Open call for evidence

Call for evidence: digital product records policy

Published 27 July 2026

Executive summary

This call for evidence aims to gather stakeholder views on digital product record (DPR) policy. DPRs, such as the EU’s Digital Product Passport (EU DPP), which will apply in Northern Ireland under the Windsor Framework, are being explored internationally as a means of providing product information and sustainability data across supply chains.

We are exploring whether a UK DPR policy could be used to streamline the provision of a range of product information for businesses, while enhancing transparency and traceability for consumers and Market Surveillance Authorities. This forms part of a wider aim to understand where benefits can be delivered to UK businesses and consumers through digitalisation of compliance processes.

We are inviting views on DPRs in general, the impacts of existing DPR policy (for example, on businesses selling into the EU and in Northern Ireland), and what the UK should consider when developing domestic policy on DPRs for goods.

Background

Digital product record systems, such as the EU DPP, are intended to store product information in a way that is easily accessible to those who need it.

DPRs look set to form an increasingly significant component of the regulatory landscape for goods across the globe. They have the potential to streamline administrative processes for businesses, and facilitate improved transparency for consumers, with respect to product information and sustainability.

The EU mandates its DPPs for a range of products under various regulations. The Ecodesign for Sustainable Product Regulation 2024/1781 (ESPR) establishes the framework for EU DPPs, setting out their principles of operation and some technical requirements.

Sector-specific product information requirements have been introduced through the:

• EU Batteries Regulation 2023/1542 (EUBR)
• Toy Safety Regulation 2025/2509
• Construction Products Regulation (EU CPR) 2024/3110

Further sector-specific requirements are expected to be introduced under ESPR delegated acts. These requirements will apply in Northern Ireland under the Windsor Framework. Further information on EU DPPs is published on the European Commission’s website.

Aside from the EU, the UN is supporting the global development of DPRs by backing initiatives to develop harmonised standards.

With the first of the EU’s mandatory EU DPP requirements entering into force for Batteries and Construction Products in 2027, now is an important moment to explore the UK’s approach to DPR policy.

This call for evidence is predominantly focused on the merits of introducing DPR architecture, particularly the underpinning framework for providing product information digitally. This is distinct from individual product information requirements for specific sectors that may be provided through DPRs, which will likely vary and evolve over time.

The government is considering product-specific DPR requirements in more targeted engagements, including surveys and consultations on:

• batteries
• construction products
• toys
• low carbon industrial products

The Department for Business, Innovation, Science and Trade is working closely with relevant departments to ensure the responses to these are considered in the round.

More broadly, the government is exploring a range of options linked to the digitalisation of product information. We recently consulted on the product safety framework, which includes options for moving to a ‘digital-by-default’ approach. These proposals build on our intention to introduce a digital option for product compliance marking, as announced earlier this year.

Although these issues are distinct to DPRs, they share a common aim of exploring the benefits to UK consumers and businesses through the digitalisation of product information. We recognise the need to future-proof this work so that the different strands complement each other as policy develops.

Methodology

We are keen to hear from all interested parties, including but not limited to:

• manufacturers
• authorised representatives
• importers, exporters and distributors
• trade associations
• businesses in or representatives of the waste and recycling sectors
• conformity assessment bodies
• regulatory bodies
• standards institutions
• consumers
• workers
• voluntary sector organisations

How to respond

Respond online.

Email DPR.engagement@businessandtrade.gov.uk

Send all responses by 11:59pm on 21 September 2026.

Following the closure of the call for evidence, responses will be used alongside other evidence to inform the government’s decision-making process on future domestic DPR policy, including the design of any future policy.

All personal data collected will be stored securely and deleted after 3 years. Large Language Models (LLMs) may be used to analyse the data collected. An anonymised summary of responses will be published on GOV.UK.

Current regulatory frameworks

The EU’s regulatory approach

The Ecodesign for Sustainable Products Regulation 2024/1781 (ESPR) entered into force in the EU and Northern Ireland in July 2024. This means UK businesses exporting to the EU, or selling in Northern Ireland, will need to comply with ESPR’s requirements.

ESPR mandates that certain products on the EU and Northern Ireland market should carry an EU DPP – a digital record of environmental and sustainability information – which is to be updated throughout a product’s lifecycle.

At present, the data intended to be accessible via EU DPPs includes information relating to a product’s manufacturing location, materials, environmental impact, repairability and recyclability. The EU has consulted on potential expansions of its use.

EU DPP requirements will be implemented in a phased roll-out, beginning with batteries in February 2027 (under the EU’s Batteries Regulation 2023/1542 (EUBR)). Depending on the battery category and applicable requirements, information may include:

• battery identification and technical characteristics
• manufacturer and economic operator information
• performance and durability data
• information supporting repair, reuse and recycling
• sustainability and circularity-related information

Other product-specific information, including necessary identifiers, data carriers and access rights, will be published through upcoming sector-specific EU delegated acts, which are secondary pieces of legislation. The EU intends to publish delegated acts, including for these sectors:

• iron and steel
• aluminium
• electronics and ICT products
• selected energy-related products, including some products where information is currently digitalised through the European Product Registry for Energy Labelling (EPREL)
• furniture and mattresses
• textiles and apparel
• recycled content and recyclability of electrical and electronic equipment
• detergents
• construction products

EU DPP obligations may fall on a range of actors in supply chains, including, but not limited to, manufacturers, importers, distributors, recyclers and refurbishers of products.

Requirements may vary depending on the drafting of delegated acts, but it is expected that these will include:

• creating and maintaining the DPP throughout the product lifecycle from manufacture to disposal
• providing the data carrier and managing product data
• maintaining relevant technical documentation
• registering the DPP on the EU registry

Further information on EU DPPs is published on the European Commission’s website.

International approach

There is broader international interest in the concept of DPRs. In 2024-25 the United Nations Economic Commission for Europe (UNECE) and the International Organisation for Standards (ISO) launched a joint DPP standardisation project, with the aim of harmonising DPR standards and ensuring a globally interoperable DPR system.

Current UK regulatory approach

EU DPP requirements will apply under the Windsor Framework, maintaining Northern Ireland’s access to both the EU and UK markets. With respect to Great Britain, the UK government has not yet determined its approach to DPRs.

However, as part of broader commitments to boost growth by reducing the administrative burden of regulation on businesses and simplifying product regulation, the government has explored digitalisation. This includes announcing a package of labelling reforms for certain products where the UKCA marking applies. This will allow important information, such as the UKCA marking and importer details, to be provided in digital formats.

Building on those reforms, we have proposed in the product safety framework consultation to give greater flexibility over how products must be labelled. Our ambition is to allow product labelling and product information to be ‘digital by default’, only requiring physical labelling by exception or on demand.

The government recently published its call for evidence on toy safety regulations. This requested views on the extent to which the EU Digital Product Passport would impact businesses. The consultation is running until 6 October 2026.

The government also recently consulted on reforms to the construction products regulatory regime through the Construction Products Reform (UK CPR) White Paper, and General Safety Requirement consultations, which closed on 20 May 2026. We are currently reviewing responses.

These consultations set out proposals to ensure construction product information and labelling is digital, and described the next steps in developing digital standards to promote consistency across product information. They also set out proposals to maintain consistency with the EU CPR where they meet our objectives.

The White Paper confirmed that we will continue to explore how a DPR, designed to deliver our objectives more effectively, could be phased in for products covered by designated standards as new standards are gradually adopted.

The 2025 Department for Energy Security and Net Zero (DESNZ) consultation on a Policy Framework to Grow the Market for Low Carbon Industrial Products complements this work. The government response, published in May 2026, confirms plans to publish voluntary guidance for buyers and for producers, each covering an Embodied Emissions Reporting Framework (EERF), and product classifications and procurement guidance. The initial sectoral focus is on steel, cement, and concrete products used in construction.

These guidance publications will be designed to align with the UK and EU construction products reforms. The guidance could help producers meet EU CPR requirements and make the resulting information more useful for buyers, subject to further policy development. DESNZ and Ministry of Housing, Communities and Local Government (MHCLG) will continue to work together to ensure that the EERF and the MHCLG’s UK CPR proposals are complementary.

The Department for Environment, Food and Rural Affairs (Defra) is working with the devolved governments to review the UK’s producer responsibility legislation for batteries. As part of this review, a series of workshops were held with industry earlier this year to explore the potential impacts of regulatory consistency with the requirements of the EUBR in Great Britain which includes the Digital Battery Passport requirements. The EUBR applies directly in Northern Ireland under the Windsor Framework. Defra plans to consult on proposals in due course.

Questions

About you

Indicate if you are responding as an individual or on behalf of an organisation.

If responding as an organisation, you will be asked to provide some further details about your organisation

• I am responding as an individual
• I am responding on the behalf of an organisation

How many employees does your business currently have on the payroll in the UK? This includes full-time and part-time staff. Include yourself if you are on the payroll as an employee.

• 1 to 9
• 10 to 49
• 50 to 249
• 250 or more
• No employees on the payroll
• Do not know

Where is your organisation primarily based?

• England
• Scotland
• Wales
• Northern Ireland
• European Union
• Outside of the UK and the EU
• Do not know

What product category or sector does your organisation primarily deal with?

• batteries
• textiles
• aluminium, steel and iron
• tyres
• energy-related products
• furniture
• mattresses
• construction material
• toys
• detergents and surfactants
• electronics and ICT
• chemicals
• paints and lubricants
• other (specify)

Has your business sold physical goods to any market outside of Great Britain, including to Northern Ireland, in the last 12 months?

• yes – we have in the last 12 months
• yes – but not in the last 12 months
• no, we never have

[If either ‘yes’ selected] Specify where outside of Great Britain your business has sold goods:

[Free text]

Survey questions

Section 1: awareness of emerging digital product records requirements

1. How would you describe your awareness of emerging requirements or initiatives related to digital product records, including at the EU and international levels?

• have not heard of the requirements
• have heard of the requirements but do not know what they involve
• have some awareness (for example, aware of the concept and that it may apply to your products)
• have strong awareness (for example, understand the requirements and have taken, or plan to take, action to prepare)

2․ Think about any regulatory developments you may have seen, read or heard recently related to digital product records. Where have you found this information? Select all that apply:

• online EU business guidance
• online UK business guidance (on EU regulations)
• government or Department for Business, Innovation, Science and Trade
• EU policy-makers, officials or counterparts
• notices and advice from colleagues
• external advice (for example from private consultants or legal experts)
• newsletters and updates from Business Representative Organisations
• trade publications or events
• Other (specify):

[Free text]

3․ What steps, if any, has your organisation taken to prepare for new or upcoming rules about digital product information or records (for example, the EU’s DPP requirements)?

[Free text]

4․ What forms of UK government guidance would you find most useful to help businesses comply with these types of requirements? Select all that apply.

• signposting to relevant EU publications and guidance
• UK government guidance on how the requirements apply to UK businesses (including trade with Northern Ireland)
• targeted webinars, or Q&As
• other (specify):

[Free text]

Section 2: business impacts

5․ In your opinion, what potential benefits for your business, sector or other affected group may come from the introduction and wider use of digital product records (for example, within the EU and other jurisdictions, including in day-to-day operations or when trading across borders)? Select all that apply:

• reduced time spent gathering or checking supplier information
• improved compliance assurance or auditability (for example, for regulatory requirements)
• more efficient cross-border compliance (for example, reduced duplication of data submissions, smoother customs processes)
• faster or more efficient product recalls
• improved end-of-life management (for example, repair, reuse, recycling)
• easier provision of product information to customers
• improved supply chain transparency
• potential cost savings over time
• no expected benefits
• not sure
• other (provide further detail):

[Free text]

6․ In your opinion, what drawbacks for your business, sector, or other affected group may come from the introduction and wider use of digital product records (for example, within the EU and other jurisdictions)?  Select all that apply:

• increased time spent gathering or verifying supplier information
• higher compliance or reporting costs (for example, to meet regulatory requirements)
• increased administrative burden
• challenges integrating DPR requirements into existing IT systems or processes
• challenges aligning with border or customs processes across jurisdictions
• risks to commercially sensitive or confidential information
• disruption to existing supply chains
• upfront investment costs (for example, systems, training, data collection)
• uncertainty around requirements or implementation
• no expected drawbacks
• not sure
• other (specify):

[Free text]

7․ What impacts, if any, might your organisation face if there were separate rules regulating digital product records in Great Britain and Northern Ireland (where EU rules apply)?

[Free text]

8․ What impacts, if any, might your organisation face if there were separate rules regulating digital product records in Great Britain and the EU?

[Free text]

9․ Which types of information in a digital record would be most valuable to you or your organisation? Select all that apply:

• product composition (for example, materials, chemicals)
• supply chain information (for example, origin, suppliers)
• environmental information (for example, carbon footprint, sustainability data)
• social and equality information (for example, human rights, labour data)
• repair and maintenance information
• end-of-life or recycling instructions
• compliance or certification information
• unique product identifiers (for example, serial numbers, batch data)
• not sure
• other (provide further detail):

[Free text]

10․ If a domestic digital product record is introduced in Great Britain, what would you consider a priority in terms of its implementation to best support your existing supply chains and distribution networks between Great Britain, Northern Ireland, and international markets?

• a system that is interoperable with that which applies in the EU and Northern Ireland, including for instance through a single data carrier
• a system that is tailored specifically to the Great Britain market, with potentially distinct labelling requirements to the EU and Northern Ireland.
• no preference
• not sure (provide further detail)
• other (provide further detail)

11․ What is your view on the potential impact of digital product records on sustainability and resource efficiency? This could be for your organisation, within Great Britain, or more widely.

• strong positive impact
• some positive impact
• no overall impact
• some negative impact
• strong negative impact
• not sure

Briefly explain your answer (for example, impacts on waste, recycling, resource use, or environmental outcomes):

[Free text]

12․ Is there anything else that the government should consider when designing digital product record rules in Great Britain?

[Free text]

Section 3: business costs

13․ Do you expect your business or sector to face additional costs as a result of upcoming EU DPP compliance changes?

• yes – one-off or transition costs
• yes – ongoing costs
• yes – both one-off and ongoing costs
• no
• not sure

If ‘yes – one-off (transition) costs’, go to questions 14, 15 and 16.

If ‘yes – ongoing costs’, go to questions 17, 18 and 19.

If ‘yes – both one-off and ongoing costs’, go to questions 14 to 19.

If ‘no’, go to question 21.

If ‘not sure’, go to questions 14 to 19.

14․ Which one-off or transition costs do you expect your business or sector to face under upcoming EU DPP compliance changes? Select all that apply:

• training and upskilling staff to use EU DPPs
• changes to business processes (for example, supply chain data collection, internal workflows)
• collection and verification of information required for compliance (including supplier engagement)
• IT system changes
• labelling and physical compliance costs
• updating internal documents, websites and customer-facing information
• costs for external advice and consultancy (for example, legal, technical, sustainability)
• other (specify):

[Free text]

15․ Approximately how much do you expect your one-off or transition costs to be?

• £0 to £999
• £1,000 to £9,999
• £10,000 to £99,999
• £100,000 to £999,999
• £1 million or more
• not sure

16․ Which aspects of the choices in question 14 do you expect to be the most significant factor (if known)?

[Free text]

17․ Which ongoing costs do you expect your business to face under upcoming EU DPP compliance changes?

• ongoing training or resourcing of staff
• ongoing changes to business processes (for example, supply chain data collection, internal workflows)
• ongoing collection and verification of information (including supplier engagement)
• ongoing IT system maintenance or updates
• ongoing data management costs
• ongoing labelling or physical compliance activities
• updating internal documents, websites and customer-facing information
• external advice or consultancy (for example, legal, technical, sustainability)
• none
• not sure
• other (please specify):

[Free text]

18․ How do you expect these changes to affect your ongoing costs each year?

• more than £100,000 reduction
• £10,000 to £99,999 reduction
• £1,000 to £9,999 reduction
• £0 to £999 reduction
• no significant change
• £0 to £999 increase
• £1,000 to £9,999 increase
• £10,000 to £99,999 increase
• more than £100,000 increase
• not sure

19․ Which aspect of the choices in question 14 or 16 do you expect to be the most significant factor (if known)?

[Free text]

20․ Approximately how much of your total expected costs will be related to product labelling (for example, updating labels, adding QR codes, printing, or packaging changes)? Provide an estimate per year, in pound (£) terms or as a rough percentage.

[Free text]

Section 4: data and supply chain capability

21․ Does your business currently collect or create the product and supply chain information that may be relevant for a digital product record (such as those envisaged under EU DPP rules)?

• we already collect or create most of this information
• we collect or create some of this information
• we do not currently collect or create this information
• this is not our responsibility
• we do not know what information may be required
• not sure

If ‘this is not our responsibility’, who do you think is responsible for this information?

If ‘not sure’, provide further detail on why you do not have this information (for example, if this is due to unclear requirements, limited visibility of your supply chain, or other reasons).

[Free text]

22․ Do any of your products rely on components or materials from the following markets? Select all that apply.

• Northern Ireland
• European Union
• other international markets
• none of the above
• not sure

23․ Do you expect your business will be able to obtain all the required product and supply chain information?

• yes, all of it
• yes, most of it
• no, some information will be difficult to obtain
• no, significant gaps are expected
• not sure

If not ‘Yes all of it’, if your business does not currently hold some of this information (or if you are unsure), what additional costs, effort or challenges would be involved in obtaining or creating it?

[Free text]

Section 5: consumer impacts

24․ In your view, how will EU DPP requirements impact consumers within Great Britain or Northern Ireland?

[Free text]

25․ What, if any, consumer safeguards or protections should be considered if digital product records were made mandatory in Great Britain?

[Free text]

Section 6: other information

26․ Do you have any other evidence to contribute?  For example, are there any other opportunities or challenges the UK government should consider in relation to digital product records that have not already been covered?

[Free text]

Would you be willing to be contacted for further discussion on this topic?

• yes (please provide your email address)
• no