Digital Product Passports: Transparency and Traceability
The EU’s Digital Product Passport (DPP) initiative is set to revolutionize how products—especially in textiles and electronics—are tracked, marketed, and recycled. Under the Ecodesign for Sustainable Products Regulation (ESPR), DPPs will become mandatory for a growing list of product categories, starting with textiles, batteries, electronics, and more
What is a DPP?
A DPP is a digital record attached to each product, containing detailed information about its materials, origins, environmental impact, repairability, and end-of-life options. This passport is accessible via a QR code or NFC chip on the product or packaging, giving regulators, partners, and consumers instant access to verified data
Why does it matter?
- Traceability: Every step in the supply chain is documented, supporting circular economy goals and sustainable business practices.
- Accountability: Manufacturers, importers, and retailers must ensure data accuracy and completeness, with audits and third-party verification required
- Consumer empowerment: Buyers can make informed choices based on transparent product histories and environmental impact.
Timeline:
- DPP requirements for batteries begin in 2027, with textiles and electronics following soon after. By 2030, DPPs will be mandatory for most regulated product categories
AI Content Moderation and the Digital Services Act (DSA)
The Digital Services Act (DSA), fully in force in 2025, introduces sweeping obligations for online platforms, marketplaces, and service providers. A key focus is on content moderation—especially the use of artificial intelligence.
What’s new?
- Proactive moderation: Platforms must act “diligently, expeditiously, and objectively” to remove illegal or harmful content, using both human and AI-driven tools
- Transparency: Providers must clearly explain why content is removed or restricted and offer users a way to appeal decisions
- Auditing and reporting: Very large platforms must publish detailed transparency reports twice a year, including the performance of AI moderation systems
AI Act overlap:
The EU’s AI Act, effective from February 2025, further restricts certain high-risk or prohibited AI practices, adding another layer of compliance for businesses deploying automated moderation tools
Stricter Cookie Consent for Retargeting and Ads
Cookie consent rules have tightened dramatically in 2025, with regulators and platforms like Google enforcing strict requirements for user tracking and retargeting
What’s required?
- Explicit, granular consent: Users must be able to easily accept or reject all non-essential cookies, with clear options and no pre-ticked boxes
- No tracking before consent: Cookies for personalized ads or retargeting (e.g., Google Ads, Facebook Pixel) can only be set after explicit user approval
- Easy withdrawal: Users must be able to revoke consent as easily as they gave it
- Proof of compliance: Advertisers must log and be able to demonstrate valid consent for all tracked users
Enforcement and penalties:
Non-compliance can lead to severe consequences. In recent years, major brands like Google, Facebook, and Amazon have faced fines ranging from €35 million to €150 million for cookie violations. Under GDPR and related rules, non-compliant ads now risk fines of up to 4% of global annual revenue
What Does This Mean for Your Business?
2025 is a turning point for digital compliance in the EU. Whether you manufacture products, operate an online platform, or run digital marketing campaigns, you must:
- Prepare for DPP requirements by mapping your product data and ensuring traceability.
- Implement robust, explainable AI moderation systems and keep detailed transparency records.
- Overhaul cookie consent flows to meet the latest GDPR and platform-specific standards.
Non-compliance is no longer an option. The risks—financial, reputational, and operational—are too great. But for proactive businesses, these new rules are also an opportunity: to build trust, stand out for transparency, and lead in a digital-first, regulation-driven market.