2026-04 · 8 min read · All articles

Digital Product Passport and Reused Goods: What Refurbishers and Collection PROs Need to Know

One of the most frequent questions we hear from businesses in the circular economy: when a Producer Responsibility Organisation (PRO) collects used textiles, or a refurbisher repairs and resells used phones, do they need to issue a new GTIN and a new Digital Product Passport (DPP)?

The short answer is: it depends on what you actually do with the product. ESPR (Regulation 2024/1781) draws a clear line in principle — but the practical detail is set by the delegated acts for each product category.

Key distinction: reuse vs. remanufacturing

ESPR distinguishes two fundamentally different scenarios.

Reuse means the product is collected, inspected, cleaned, and possibly given minor repair, then resold in essentially its original state. In this case, no new DPP is required. The original passport, if one exists, remains valid and travels with the product to the next user. This is an important principle — the DPP is the "biography" of a specific physical item, not of a commercial transaction.

Remanufacturing, by contrast, means the product is significantly modified: components are replaced, warranty is renewed, function or specification changes. Here the remanufacturer becomes a new "economic operator placing the product on the market" within the meaning of Article 9 ESPR. A new DPP must be issued and the operator takes on the responsibilities of a manufacturer.

The boundary between the two categories is not always sharp — the delegated acts for individual categories will define it more precisely. The clearest existing precedent is the Battery Regulation (2023/1542), where remanufactured batteries explicitly get a new DPP and the original is linked to it.

Textile (a PRO collects and resells second-hand)

If a PRO only collects, sorts and resells clothing in its original state (the typical second-hand channel), this counts as reuse — no new DPP is required. The PRO functions as a waste operator and subsequently a distributor of used goods, not as a manufacturer.

Caveat: textiles do not yet have an approved delegated act for DPP (one is being prepared, expected 2027–2028). So for most textiles being collected today, no original DPP exists that would need to be transferred. EPR obligations for textiles (from the revision of the Waste Framework Directive) are a separate regime.

If, however, the PRO does upcycling — for example shredding old clothes and sewing new products from them — that is a new product, and the full producer obligation applies, including a new GTIN and DPP.

Mobile phones (a PRO collects and resells as refurbished)

This is almost always refurbishment, not just reuse. A refurbisher typically:

• replaces the battery
• replaces the display or other components
• reinstalls firmware
• provides a new warranty (typically 12–24 months)

In doing so they become a new economic operator with obligations comparable to the original manufacturer:

1. New DPP with their own data — who refurbished it, when, which components were replaced, what the new warranty is, environmental profile data after refurbishment. The original DPP (if any) should be linked as a reference.
2. New GTIN — this is a GS1 rule, not ESPR. GS1 rules require a new GTIN whenever the product changes in parameters that affect the consumer or trade channel (warranty, specification, packaging for the refurbished market). A refurbished iPhone 13 gets a different GTIN from a new iPhone 13.
3. CE marking and declaration of conformity — the refurbisher takes on responsibility for compliance with radio, EMC and safety directives.
4. WEEE registration as producer (in every Member State where they place the product on the market).
5. Product safety responsibility under GPSR (Regulation 2023/988).
6. Consumer rights — minimum 12-month warranty for used goods (Directive 2019/771; some Member States require longer).

What this means in practice

Refurbishers and remanufacturers are full-fledged economic operators with the same DPP obligations as original manufacturers — they are simply smaller and often less technologically equipped. This is precisely the segment that needs accessible self-service tools.

When the delegated acts for electronics are adopted (expected 2026–2027), DPP linking will become important: the new passport must reference the original. Anyone choosing a DPP platform today should make sure the data model is ready for this.

This article is a regulatory overview, not legal advice. For specific implementations — particularly once the delegated acts for textiles and electronics are finalised — we recommend consulting a lawyer specialising in ESPR.