Chemicals DPP & DMP: Product and Material Passports with GoodsTag

GoodsTag provides the infrastructure to create and manage Digital Product Passports and Digital Material Passports for chemicals, paints and lubricants, linked to each other and ready for your customers’ product passports.

Acetic acid canister with a QR code label in a chemical plant, next to a smartphone showing its Digital Product Passport

Why act now?

Digital Labels, New Hazard Classes, Customer Passports: Chemical Data Is Going Digital.

Since 1 July 2026, the revised CLP Regulation lets you put part of the hazard label online, under strict rules. New hazard classes for endocrine disruptors and persistent substances already apply to new mixtures, and every mixture on the market must be classified for them by 1 May 2028. Your customers’ product passports will also ask for the substances in your materials.

Start Your Chemicals DPP

1 May 2028

New hazard classes for all mixtures

What’s Inside a Chemicals Digital Product Passport?

The Ecodesign for Sustainable Products Regulation (ESPR) names paints, lubricants and chemicals among the product groups its first working plan had to prioritise. The European Commission’s working plan 2025–2030 did not include them: paints and lubricants showed a lower improvement potential, and chemicals were judged a very complex group, with a scoping study to prepare a later decision. No passport act is scheduled yet. What already applies is digital: CLP digital labels, safety data sheets, the SCIP database, and the substance data your customers’ products will need for their own passports.

A chemicals passport brings that data together in one place. Based on the rules in force and the ESPR’s information requirements, it may hold:

  • passport

    Identity and Composition

    Unique product identifier, product name, batch, the responsible supplier and, where it applies, the unique formula identifier (UFI)

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    Hazards and Safe Use

    CLP classification and label elements, the digital label, the safety data sheet and instructions for safe use

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    Substances of Concern

    Substances of very high concern and other substances of concern, with concentration and location, plus VOC content and carbon footprint where available

  • cycle

    Linked Material Passports

    Links to the Digital Material Passports of the raw materials in each product, so their data flows into the product passport

  • assignment_turned_in

    Compliance and End of Life

    REACH and SCIP references, certificates and ecolabels, and disposal, collection and recycling information for products and packaging

All structured, machine-readable, and ready for customers, safety officers, recyclers and authorities.

DPP and DMP

One Product Passport, Linked to Every Material Passport

A paint, an adhesive or a lubricant is a product on its own, and a material in someone else’s product. That is why chemicals need two kinds of passport, and why GoodsTag covers both, linked in a parent-child relation.

Digital Product Passport (DPP)

The passport of a product placed on the market, such as a can of paint or a drum of lubricant. The ESPR defines it and its delegated acts will set its content, product group by product group.

Digital Material Passport (DMP)

The passport of a material, such as a resin, a pigment or a base oil, and of its batch: composition, substances of concern, origin, footprint and certificates. It is an industry term, not yet defined in EU law.

Parent · DPP

Industrial protective coating, 20 L

Batch PC-2024-1187 · sample data

  • Child · DMP

    Epoxy resin

    Supplier batch, composition, carbon footprint

  • Child · DMP

    Hardener

    Classification, substances of concern, safe use

  • Child · DMP

    Additive package

    Concentration, origin, certificates

The product passport is the parent. Each material in it keeps its own passport, linked as a child, and your own DPP can in turn become a child DMP in your customer’s product.
  • One parent, many children

    Each DPP references the DMPs of the materials it contains, down to the batch, through persistent identifiers.

  • Update once, inherit everywhere

    When a supplier updates a material passport, every product passport linked to it sees the change.

  • Each party shares what it should

    Suppliers keep control of their formulations: access rights decide which material data reaches customers, recyclers or authorities.

There is no EU legal definition of a Digital Material Passport yet. GoodsTag uses the term for material and batch data structured like a DPP, so it can be linked to product passports.

Need Clarity on Chemicals DPP Requirements?

The rules for chemicals come from several acts at once, and some are still changing. We follow every step so you don’t have to.

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Ecodesign for Sustainable Products Regulation (ESPR)

Regulation (EU) 2024/1781, the legal framework for Digital Product Passports. Names paints, lubricants and chemicals among its priorities and defines substances of concern.

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ESPR Working Plan 2025–2030

COM(2025) 187 final, 16.04.2025. Does not include paints, lubricants or chemicals; plans a study on chemicals to prepare a later decision.

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CLP revision

Regulation (EU) 2024/2865, in force since 10 December 2024. Allows voluntary digital labels from 1 July 2026: free of charge, without registration, available for at least 10 years.

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CLP postponement

Regulation (EU) 2025/2439 moves the new label formatting rules, including minimum font sizes, from 1 January 2027 to 1 January 2028. Digital labelling still applies from 1 July 2026.

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New CLP hazard classes

Delegated Regulation (EU) 2023/707: endocrine disruptors, PBT/vPvB and PMT/vPvM. Mixtures placed on the market before 1 May 2026 must comply by 1 May 2028.

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REACH safety data sheets

Regulation (EU) 2020/878 amending Annex II to REACH, the current format of the safety data sheet, required since 1 January 2023.

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SCIP database

ECHA’s database for articles containing substances of very high concern above 0.1 % w/w, under the Waste Framework Directive. A pending proposal would end it in favour of tools such as DPPs.

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Common data platform on chemicals

Regulation (EU) 2025/2455, part of the “one substance, one assessment” package. ECHA must set up the platform by 2 January 2029.

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Construction Products Regulation

Regulation (EU) 2024/3110 introduces a DPP for construction products, due 18 months after its delegated act. Coatings are covered only where a harmonised technical specification applies.

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More sources will follow as the chemicals rules take shape.

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Digital Product Passport

Chemicals DPP Experts, Ready to Work With Your Team

End-to-end support to simplify your DPP and DMP rollout.

What’s Getting in the Way of DPP Success?

A chemicals passport depends on data from raw-material suppliers, regulatory teams and production, batch by batch.

  • flowsheet

    Composition and substance data spread across suppliers and systems

  • assignment_late

    Confidential formulations that must stay protected

  • quick_reference_all

    Safety data sheets, labels and certificates kept in separate tools

  • cycle

    Batch variations, reformulations and regulatory updates

  • attribution

    Customers asking for material data in different formats

Why Leading Teams Choose GoodsTag for DPPs

Green package surrounded by circular arrows and small leaves symbolizing eco-friendly recycling or circular packaging.

Full Lifecycle Support

Your passports stay accurate through reformulations, new batches, reclassifications and evolving regulations.

Built for Scale

Handles large portfolios of products, materials and batches, with product and material passports linked to each other.

3D illustration of digital interface with gears and check marks symbolizing system configuration and successful operation.

Compliance in Mind

Your data model follows the EU requirements as they are finalised, from substances of concern to the CLP rules for digital labels.

Proven Partner

Proven track record in high-stakes, high-volume environments.

How the DPP platform works

The GoodsTag DPP Hub: Connecting Enterprise, Partners and Regulators

From the data you already have to a verifiable passport that every authorised party can read. Designed for interoperability and regulatory compliance.

  1. Step 1 · Connect

    Your data sources

    • Supplier data
    • Material passports (DMP)
    • ESG and sustainability data
    • Business systems: ERP, MES
    • PLM and PIM
    • Files: PDF, CSV
  2. Step 2 · Build

    GoodsTag DPP Factory

    1. Data normalisation and validationSupplier and system data mapped to one structure and checked for completeness.
    2. Digital twin foundationA digital identity for each product, batch or item, linked to its data carrier.
    3. DPP–DMP linkingEach product passport is the parent of the material passports (DMP) of its components, linked down to the batch.
    4. DPP data model translatorYour data mapped to the data model each regulation requires.
    5. Verifiable credential issuancePassport data signed, so its origin and integrity can be checked.
    6. DPP event storeEvery creation and change recorded as a versioned, traceable event.
  3. Step 3 · Publish

    Issued and connected

    • EU central DPP registryUnique identifier and link registered with the EU registry, which stores the index, not the passport.
    • Public DPP viewProduct ID, material composition, sustainability data, signature check and conformity certificates in one scan.
    • Back-up copyA copy of the passport held by an independent DPP service provider, as ESPR Article 10(4) requires.
  4. Step 4 · Access

    Role-based passport

    • AuthoritiesMarket surveillance and customs see the restricted data the law grants them.
    • End customersPublic information, free of charge, with no login.
    • RecyclersComposition and dismantling data for treatment and recovery.
    • Lifecycle partnersRepairers and remanufacturers with a legitimate interest.

Interoperability

Data carriers and standards, GS1 Digital Link conformant, API-first, multiple identity levels from model to item, and role-based data access.

Compliance

Architecture aligned with the regulations and the passport lifecycle, ready for the EU DPP registry, controlled access and GDPR-compliant processing.

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Example of an acetic acid Digital Product Passport on a smartphone, with sample data

What Could a Chemicals DPP Look Like?

Your customers won’t read a technical file. They’ll scan a QR code on the can, the drum or the label.

Here’s an example of what they (and safety officers and authorities) could see on the other side, with the material passports behind it. Sample data only.

Want to see it with your own products? [Talk to us]

The Deadlines Are Closer Than You Think

No ESPR passport act is planned yet for chemicals, paints or lubricants, but the rules on hazard data and digital labels already apply or start soon.

Here are the key dates you need to know about (as of October 2026):

2024–2025
The groundwork. The ESPR entered into force on 18 July 2024 and the CLP revision on 10 December 2024. In April 2025, the ESPR working plan left paints, lubricants and chemicals out of its first round. Since 1 May 2025, new substances must be classified for the new hazard classes.
2026: Digital labels and new hazard classes
From 1 May 2026, new mixtures must be classified for endocrine disruption and persistence. From 1 July 2026, the CLP allows digital labels. Substances already on the market must apply the new hazard classes by 1 November 2026.
2028 and beyond
The new CLP label formatting rules apply from 1 January 2028, and a simplification under negotiation may change them again. By 1 May 2028, every mixture on the market must be classified for the new hazard classes. The detergents passport applies from 23 September 2029, and the Commission will reconsider chemicals at the working plan’s mid-term review.

How We Help You Build Your Chemicals DPP

A simple, practical path for chemical, paint and lubricant manufacturers and distributors.

Map the data you already have

Lay out all existing data across ERP, product stewardship and SDS authoring systems, supplier declarations and quality records to see where each field currently lives.

Identify missing information

Spot the gaps by separating usable data from incomplete, messy, or missing information, from raw-material composition to substances of concern.

Define internal ownership

Assign clear owners for each data area so updates and approvals have defined responsibility.

Align your structure with the EU data model

Match your internal fields to the EU DPP data model and link each product to the material passports of its ingredients.

White and teal rocket launching centered inside a green and teal circular arrow symbol.

Create a publishing workflow

Set a structured workflow for validating, approving, and publishing data into the DPP, the DMP and the digital label.

Plan for ongoing updates

Establish routines and triggers to keep the passports up to date with every new batch, reformulation and reclassification.

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Compliance Without Headaches

Turn the upcoming EU chemicals requirements into a competitive advantage, today.

Frequently Asked Questions

1. What exactly is a Digital Product Passport (DPP) for chemicals?

A Digital Product Passport is a structured, machine-readable data set that stores verified product information across a product's lifecycle. For chemicals, paints and lubricants, it brings together identity, composition, hazards, safe use and end-of-life data, reachable through a QR code on the container or the label. The EU Ecodesign for Sustainable Products Regulation (ESPR) sets the framework for passports; delegated acts set the exact data for each product group.

2. Is a DPP mandatory for chemicals, paints or lubricants?

Not yet. The ESPR names paints, lubricants and chemicals among its priorities, but the European Commission's working plan 2025–2030 did not include them. For chemicals, the Commission planned a study to define the scope, to be considered at the plan's mid-term review or in a later plan. As of October 2026, no delegated act requires a passport for them. Detergents are different: the new Detergents Regulation (EU) 2026/405 introduces a passport from 23 September 2029.

3. What is a Digital Material Passport (DMP)?

A Digital Material Passport is the passport of a material and its batch, such as a resin, a pigment, a solvent or a base oil: its composition, substances of concern, origin, carbon footprint and certificates, in a structured format. The term comes from industry and research projects; it has no definition in EU law yet. GoodsTag structures DMPs like DPPs, so the two can be linked.

4. How do the DPP and the DMP relate in GoodsTag?

In a parent-child relation. The product's DPP is the parent, and the DMPs of the materials it contains are its children, linked through persistent identifiers down to the batch. Material data flows up into the product passport, and a change to a material passport reaches every product linked to it. Your own product can also become a child material in your customer's product, so the chain continues downstream.

5. What already applies to chemicals today?

Several rules. Safety data sheets follow the REACH Annex II format. Since 1 July 2026, the revised CLP Regulation allows digital labels. New hazard classes for endocrine disruptors, PBT/vPvB and PMT/vPvM apply to new mixtures since 1 May 2026, and to all mixtures by 1 May 2028. Articles containing substances of very high concern above 0.1 % w/w must still be notified to ECHA's SCIP database.

6. Can the passport carry the CLP digital label?

It can sit behind the same QR code. The CLP keeps the physical label mandatory and lets only some supplemental information appear online alone. A digital label must be free of charge, need no registration or app, show all label elements in one place apart from other information, stay available for at least 10 years and be reachable in no more than two clicks. GoodsTag can publish the label elements as their own view of the passport, set up to meet these conditions.

7. How do substances of concern fit in?

The ESPR defines substances of concern, including substances of very high concern under REACH and substances with certain CLP classifications, and requires future product passports to track them: name, concentration, location in the product, safe use and end-of-life information. Manufacturers downstream will need this data from their chemical suppliers. A material passport is the structured way to provide it, once, to every customer that needs it.

8. How do we connect containers and batches to the passport?

GoodsTag assigns a unique digital identity to each product, batch or container. This identity is connected to the physical product via QR codes, NFC or RFID tags on cans, drums, IBCs or labels. When scanned, the identifier routes the user to the product's digital twin, which hosts the passport and its linked material passports.

9. How do we feed all this data into the GoodsTag platform?

GoodsTag features an API-first architecture that integrates with your existing enterprise systems, including ERP, product stewardship and SDS authoring tools, LIMS and supplier databases such as SAP S/4HANA. Data synchronization is event-driven and supports global GS1 standards like EPCIS 2.0 and GS1 Digital Link for real-time traceability.

10. Is the GoodsTag platform ready for the upcoming requirements?

No passport act for chemicals, paints or lubricants has been adopted, so no platform can claim full compliance with one today. GoodsTag builds on the principles the ESPR already sets for passports: a unique product identifier, a data carrier on the product, open and interoperable formats, and access rights for each audience. The platform is based on GS1 Digital Link, and its data models are configurable, so each data set can be mapped as soon as it is defined.

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The Suppliers That Move First Will Set the Standard

Build your business on top of compliance.

Product passports will make the substances in every product visible, all the way up the supply chain. The chemical, paint and lubricant suppliers that share structured material data first will become the easy choice for their customers, and turn compliance into a competitive edge.