Carbon Footprint and Environmental Data in a DPP

Environmental data is one of the layers that a Digital Product Passport (DPP) brings together in a single place. For many companies the most demanding part will be the carbon footprint. This article explains what this layer covers, where its scope comes from, and how to prepare the data before it becomes mandatory.

What environmental data means in a passport

The environmental layer describes a product's impact across its whole life cycle — from raw-material sourcing, through manufacturing and use, to end-of-life handling. That life cycle is the reference point for most environmental indicators.

In practice this layer can include several kinds of information:

• the carbon footprint of the product or its key components,
• energy and resource use during manufacturing or use,
• durability and reparability, which shape the real-world environmental impact,
• recycled content and the potential for reprocessing.

Not every product will report all of these. The exact data set depends on the product group.

Where the required scope comes from

ESPR (the Ecodesign for Sustainable Products Regulation, 2024/1781) is a horizontal framework — it does not itself decide which environmental indicators a given product must report. That is done by delegated acts adopted separately for individual sectors.

As a result, the scope of environmental data will differ between batteries, textiles or furniture. Until the delegated act for your sector is adopted, the exact list of fields stays open — but the direction is clear: environmental data will be required more and more often. We explain the phased mechanism in the ESPR timeline.

Carbon footprint: why it is hard

A carbon footprint is rarely a single number you can read from a system. It usually requires a life-cycle assessment (LCA) and supplier data of varying quality. That makes it the most labour-intensive part of the environmental layer.

A good practice is to start with an inventory: which components and processes drive the emissions, and where the data comes from. Even if the methodology for your sector is not yet settled, organising your data sources pays off now.

The passport and other environmental rules

Carbon footprint also appears outside ESPR itself. In the battery sector a carbon-footprint declaration is part of broader obligations. For imports of carbon-intensive goods, a separate instrument — CBAM (the Carbon Border Adjustment Mechanism) — covers embedded emissions.

In construction, environmental data builds on existing Environmental Product Declarations (EPDs). These instruments are distinct from the DPP, but they draw on the same source data — which is why it is worth planning them together rather than in isolation.

How to prepare environmental data

The environmental layer is usually a data-gathering and tidying project, not a one-off entry. A few steps you can take regardless of when the delegated act arrives:

1. Map which environmental data you already hold (product sheets, supplier documentation, EPDs).
2. Identify the gaps — most often around carbon footprint and recycled content.
3. Decide at which level the data is available: model, batch or item.
4. Plan for updates, because environmental data changes over time.

We cover the level of detail in How to set your data granularity, and how to structure materials in Composition and materials in a DPP.

Access to environmental data

Not all environmental data has to be public to the same extent. ESPR provides for layered access — some information is visible to consumers, while some is reserved for market-surveillance authorities or recyclers. When designing a passport, it is worth deciding from the start what is public and what is restricted.

Primary versus secondary data

A carbon-footprint assessment distinguishes primary data — collected directly from processes and suppliers — from secondary data, drawn from databases and averaged values. Primary data is more accurate but harder to obtain.

At the start you usually work with a mix of both, and over time replace secondary data with primary data where it most affects the result. This strategy lets you get going faster without sacrificing credibility.

Environmental data changes over time

A carbon footprint is not a fixed value. It shifts with suppliers, production technology and the energy mix. That is why environmental data needs periodic review rather than a one-off entry.

It is worth deciding upfront who updates the data and how often, and how successive values are versioned. That keeps the passport credible and its change history reproducible during a compliance check.

Common mistakes with environmental data

A few traps recur regardless of industry:

• treating the carbon footprint as a single number with no stated methodology,
• ignoring the use phase, which can dominate the result,
• copying a supplier's value without checking its scope and system boundaries,
• having no update plan, so the data quickly goes stale.

Avoiding these from the start is cheaper than fixing whole data sets later.

Key takeaways

• Environmental data is the DPP layer describing a product's impact across its life cycle.
• The exact set of indicators comes from delegated acts, not from ESPR itself.
• Carbon footprint is the most labour-intensive part — it needs a life-cycle assessment and supplier data.
• CBAM, battery rules and EPDs are separate but draw on the same source data.
• It pays to start organising environmental data before the delegated act becomes binding.

See how CyfroPass helps you gather and publish a product's environmental data in one passport. Visit cyfropass.pl and get your data in order before it becomes mandatory.