DPP Guide
What is a Digital Product Passport? Explained for exporters.
ESPR entered into force on 18 July 2024 as a framework for covered product groups. EUDR applies from 30 December 2026 for large and medium operators. Here is what that means for Kenyan exporters — in plain language.
The Basics
The questions exporters ask most.
What is a Digital Product Passport?
A Digital Product Passport (DPP) is a standardised, machine-readable digital record linked to a physical product via a QR code or data carrier. It contains structured information about the product's origin, composition, sustainability credentials, and supply chain journey. Under Regulation (EU) 2024/1781 (ESPR), DPPs become legal requirements only for product groups covered by later delegated acts; ESPR itself excludes food and feed.
Which regulation requires it — and is it already in force?
The EU Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) entered into force on 18 July 2024. It is framework law: product-specific DPP requirements apply later through delegated acts. Separately, the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) applies to large and medium operators from 30 December 2026 and to most micro and small operators from 30 June 2027.
Does this affect Kenyan exporters specifically?
Yes, but the route differs by product. Kenyan coffee supply chains are directly exposed to EUDR because coffee is a listed commodity. Tea and avocado exporters are more likely to face buyer-led traceability, packaging, sustainability, and product-data requests unless future EU rules change their legal scope. In practice, EU buyers may ask for structured data before a supplier has a direct filing obligation.
When do food exporters need to act?
There is no confirmed ESPR deadline making food or feed exports carry mandatory DPPs. What is confirmed is that ESPR entered into force on 18 July 2024 for covered product groups, while EUDR applies to covered commodities such as coffee from 30 December 2026 for large and medium operators. Buyers may request DPP-style data earlier so they can manage traceability, sustainability, packaging, and due diligence systems.
What data does a DPP contain?
Data requirements vary by product category and are finalised through delegated acts. For covered product groups, DPP data can include identifiers, materials, environmental performance, substances of concern, repairability, and supply chain information. For Kenyan agricultural exporters, the practical preparation layer is buyer evidence: farm location, supplier identity, legality records, certifications, pesticide records, water-use evidence, cold-chain logs, batch numbers, and shipment traceability.
How is a DPP actually accessed?
A DPP is accessed via a data carrier attached to the product or its packaging — typically a QR code, but also NFC, RFID, or GS1 DataMatrix. When scanned, the carrier resolves to a web-based URI (following GS1 Digital Link standards) that retrieves the DPP data. The data itself is structured in JSON-LD format, making it machine-readable by EU customs systems, buyer platforms, and market surveillance authorities.
Three Regulations
EUDR, ESPR, and DPP: What's the difference?
| Aspect | EUDR | ESPR | DPP |
|---|---|---|---|
| Full Name | EU Deforestation Regulation | Ecodesign for Sustainable Products Regulation | Digital Product Passport |
| Focus | Commodity traceability | Product sustainability | Machine-readable product data |
| Applies To | Operators exporting coffee, cocoa, timber, soy, palm, cattle to EU | Manufacturers and importers of covered product categories | Any buyer or platform requiring structured product information |
| Deadline | 30 Dec 2026 (large/medium) 30 June 2027 (micro/small) | Framework in force 18 July 2024; product rules via delegated acts | No single deadline; depends on buyer or future ESPR delegated acts |
| Key Step | Geolocation, legality, deforestation-free proof | Environmental metadata, repairability, materials, lifecycle data | JSON-LD, QR/GS1 Digital Link, batch/supplier/certification data |
| Why Kenyans Care | Coffee is listed; requires GPS, supplier ID, legality records | Affects packaged goods; likely impacts future tea/avocado buyers | Already requested by many EU importers |
Bottom line: EUDR is the immediate legal requirement for Kenyan coffee exporters. ESPR is a framework waiting for product-specific rules that may or may not apply to food. DPP is not a separate law — it is the data format and delivery method required to prove EUDR and ESPR compliance.
GS1 Kenya / GTIN Guidance
Why GTINs and GS1 Digital Link matter.
For exporters, GS1 is less about decoration on a label and more about making products identifiable across buyer, retailer, logistics, and compliance systems. The GTIN identifies the product. The barcode or QR code carries the identifier. GS1 Digital Link connects that identifier to online product data.
Kenyan exporters usually need GS1 identifiers when a buyer, retailer, marketplace, or data platform requires standard product identification. They should register through GS1 Kenya where GTINs or GS1-compatible barcodes are needed, then keep the linked product and shipment data accurate.
GTIN identifies the product
A Global Trade Item Number is the unique product identifier used in GS1 barcodes. It tells buyer, retailer, logistics, and platform systems which trade item they are looking at. It does not contain the whole compliance record by itself.
Barcode or QR carries the identifier
A barcode, QR code, or GS1 DataMatrix is the visible data carrier. It lets a scanner read the product identifier, batch or lot details, dates, or a web link depending on the barcode type and buyer requirement.
GS1 Digital Link connects to online data
GS1 Digital Link turns GS1 identifiers into a standard web address. A scan can point to product information, traceability data, certification evidence, recall status, or buyer-specific content through a resolver or product-data page.
The data still has to be maintained
A QR code is only useful if the linked data is accurate. Exporters still need clean product masters, lot records, certificates, farm or supplier data, and shipment files behind the scan.
When exporters need it
A buyer, retailer, marketplace, or importer asks for standard product identifiers.
You sell packaged export SKUs that need barcodes, carton identifiers, or QR-linked product information.
Your buyer wants product data connected to GTINs, batch numbers, lots, certificates, or traceability records.
You are preparing for DPP-style data systems where a physical product needs a persistent digital lookup point.
How it relates to QR product data
A normal QR code can point anywhere. A GS1 Digital Link QR uses a standard structure based on GS1 identifiers, so different systems can recognise the product and route scans to approved information.
For TRACE users, the practical takeaway is simple: do not start with the QR code. Start with clean product identifiers, batch records, supplier data, certificates, and shipment evidence. The QR or Digital Link is the access point, not the evidence itself.
DPP Standards & Formats
The technical standards your DPP must use.
You don't need to implement these yourself — but you need to understand them well enough to ask the right questions when choosing a DPP platform or briefing your cooperative's tech team.
JSON-LD
Technical standardJavaScript Object Notation for Linked Data
A machine-readable linked-data format used in many product-data and web-data systems. ESPR DPP technical rules are still implemented through product-specific measures and standards, but Kenyan exporters can benefit from keeping evidence structured enough for buyer and platform systems.
Action
Ask any platform or buyer portal: 'Can our supplier, lot, farm, certification, and shipment data be exported in a structured machine-readable format?'
EPCIS 2.0
Supply chain standardElectronic Product Code Information Services
A GS1 standard for recording and sharing supply chain events — when goods moved, where they went, what temperature they were stored at, and when they were processed. It is useful for documenting the journey from farm to port even before a formal DPP obligation applies to a product.
Action
Start logging logistics events digitally now — load, in-transit, and delivery — with timestamps and GPS locations. Paper records cannot be converted to EPCIS retroactively.
GS1 Digital Link
OperationalThe QR code web standard
A GS1 web-linking standard that lets QR codes and barcodes resolve to structured product information. It is relevant to future DPP systems and to buyer-facing product data, but it does not by itself create a legal DPP deadline for food exports.
Action
Register export SKUs with GS1 Kenya where product identifiers are needed, and ask buyers whether they expect GTINs, batch numbers, or QR-linked product data.
Verifiable Credentials
AdvancedW3C tamper-proof digital certificates
A W3C standard for issuing machine-verifiable digital certificates. These can support certifications such as organic, deforestation-free, fair trade, or Rainforest Alliance where issuing bodies support them. For now, many Kenyan exporters will still rely on paper or PDF certificates while buyers and certifiers digitise.
Action
Ask the issuing body whether certificates can be verified digitally — for example KEPHIS for phytosanitary documents, or private certifiers for organic and sustainability certificates.
Getting Compliant
Six steps to DPP readiness.
Steps 1–4 are data and infrastructure work that takes 12–24 months. Steps 5–6 are platform and buyer alignment. Starting now is not early — for many cooperatives, it is already late.
Audit your current data against DPP fields
Map every data point you currently collect — farm records, pesticide logs, certifications, logistics documents. Separate confirmed legal needs, such as EUDR evidence for covered commodities, from buyer-led requests such as QR-linked product data, cold-chain proof, or sustainability summaries. The gap between what you have and what buyers need is your readiness gap.
Register GPS farm coordinates — now
EUDR requires geolocation for plots producing covered commodities. For Kenyan coffee supply chains, large and medium EU operators must comply from 30 December 2026, with most micro and small operators following from 30 June 2027. At smallholder cooperative scale — where a single cooperative may have thousands of members — accurate collection can take 12–18 months.
Digitise supply chain events
Paper records, WhatsApp logs, and scattered spreadsheets are hard to audit when buyers ask for shipment evidence. Begin recording key supply chain events digitally: harvest date and location, processing intake, packaging date and batch number, cold-chain readings, and loading or delivery confirmation with timestamps.
Obtain a GS1 GTIN for your products
Many structured product-data systems use Global Trade Item Numbers (GTINs) to link physical products to digital records. Register with GS1 Kenya where your export SKUs need standard product identifiers, especially if buyers expect QR-linked product data or GS1 Digital Link compatibility.
Evaluate DPP platform options
Evaluate platforms against confirmed legal needs and buyer expectations separately. For EUDR, coffee supply chains need traceability, geolocation, legality, and deforestation-free evidence. For DPP-style buyer requests, ask whether the system can structure product, supplier, certification, and shipment data for export.
Brief your EU buyer before they ask
EU importers and operators will ask suppliers for data before some legal deadlines arrive, especially where they need time to build due diligence systems. Contact your EU buyer now and ask which EUDR, packaging, certification, traceability, and product-data fields they need before 30 December 2026.
See when each requirement hits.
Confirmed law, later DPP implementation, buyer pressure, and preparation milestones — separated so you can plan without overclaiming.
Stay informed
Follow the regulatory shift before it becomes a deadline.
TRACE keeps exporters, advisors, and institutions oriented around the records and actions that matter most for DPP readiness.