Digital Product Passport in Adhesives: The Invisible Component Becomes Visible

Summary

The Digital Product Passport (DPP), implemented under the European Union's Ecodesign for Sustainable Products Regulation (ESPR) and the Construction Products Regulation (CPR), is forcing adhesive and binder manufacturers into a fundamental transformation ranging from formulation transparency to supply chain traceability. Adhesives, which are usually an invisible component of only a few grams in the final product, will now have their own digital identity.

1. Why Did Adhesives Suddenly Move to the Center of Regulation?

Adhesives are a component that bonds two or more materials together in nearly every sector from automotive to packaging, construction to electronics, yet remain physically "invisible" in the final product. It is precisely this invisibility that has, for years, kept adhesives in the shadow of environmental and circularity regulations. While the wood of a piece of furniture, the steel of a vehicle, or the plastic of a package is separated at recycling facilities, the epoxy, polyurethane or acrylic-based adhesive systems holding those parts together have almost never been questioned.

The ESPR, which entered into force in July 2024 and will be fully implemented in July 2026, has introduced durability, repairability, recyclability and environmental transparency requirements for nearly all physical products placed on the EU market. The obligation to present these requirements for each product under the Digital Product Passport (DPP) has been implemented. 

With the DPP, a structured data layer accessible via a QR code, RFID tag or NFC chip on the product is provided, containing material composition, chemical content, carbon footprint and end-of-life instructions. 

The truly critical point for adhesive manufacturers is that the sector is, in most cases, not directly subject to the DPP obligation, but is included indirectly through the passports of the product groups it serves (construction materials, packaging, furniture, textiles, automotive, electronics). For a construction adhesive manufacturer, the primary framework is the renewed CPR, which introduces a passport system specific to construction products, while for applications outside the scope of construction, the ESPR comes into play. As a result, formulation data must now be present not only in the manufacturer's own quality system but also in the digital passport of the downstream sector.

2. Regulatory Framework: ESPR, CPR and Timeline

The EU Commission's central DPP Registry (EU Registry) was activated in July 2026. Thus, the infrastructure that houses the unique identifiers of product passports and can be queried by customs and market surveillance authorities is now functional. However, the transition process will proceed gradually. The first legally fixed date will enter into force for batteries in February 2027. According to the ESPR Working Plan covering 2025-2030; the DPP obligation will begin for iron and steel by the end of 2026, for aluminum, textiles and tires in 2027, for furniture in 2028, and for electronics and mattress groups in 2029. In addition, a development directly concerning adhesives will be the establishment of a separate construction-specific DPP system under the Construction Products Regulation (CPR). This system is expected to be a passport compatible with CE marking, containing technical, safety, compliance and environmental information. This chronology provides an important strategic clue for adhesive manufacturers. Expecting a separate "adhesive delegated act" for adhesives themselves would be the wrong strategy. What is actually decisive is when the final product group in which the adhesive is used will become subject to the passport obligation. 

3. What's in the Passport? Adhesive-Specific Data Layers

The data architecture of the DPP consists of five basic layers: product identity, material composition, performance and sustainability, repair/end-of-life information, and compliance documents. For adhesives, each of these layers carries serious sector-specific technical and commercial sensitivities.

3.1. Material Composition and Substances of Concern (SoC)

ESPR's definition of "Substances of Concern" covers an estimated 4,600 or more substances, including Substances of Very High Concern (SVHC) under REACH, substances falling into certain CLP hazard classes, and persistent organic pollutants. Isocyanates, epoxy resins, solvents and certain plasticizers frequently found in adhesive formulations are directly targeted by this list. Every SVHC above the 0.1% weight threshold must be declared in the passport. This requires a delicate balance to be struck between formulation confidentiality and the transparency obligation.

3.2. Carbon Footprint and Environmental Performance

The passport requires indicators such as product carbon footprint, recycled content ratio, and biodegradation period (not yet standardized specifically for adhesives but on the agenda), and microplastic pollution. The sector alliance led by the Royal Society of Chemistry (RSC), which develops a passport for "Polymers in Liquid Formulations" (PLF) including sealants and adhesives, aims precisely to fill this gap. For this purpose, separate sustainability targets for single-use and durable products, as well as metrics such as packaging recyclability and water use efficiency, have been defined.

3.3. Application, Disassembly and End-of-Life

Regarding the separability of materials bonded with adhesive, a high-performance but non-disassemblable bond can lead to the loss of valuable materials at recycling facilities. For this reason, the DPP encourages adhesive selection to be evaluated not only by bonding strength and durability criteria, but together with disassembly and recycling compatibility criteria. Systems with heat-releasable, solvent-dissolvable or controlled debonding technologies in particular gain a competitive advantage in this context. 

4. Data Collection: Between Confidentiality and Transparency

The vast majority of adhesive manufacturers protect their formulations as their most critical trade secrets. The tension between the transparency demand brought by the DPP and intellectual property protection is the most concrete implementation problem facing the sector. An automotive OEM should request not the full chemical recipe of the adhesive obtained from its supplier, but structured data points sufficient to fill out the passport (presence/absence of SVHC, weight percentages, hazard classes). This forces adhesive manufacturers to move their data out of PDF safety data sheets and into structured databases that communicate with ERP, PIM (Product Information Management) and Life Cycle Assessment (LCA) systems.

5. Building the Data Infrastructure: Combining PIM, ERP and LCA

The PIM system holds the material composition and compliance documents for each Stock Keeping Unit (SKU) as a central record. The ERP system feeds batch/lot-based production data and supplier-sourced raw material information. Life Cycle Assessment (LCA) calculates carbon footprint and environmental impact indicators. The DPP itself is merely a presentation layer fed by these three sources, accessed via a QR code or RFID tag. In fact, it is not a separate system that "fills" the passport, but an output of the correctly integrated existing systems. The most frequently overlooked dimension of this integration is the requirement for traceability at the batch (lot) level. 

An adhesive formulation may undergo a change of raw material supplier or recipe revision over time; therefore, the passport must be able to present accurate data at the "batch/version" level, not the "product" level. This requires the product-version relationship to be clearly modeled in the PIM system, and the batch-supplier relationship in the ERP. Additionally, in order to realistically provide carbon footprint and environmental impacts, primary (raw) data from product manufacturing should be used as the first priority in LCA analyses. If this primary data cannot be accessed under any circumstances, database emission values from datasets such as IDEMAT, SimaPro, GaBi, OpenLCA should be used. Environmental impact values calculated as a result of analyses generally performed with primary data can be considerably lower than analysis values obtained using database emission values from datasets.

6. A Practical Roadmap for Manufacturers

Although the DPP does not yet directly mandate adhesives, the cost of being caught unprepared will be high. For this reason, companies should treat the following steps not as a "one-time project" but as a reusable compliance infrastructure;

Centralize formulation data: Safety data sheets, technical data sheets and LCA outputs should be combined in a single, structured data source.

Build your SVHC and substances of concern inventory today: All components or substances exceeding the 0.1% threshold should be recorded by weight percentage and hazard class.

Monitor your customer sector's timeline: If you sell to automotive, packaging, construction or furniture, your DPP obligation depends on that sector's delegated act.

Build carbon footprint and LCA capacity: Companies that cannot produce product-based carbon data will be at a disadvantage in major customer contracts.

Invest in R&D for disassembly and debonding technologies; Disconnectable bonds will provide a competitive advantage under future circularity criteria.

Establish a data governance policy: Define in advance what data will be shared with whom and at what access level; establish layered access models that ensure compliance while protecting intellectual property.

Join sector alliances: Joint efforts such as the RSC's PLF passport initiative are the most effective way to make the adhesive sector's voice heard in the formation of common standards.

7. Conclusion: Transparency Is Not a Burden But an Opportunity for Differentiation

The Digital Product Passport may appear to be an administrative burden for the adhesive sector in the short term, as it requires opening up formulation data, investing in data infrastructure and supply chain coordination. However, in the medium term, transparency has become not only a compliance cost but also a tool for differentiation. Adhesive manufacturers that can prove their carbon footprint, do not contain substances of concern, and offer disassemblable bonds will stand out in the supplier selection criteria of major OEMs and construction companies.

As the EU Commission itself states, the DPP infrastructure is being established in 2026, and the actual product-based obligations will come into effect from 2027 onward. This situation offers the sector a window of opportunity. Before legal obligations come knocking at the door, there is still time to build data systems, map the supply chain, and turn sustainability data into a competitive advantage. The invisible component becoming visible is, in fact, an opportunity for the adhesive sector to strengthen its strategic position in the value chain.