evidence provenance
• machine-readable data
• change history
• a configurable mapping to future DPP requirements.

Keep unconfirmed fields and granularity flexible.

If no generic DPP is currently established

Do not create speculative compliance work.

Instead, map what already exists:

1. Product identity

Know what identifies:

• product or model
• variant
• batch or lot
• individual item where relevant.

2. Operator identity

Know which legal entity has which role.

3. Current sector law

Tag every important field with its present legal or operational basis.

Do not call adjacent law "DPP law".

4. Evidence

Keep the source, date, scope and owner of important assertions.

5. Traceability

Preserve the relationships your current law and operational model already require.

6. Machine-readable product truth

Do not leave critical facts only in PDFs, artwork or emails.

7. Change history

Know which value changed, when, why and which outputs were affected.

This is useful preparation because it is based on what is true now.

How to monitor change

Do not monitor rumours. Monitor legal and official triggers.

For a boundary category, useful triggers include:

• a new ESPR Working Plan
• a Commission product-specific DPP page
• a formal consultation or preparatory study for the category
• a Commission proposal affecting the sector
• a draft delegated act
• an adopted delegated or implementing act
• an Official Journal publication
• a material amendment to the sector's existing law.

For ESPR categories, the Commission's DPP implementation page and Working Plan are useful high-level watchpoints.⁹¹⁰

For food, cosmetics and jewellery, sector-specific law remains just as important as the DPP programme.

What would change this page

This page should be rechecked if:

1. ESPR's scope is amended
2. a future Working Plan formally prioritises cosmetics or jewellery for product-specific DPP work
3. a new EU legal instrument creates a generic cosmetics DPP
4. a new EU legal instrument creates a generic jewellery or watches DPP
5. separate EU legislation creates a food digital-product-information regime that materially changes the current boundary explanation
6. current sector rules for food, cosmetics, GPSR, REACH or conflict minerals materially change the examples used here.

Until then, the safe position is to distinguish current law from future possibility.

Direct questions

Does food need a Digital Product Passport?

There is no generic ESPR food DPP requirement because food is expressly outside ESPR's scope.¹ Food still has extensive information and traceability obligations under other EU law.

Do cosmetics need a DPP?

Current evidence does not establish a generic EU cosmetics DPP. Cosmetics already have significant regulatory product information, including the Product Information File, electronic notification, responsible-person duties, labelling, batch identity and ingredient information.⁵

Does jewellery need a DPP?

Current evidence does not establish a generic EU jewellery or watches DPP. Product-safety identification, REACH restrictions and conditional supply-chain duties may apply depending on the product and operator.⁶⁷⁸

Will every product eventually need a DPP?

Not established. Current EU law does not provide a reliable basis for saying every product will eventually require one.

Does every consumer product need a DPP by 2030?

No. There is no universal 2030 DPP deadline for all consumer products.

If my category has no DPP, should I ignore DPP regulation?

No. Check whether your product is in official development and monitor relevant triggers. More importantly, continue to comply with the sector law that already applies.

What product data should I prepare anyway?

Prepare governed identity, operator data, existing regulated information, evidence provenance, batch or lot relationships where relevant, traceability, machine-readable records and change history.

Related ActivateDigital Knowledge

• Digital Product Passport Requirements by Product Category
• How to Prepare for a Digital Product Passport
• Is Your Product Data Ready for a DPP?
• Which Product Attributes Are Worth Fixing Once
• Passport Evidence: How We Know, and What a Blank Means
• Who Needs a Digital Product Passport?
• Textile Digital Product Passport Requirements (P1 canonical contrast, wire when published)
• Tyre Digital Product Passport Requirements (P1 canonical contrast, wire when published)

This is a regulatory information resource, not personalised legal advice. Product classification, operator role and applicable obligations should be checked against the law applying to the specific product and business.

Do Food Supplements Need a Digital Product Passport?

Direct answer

No generic ESPR Digital Product Passport applies to an ordinary food supplement marketed as food. Food is outside the scope of the Ecodesign for Sustainable Products Regulation, and EU food-supplement law treats supplements as foodstuffs.

But that does not mean a supplement has no structured product-data requirements.

Food businesses still need to manage mandatory food information, supplement-specific composition and warning information, the responsible operator, online-sale information, traceability, lot/batch identification and controlled nutrition or health claims.

The answer can change at the boundary. A product presented or functioning as a medicinal product needs a different classification assessment. And a connected dispenser or electronic device sold with a supplement is a separate product layer that can bring its own electronics, radio, battery and software obligations.

Why the word “supplement” is not enough

A commercial label is only the starting point.

For an ordinary food supplement, the relevant legal route is food law. But EU medicinal-products law also defines products by their presentation and function. That means a business cannot safely settle a borderline case from its ecommerce category alone.

The facts that matter can include:

• what the product contains
• dose and mode of action
• how it is presented
• the exact claims made
• whether it is intended to prevent, treat or cure disease
• whether an electronic dispenser or app is a separate regulated product.

Which rules apply to an ordinary food supplement?

Food Supplements Directive

Directive 2002/46/EC sets the EU framework for food supplements. It defines supplements as foodstuffs intended to supplement the normal diet and marketed in dose form.

It also requires supplement-specific label information, including the categories of nutrients or substances that characterise the product, the recommended daily portion and specified warnings.

Food supplements must not be labelled, presented or advertised with properties of preventing, treating or curing human disease.

Food Information to Consumers

Regulation (EU) 1169/2011 supplies the broader mandatory food-information framework.

That includes the responsible food-business operator and the mandatory particulars relevant to the product. For distance selling, the regulation also determines which mandatory information needs to be available before the purchase is concluded and what must be available at delivery.

For ecommerce teams, this is a product-data requirement even though it is not a DPP.

Traceability and lot identification

General Food Law requires food business operators to be able to identify relevant suppliers and business customers and make traceability information available to competent authorities.

Lot identification rules provide a batch-level mechanism for foods. Again, this is structured regulatory product data without being a Digital Product Passport.

Nutrition and health claims

Nutrition and health claims are separately controlled under Regulation (EC) 1924/2006.

Claims should therefore be managed as governed product assertions with a legal basis and evidence trail, rather than as unstructured marketing copy.

DPP position

The launch of DPP infrastructure does not make every product a DPP product. A legal instrument still has to require a passport for the relevant product.

What product data still needs to exist?

For an ordinary supplement, a governed product record may need to cover:

• product identity and designation
• responsible food-business operator
• ingredients and allergens where applicable
• supplement nutrients/substances and declared amounts
• recommended daily portion
• required supplement warnings
• net quantity and other mandatory food particulars
• conditions of use or storage where required
• mandatory information for online sale
• lot/batch
• supplier and customer traceability records
• controlled nutrition and health claims
• supporting evidence and authorisation conditions.

Some of this information is public or on-pack. Some is required online. Some is held for traceability or substantiation. It should not all be relabelled as DPP data.

Boundary examples

A standard vitamin supplement

If capsules are marketed as an ordinary food supplement with compliant food claims, the product follows food-sector information rules rather than ESPR DPP rules.

A “supplement” claiming to treat a disease

That wording raises a medicinal-product boundary question. Classification needs the product facts, not just the seller’s chosen category.

A smart dispenser with supplement refills

Treat the system in layers.

The ingestible refill can be a food product. The powered dispenser may separately be electrical/electronic equipment. Wireless connectivity, an incorporated battery and software can each add further obligations.

“No DPP for food” does not answer the compliance question for the device.

Ask these questions before deciding which route applies

1. Is the product actually marketed and presented as food?
2. What ingredients and active substances does it contain?
3. What dose and mode of action are relevant?
4. What exact nutrition, health or disease-related claims are made?
5. Does any presentation suggest prevention, treatment or cure of disease?
6. Which food-business operator is responsible for the information?
7. What information must appear before an online purchase?
8. How are lot and traceability records governed?
9. Is a device, dispenser or app also being placed on the market?
10. Does any separate hardware layer trigger electronics, radio, battery or software law?

What we know

• Ordinary food supplements are treated as foodstuffs under Directive 2002/46/EC.
• Food is outside ESPR scope.
• Food-sector law nevertheless creates substantial product-information, claims and traceability obligations.
• The medicinal boundary depends on product-specific facts.

What remains product-specific

A webpage cannot determine whether a borderline product is a medicinal product from the word supplement. Composition, function, dose, presentation and claims may require specialist regulatory assessment.

What we're watching for food supplements

• any EU legislation that expressly creates a digital-passport requirement for food or supplements
• material changes to the medicinal/food boundary or supplement harmonisation
• Member State notification/classification developments relevant to a specific target market.

Sources

• Regulation (EU) 2024/1781, Ecodesign for Sustainable Products Regulation (ESPR). Article 1 excludes food and feed from ESPR's scope. Articles 9-11 set the DPP architecture for applicable product-specific measures.

  View official source

• Regulation (EU) No 1169/2011 on the provision of food information to consumers. Especially Article 9 on mandatory particulars and Article 26 on origin/provenance where applicable.

  View official source

• Regulation (EC) No 178/2002, General Food Law. Especially Article 18 on traceability.

  View official source

• Directive 2011/91/EU on indications or marks identifying the lot to which a foodstuff belongs.

  View official source

• Regulation (EC) No 1223/2009 on cosmetic products. Especially Articles 4, 11, 13 and 19.

  View official source

• Regulation (EU) 2023/988 on general product safety. Especially Article 9 on manufacturers, technical documentation and product identification.

  View official source

• Regulation (EC) No 1907/2006, REACH. Particularly Annex XVII restrictions relevant to articles, including defined jewellery uses.

  View official source

• Regulation (EU) 2017/821 on supply-chain due diligence for Union importers of tin, tantalum, tungsten, their ores and gold. Scope and obligations are operator- and threshold-dependent.

  View official source

• European Commission, Digital Product Passport FAQs. Current Commission explanation that ESPR has no general DPP obligation for every product and introduces requirements product by product.

  View official source

• ESPR and Energy Labelling Working Plan 2025-2030, COM(2025) 187 final. Current prioritisation and indicative development programme.

  View official source

• European Commission, Digital Product Passport. Current implementation timeline and official DPP programme information.

  View official source

https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en