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EU ESPR Regulation (EU) 2024/1781

Your Digital Product Passports Need a Backup Plan

The EU requires companies to maintain backup copies of DPP data with certified third-party providers. Products last decades — your DPP data must too.

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Why DPP Backup Matters

The EU's DPP regulation creates a massive data persistence challenge

Products outlive companies. Your DPP data infrastructure must be resilient enough to match.

30+

Years of data retention required for construction products and durable goods under EU delegated acts.

2027

First DPP deadlines arrive for batteries. Other product categories follow between 2028–2030.

100%

Of EU products will need Digital Product Passports. Free access to DPP data is required by law.

Complete Guide to DPP Backup

In-depth articles covering every aspect of Digital Product Passport data preservation.

  1. What is DPP Backup?
  2. EU ESPR Requirements for DPP Data Persistence
  3. What Happens When Companies Go Bankrupt?
  4. The EU DPP Registry & Backup Infrastructure
  5. Technical Requirements for DPP Data Preservation
  6. GS1 Digital Link & URL Persistence
  7. Data Sovereignty & GDPR Implications
  8. Industry Solutions & Approaches
  9. Blockchain & Decentralized Solutions
  10. Cost Implications of Long-Term Storage
  11. Best Practices for DPP Backup Strategy

1. What is DPP Backup?

A Digital Product Passport (DPP) is a structured digital record containing sustainability, composition, repair, and end-of-life information about a product. Under the EU's Ecodesign for Sustainable Products Regulation (ESPR), virtually all physical products sold in the EU will require a DPP.

DPP Backup refers to the regulatory requirement and technical practice of maintaining redundant, persistent copies of Digital Product Passport data with certified independent third-party providers. This ensures that DPP information remains accessible throughout a product's entire lifecycle — even if the original company ceases to exist.

Key Principle: The EU will require companies to place a backup copy of their DPP with a certified third-party provider. This is not optional — it's a core compliance requirement under ESPR.

Why Backup is Essential

Consider a battery manufacturer that creates DPPs for electric vehicle batteries in 2027. Those batteries may be in use until 2045 or later. If the manufacturer goes bankrupt in 2032, who serves the DPP data? Without a backup mandate, the answer is: nobody. The QR codes on millions of batteries would lead to dead links, and critical recycling and safety data would be lost forever.

DPP backup solves this by ensuring a certified third party always holds a copy of the data, ready to serve it if the original source becomes unavailable.

2. EU ESPR Requirements for DPP Data Persistence

The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 establishes the legal framework for Digital Product Passports. Several provisions directly address data persistence and backup:

Article 11 — Digital Product Passport Storage

The ESPR allows companies to store DPP data either in their own systems or through third-party DPP service providers (Article 11.c). Critically, when third-party providers are used, they "shall not sell, reuse or process such data, in whole or in part, beyond what is necessary for the provision of the relevant storing or processing services" unless specifically agreed with the economic operator.

Mandatory Backup with Certified Providers

The regulation requires companies to place backup copies of their DPP data with certified independent third-party product passport service providers and backup storage providers (as referenced in CIRPASS project documentation and EC guidance). These providers must meet certification requirements set by the EU.

Data Retention Period

DPP data must remain accessible for the period defined in the relevant delegated acts for each product category. This typically covers the expected lifetime of the product:

  • Batteries: 10-20 years (EV batteries may last longer)
  • Electronics: 5-15 years depending on product type
  • Textiles: 3-10 years
  • Construction products: 30-50+ years
  • Industrial machinery: 20-40 years

Free Access Requirement

Access to mandatory DPP data must be free of charge. While the fees for DPP hosting and backup services will be left to the market (companies pay their service providers), end users, regulators, and recyclers must be able to access the data at no cost.

Delegated Acts: The ESPR provides the framework, but specific backup requirements per product category will be detailed in follow-up delegated acts. The first delegated acts (for batteries) are expected to define precise backup obligations by 2026-2027.

3. What Happens When Companies Go Bankrupt?

Company insolvency represents the most critical risk to DPP data persistence. Without backup measures, bankruptcy could render millions of Digital Product Passports inaccessible overnight.

The Insolvency Problem

When a company enters insolvency proceedings:

  • Servers may be shut down as part of asset liquidation
  • Domain names expire or are sold to unrelated parties
  • Cloud hosting subscriptions are cancelled for non-payment
  • IT staff are made redundant — no one maintains the systems
  • Data may be deleted, sold, or simply lost

For DPP data, this means every QR code on every product ever sold by that company would suddenly resolve to nothing. Recyclers couldn't access material composition data. Repairers couldn't find spare parts information. Regulators couldn't verify compliance.

The Scale of the Problem

In the EU, approximately 200,000 companies go bankrupt each year. Many of these are manufacturers or importers that would have DPP obligations. Without backup requirements, each bankruptcy could orphan thousands or millions of product passports.

How Backup Solves It

Under the ESPR backup mandate:

  • A certified third-party provider holds a complete copy of all DPP data
  • If the original company becomes unavailable, the backup provider can serve the data
  • The EU DPP registry can redirect data carrier lookups to the backup provider
  • End users experience no interruption — QR codes continue to work

Beyond Bankruptcy

Backup also protects against other scenarios:

  • Mergers & Acquisitions: DPP data may be deprioritized during transitions
  • System migrations: Data can be lost when companies change platforms
  • Cyberattacks: Ransomware could lock DPP data; backups provide recovery
  • Market withdrawal: Companies exiting the EU market might stop serving DPP data
  • Technical failures: Hardware failures, cloud outages, or database corruption

4. The EU DPP Registry & Backup Infrastructure

The EU is building a central DPP registry that plays a crucial role in the backup ecosystem.

How the Registry Works

The DPP system follows a decentralized data architecture — the EU is not building a single central cloud to store all product data. Instead:

  • Companies create and host their own DPP data (directly or via service providers)
  • Each DPP is associated with a unique product identifier
  • Companies register their DPPs on the central EU registry
  • The registry acts as a lookup/discovery layer — pointing to where data is hosted

Registry's Role in Backup

The central registry is critical for backup failover:

  • It knows which backup provider holds copies for each company
  • If the primary data source becomes unavailable, the registry can redirect requests to the backup provider
  • It ensures there's always a resolvable path from product identifier to DPP data
  • Market surveillance authorities can use it to verify backup compliance

Decentralized but Resilient

The decentralized approach means no single point of failure for the entire DPP ecosystem. But it does mean each company must ensure their individual DPP hosting is resilient — which is exactly why the backup requirement exists.

Timeline: The EU DPP registry infrastructure is being developed alongside the first delegated acts. Technical specifications are expected to be finalized in 2026, with the registry operational before the first DPP mandates take effect.

5. Technical Requirements for DPP Data Preservation

Preserving DPP data for decades requires careful technical planning across formats, standards, and infrastructure.

Data Formats & Standards

  • JSON-LD: The expected primary format for DPP data, providing linked data capabilities
  • Schema.org vocabularies: Standardized data models for product information
  • ETSI standards: European standards for digital signatures and data integrity
  • W3C Verifiable Credentials: For authenticating data provenance

Interoperability Requirements

The ESPR mandates that DPP systems must be interoperable. This means:

  • Standard APIs for data access and retrieval
  • Common data models across product categories
  • Machine-readable formats for automated processing
  • Human-readable presentations for consumers

Backup Technical Considerations

  • Data integrity: Cryptographic hashes to verify backup copies match originals
  • Version control: DPP data can be updated (e.g., after repairs) — backups must handle versioning
  • Synchronization: Backup copies must stay current with the primary data source
  • Format migration: Over 30+ years, data formats may evolve — backup providers must handle migrations
  • Geographic redundancy: Data should be stored in multiple physical locations within the EU

Storage Architecture

Effective DPP backup requires a multi-tier storage approach:

  • Hot storage: Immediately accessible copies for real-time queries
  • Warm storage: Near-line copies for failover scenarios
  • Cold/archive storage: Long-term preservation copies with lower access frequency

6. GS1 Digital Link & URL Persistence

GS1 Digital Link is the primary data carrier standard for DPP access, and its persistence is directly tied to the backup challenge.

What is GS1 Digital Link?

GS1 Digital Link encodes product identifiers (GTINs, serial numbers) into web URLs. When a consumer scans a QR code on a product, the URL resolves to the DPP data. Example:

https://id.example.com/01/09506000134352/21/ABC123

The URL Persistence Problem

The URL contains a domain name owned by the company. If the company disappears:

  • The domain expires and stops resolving
  • The server behind the URL goes offline
  • The QR code becomes a dead link

Solutions for URL Persistence

  • GS1 resolver network: A distributed network of resolvers that can redirect requests based on the product identifier, regardless of the original domain
  • EU registry resolver: The central DPP registry can act as a fallback resolver, redirecting to backup data
  • Permanent identifiers: Using DOI-like persistent identifiers that are independent of any single company's infrastructure
  • Domain escrow: Backup providers can take over domain resolution for defunct companies

Best Practice: Companies should use GS1 Digital Link resolvers that support multi-destination resolution. This means the same QR code can point to the primary DPP server, the backup provider, and the EU registry simultaneously.

7. Data Sovereignty & GDPR Implications

DPP backup intersects with data protection law in several important ways.

What DPP Data is Personal?

Most DPP data is product-related (materials, manufacturing data, recycling instructions) and not personal data. However, some DPP data may become personal:

  • Product ownership history (if tracked)
  • Usage patterns from connected products
  • Repair history linked to identifiable individuals
  • Purchase information in private DPP sections

GDPR Compliance for Backup Providers

Backup providers storing any personal data elements must:

  • Act as data processors under GDPR Article 28
  • Store data within the EU/EEA (or approved jurisdictions)
  • Implement appropriate technical and organizational measures
  • Support data subject rights (access, erasure, portability)
  • Maintain data processing agreements with economic operators

Data Sovereignty Considerations

The ESPR's requirement for backup storage raises sovereignty questions:

  • Where must backup data be stored? EU data sovereignty rules may require storage within the EU
  • Who controls the data? The ESPR specifies that backup providers cannot sell or reuse DPP data
  • Cross-border access: Market surveillance authorities from different member states need access
  • Trade secrets: Some DPP data (like material composition) may be commercially sensitive

8. Industry Solutions & Approaches

Several approaches are emerging to address the DPP backup challenge.

Certified Third-Party Storage Providers

The most straightforward approach: specialized companies that offer EU-certified DPP backup storage. These providers:

  • Receive and store copies of DPP data from economic operators
  • Maintain high-availability infrastructure
  • Can serve data if the primary source becomes unavailable
  • Meet EU certification requirements for data security and reliability

DPP-as-a-Service Platforms

Many DPP solution providers are building backup into their core offering:

  • Automatic replication across multiple data centers
  • Built-in failover mechanisms
  • Long-term data archival capabilities
  • Integration with the EU DPP registry

Industry Consortia

Sector-specific approaches where industry groups collectively manage DPP backup:

  • Battery industry: Battery Passport consortium models
  • Textiles: Fashion industry data sharing initiatives
  • Electronics: WEEE-connected data preservation

Open Source & Standards-Based Approaches

The CIRPASS project and other EU-funded initiatives are developing open standards for DPP data exchange and backup, ensuring vendor independence and long-term interoperability.

9. Blockchain & Decentralized Solutions for DPP Backup

Blockchain and decentralized technologies offer unique advantages for DPP data persistence.

Why Blockchain for DPP Backup?

The EU has explicitly acknowledged that "blockchains could provide a solution to information persistence because data is stored on globally available, persistent public ledgers." Key advantages:

  • Immutability: Once written, data cannot be altered or deleted
  • Persistence: No single entity can shut down the network
  • Transparency: Data availability can be verified by anyone
  • No single point of failure: Distributed across thousands of nodes

Approaches

  • On-chain hashes: Store cryptographic hashes of DPP data on-chain for integrity verification, with actual data stored off-chain
  • Decentralized storage (IPFS/Filecoin): Store DPP data on decentralized file networks with blockchain-based addressing
  • DID/Verifiable Credentials: Use W3C Decentralized Identifiers for product identity and verifiable credentials for DPP data claims
  • Smart contracts: Automate backup verification and failover logic

Limitations

  • Cost: Storing large amounts of data on-chain can be expensive
  • Updatability: DPP data needs to be updateable (repairs, ownership changes) — blockchain immutability can be a challenge
  • GDPR right to erasure: Immutable data conflicts with deletion requirements
  • Scalability: Billions of products × detailed DPP data = massive scale
  • Regulatory uncertainty: EU hasn't mandated or prohibited blockchain for DPP

Hybrid Approach: The most promising solutions combine blockchain (for integrity proofs and persistent addressing) with traditional cloud storage (for the actual DPP data), getting the best of both worlds.

10. Cost Implications of Long-Term DPP Data Storage

Maintaining DPP data for decades introduces significant cost considerations.

Storage Cost Factors

  • Data volume: A single DPP might be 10KB-10MB depending on product complexity
  • Number of products: Large manufacturers may have millions of unique DPPs
  • Retention period: 10-50+ years of continuous hosting
  • Availability requirements: 24/7 access with high uptime SLAs
  • Synchronization costs: Keeping backup copies up-to-date

Cost Estimates

DPP backup service pricing is still emerging. No established market pricing exists yet, as the certified backup provider framework is being developed alongside the first delegated acts. Costs will depend on:

  • Product volume — number of unique DPPs to store
  • Retention period — 5 years for electronics vs 50+ years for construction
  • Data complexity — simple product data vs rich lifecycle records
  • Update frequency — static snapshots vs dynamic data synchronization

As the market matures and delegated acts define specific requirements, pricing models will become clearer. Early movers who establish backup infrastructure now will likely benefit from lower costs and better provider terms.

Who Pays?

The ESPR framework makes the economic operator (manufacturer/importer) responsible for DPP costs, including backup. However:

  • Access to DPP data must remain free for end users
  • Backup provider fees are market-driven
  • Industry consolidation may drive down per-product costs
  • Pre-payment/escrow models may be needed for post-insolvency periods

11. Best Practices for DPP Backup Strategy

Companies preparing for DPP compliance should build backup into their strategy from day one.

Strategic Recommendations

  1. Start early: Don't wait for delegated acts to finalize. Build backup-ready DPP infrastructure now.
  2. Choose certified providers: Work with backup providers that are pursuing EU certification.
  3. Use standard formats: JSON-LD, GS1 Digital Link, and standard APIs ensure your data is portable between providers.
  4. Plan for the long term: Model your backup costs over the full expected product lifecycle, not just year one.
  5. Test failover: Regularly verify that your backup data is complete, current, and accessible.
  6. Document everything: Maintain clear records of your backup arrangements for regulatory audits.
  7. Consider redundancy: A single backup provider is good; multiple providers or a blockchain hash layer adds extra security.
  8. Automate synchronization: Manual backup processes will fail. Use automated, API-driven sync.

Technical Checklist

  • DPP data exported in standard machine-readable format
  • Automated backup sync with certified third-party provider
  • Cryptographic integrity verification of backup copies
  • Failover DNS/resolver configuration tested
  • Data retention policy covering full product lifecycle
  • GDPR data processing agreement with backup provider
  • Version history maintained for updated DPP records
  • Disaster recovery plan documented and tested annually

Pro Tip: Treat DPP backup like a critical business continuity requirement — because under EU law, that's exactly what it is.

Frequently Asked Questions

Common questions about Digital Product Passport backup requirements.

What is DPP Backup?
DPP Backup refers to the mandatory requirement under the EU ESPR regulation for companies to maintain backup copies of their Digital Product Passports with certified third-party providers. This ensures DPP data survives company insolvency, system failures, and remains accessible for the product's entire lifecycle — potentially 10-30+ years.
Why is DPP backup required by the EU?
Products often outlive the companies that make them. A washing machine lasts 15 years; a building component lasts 50+. The EU requires backup to ensure sustainability data, repair instructions, and recycling information remain available even if the manufacturer goes bankrupt, changes systems, or exits the market.
What happens to DPP data when a company goes bankrupt?
Under ESPR, DPP data must remain accessible even in cases of insolvency or market withdrawal. The certified backup provider continues serving the data, and the EU DPP registry can redirect lookups from the defunct company's systems to the backup provider. Without this mechanism, millions of product QR codes would become dead links.
Who are certified DPP backup service providers?
These are independent third parties certified by the EU to store backup copies of Digital Product Passports. They must meet specific security, availability, and data protection requirements. They cannot sell, reuse, or process stored DPP data beyond what is necessary for the storage service. The certification framework is being developed alongside the first delegated acts.
Can blockchain be used for DPP backup?
Yes. The EU has acknowledged that blockchain could provide a solution for DPP data persistence since data is stored on globally available, persistent public ledgers. While not mandatory, blockchain-based approaches — especially hybrid models combining on-chain integrity proofs with off-chain data storage — are promising. Challenges include cost, scalability, and GDPR compliance.
How long must DPP backup data be retained?
The retention period is defined in the delegated acts for each product category, typically covering the expected product lifetime. This ranges from 5-15 years for electronics, 10-20 years for batteries, and 30-50+ years for construction materials. Backup providers must maintain data for the full specified period.
Is access to DPP backup data free?
Yes. The ESPR states that access to mandatory DPP data must be free of charge for end users, regulators, and other stakeholders. The costs of hosting and backup are borne by the economic operator (manufacturer/importer), while the backup provider's fees are market-driven.
What are the penalties for not having DPP backup?
The ESPR provides for penalties including fines imposed by EU member states on non-compliant companies. Specific penalty amounts will be defined by each member state. Beyond fines, products without compliant DPPs (including backup) could be banned from the EU market.
Does DPP backup apply to non-EU companies?
Yes. Any company placing products on the EU market — regardless of where they are headquartered — must comply with DPP requirements, including the backup obligation. This applies to manufacturers, importers, and third-party marketplace sellers.
When do DPP backup requirements start?
The first DPP requirements (for batteries) take effect from February 2027. Other product categories will follow through delegated acts between 2028-2030. Companies should begin preparing their DPP backup strategy now, as certification processes and provider selection take time.

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