What is a Digital Product Passport (DPP)?
The Digital Product Passport (DPP) is a core instrument of the European Ecodesign for Sustainable Products Regulation (ESPR), which entered into force in July 2024. It is designed to cover nearly all physical products on the EU single market, from textiles and electronics to construction materials.
What a creation tool for both looks like is shown on the DPP software page.
The goal: consumers, recyclers, and authorities gain access to standardized information about a product's origin, composition, repairability, and environmental impact. The DPP is accessed via a machine-readable data carrier (e.g., QR code) and linked to an EU-wide registry.
Important: The DPP is a framework concept. The specific data requirements are defined separately for each product category through so-called Delegated Acts. This means a DPP for textiles will contain entirely different fields than a DPP for batteries. For product categories other than batteries there are no fixed dates yet; the first delegated acts are expected in 2028 or 2029 at the earliest.
What is a Battery Passport?
The battery passport is the first and most concrete implementation of the Digital Product Passport. It is mandated by the EU Battery Regulation (EU) 2023/1542 and becomes mandatory from 18 February 2027 for EV batteries, industrial batteries (> 2 kWh), and LMT batteries.
Unlike the general DPP framework, the data requirements for the battery passport are already largely defined, particularly through the DIN DKE SPEC 99100:2025-02, which establishes the technical data standard.
The battery passport covers seven data categories: identification, materials and composition, carbon footprint, supply chain due diligence, circularity, performance and durability, and labeling and conformity. For a comprehensive overview, see our article What is a Battery Passport?
Key Differences at a Glance
Although the battery passport is technically a Digital Product Passport, there are significant differences in scope, timeline, and implementation readiness:
- Legal basis: The DPP is based on the ESPR (framework regulation), while the battery passport is based on the EU Battery Regulation (sector-specific).
- Timeline: The battery passport becomes mandatory in February 2027. For other DPP product categories there are no binding dates yet: under the ESPR working plan 2025 to 2030 the first delegated acts are expected from 2026 onwards, starting with iron and steel, and the DPP obligation follows roughly 18 months after each act.
- Data standard: The battery passport already has a technical standard in DIN SPEC 99100. For other product categories, no comparable data model exists yet.
- Scope: The battery passport applies to EV batteries, LMT batteries and industrial batteries above 2 kWh. The 2 kWh threshold applies to industrial batteries only. The DPP is intended to cover nearly all products on the EU market long-term.
- Implementation tools: Specialized software like DPP Hero already exists for the battery passport. For other DPP categories, no established tooling is available yet.
Legal Framework: ESPR and EU Battery Regulation
The two regulations are hierarchically related:
The ESPR (Regulation (EU) 2024/1781) is the overarching framework regulation. It defines the Digital Product Passport concept, establishes the architecture (data carriers, registry, access rights), and empowers the European Commission to issue product-specific requirements via Delegated Acts.
The EU Battery Regulation (Regulation (EU) 2023/1542) is sector-specific and was adopted before the ESPR. Articles 77 and 78 contain concrete requirements for the battery passport, including the obligation to provide it via a QR code and link it to the EU registry.
For battery manufacturers, this means: you should primarily follow the EU Battery Regulation and its timeline. The ESPR provides the technical infrastructure (registry, data carrier standards), but the content requirements come from the Battery Regulation.
Other product passports besides ESPR and batteries
The comparison “battery passport versus ESPR product passport” now falls short, because the legislator has built the passport into other acts as well. Three are already adopted, one refers to the others:
- Construction products, Regulation (EU) 2024/3110: creates a passport system of its own for construction products which, in the words of the regulation, corresponds “as far as possible to the digital product passport under Regulation (EU) 2024/1781”.
- Toys, Regulation (EU) 2025/2509: the new toy safety regulation works with the digital product passport throughout, down to the option of providing warnings digitally through it.
- Detergents, Regulation (EU) 2026/405: requires a product passport and a digital label; the technical documentation has to be kept for ten years from placing on the market.
- Packaging, Regulation (EU) 2025/40: creates no passport of its own but points to the others: where the packaged product falls under the ESPR or other Union law requiring a passport, “that digital product passport should also be used for making available the relevant information under this Regulation”.
In practice the question is no longer “battery passport or DPP” but “which acts hit my range, and how many passports does that produce”.
The difference that decides the choice of system
Between the regimes lies a technical difference that often only shows up during implementation: an ESPR product passport is initially a mostly static record. It describes the product as placed on the market, and little changes afterwards. The battery passport is built differently from the start.
For the individual battery, Annex XIII point 4 requires values that change over the service life: the performance and durability values “when the battery is placed on the market and when it is subject to changes in its status”, the state of health under Article 14, the status, and the data resulting from its use. Article 77(4) additionally requires the information to stay “up to date”.
So when choosing a system, check whether it can carry data forward: an interface for later condition data, versioning, and access levels that keep those values out of the public view. A tool that only produces a record once carries a battery passport no further than the day of sale.
Battery-powered products: two passports, not one
At the interface it gets concrete. A built-in battery remains a battery in the sense of the Battery Regulation, even inside an e-bike, a power tool or a vehicle. It carries its own battery passport, and the duty for it sits with the economic operator that placed the battery on the market.
The end product itself may later get its own product passport under the ESPR, once a delegated act covers its product group. Then two passports exist side by side, under different legal bases, with different responsible parties and different deadlines. Article 78(a) does require the battery passport to be “fully interoperable with other digital product passports” required under the ecodesign rules; that does not merge them.
Timeline: When Does What Apply?
The deadlines differ significantly:
Battery Passport (EU Battery Regulation):
- CO₂ footprint declaration: not yet triggered. Article 7(1) of the EU Battery Regulation ties it to 18 February 2025 for EV batteries and 18 February 2026 for rechargeable industrial batteries above 2 kWh, or to 12 respectively 18 months after the delegated methodology act and the implementing act on the format enter into force, whichever is later. Neither act had been adopted as of 21 August 2026.
- February 2027: Full digital battery passport becomes mandatory
- 18 August 2026: CO₂ performance classes for EV batteries, once the corresponding delegated act is in place (as of 21 August 2026 it has not been adopted); maximum CO₂ threshold from 18 February 2028
Digital Product Passport (ESPR):
- July 2024: ESPR entered into force
- 2025 to 2027: Drafting of the first product-specific Delegated Acts (likely textiles, electronics, steel/iron)
- 2028 to 2030: Phased introduction of the first DPPs for additional product categories
- 2030+: Broader coverage across more product groups
The battery passport is the frontrunner, it will become mandatory at least one to two years before most other DPP categories.
What Data Does the Battery Passport Contain?
DIN DKE SPEC 99100 defines seven data categories for the battery passport:
- Identification (Section 6.1): Product name, GTIN, serial number, manufacturer, manufacturing facility, economic operator
- Materials and Composition (Section 6.5): Battery chemistry, cathode material, anode material, electrolyte, hazardous substances, critical raw materials
- Carbon Footprint (Section 6.3): Total carbon footprint per kWh, broken down by lifecycle phases
- Due Diligence (Section 6.4): Due diligence reports, audit reports, supply chain risk assessment
- Circularity (Section 6.6): Disassembly instructions, spare parts availability, recycling rates for cobalt, lithium, nickel, lead
- Performance and Durability (Section 6.7): Rated capacity, voltage, energy content, cycle life, internal resistance
- Labeling and Conformity (Section 6.2): EU declaration of conformity, test reports, CE marking, battery symbols
For the general DPP under the ESPR, comparable categories are planned, but the specific fields will only be defined through the respective Delegated Acts. For detailed information on the carbon footprint, see our article Carbon Footprint in the Battery Passport.
Do You Need a Battery Passport or a DPP?
The answer depends on your product:
You need a battery passport if:
- You manufacture, import, or place EV batteries, industrial batteries (> 2 kWh), or LMT batteries on the EU market
- Your product first enters the EU market on or after 18 February 2027
- You are the economic operator (manufacturer, authorized representative, or importer) responsible for EU conformity
You don't (yet) need a DPP if:
- Your product is not a battery and doesn't fall under an already adopted product category
Preparation is still worthwhile today, because the ESPR delegated acts for further product categories are on the way.
For battery manufacturers, the path is clear: start structuring your data now and don't wait until the last months before the deadline. Specialized tools like DPP Hero provide the DIN SPEC 99100 data structure out of the box, without months-long IT projects.
Data carriers, product groups and roles: three differences up close
The data carrier. The Battery Regulation commits: under Article 13(6), every battery carries a QR code from 18 February 2027. The Ecodesign Regulation stays open and defines the data carrier as “a barcode, a two-dimensional symbol or another automatic data capture medium that can be read by a device”. NFC tags and RFID are possible there, not for the battery passport. Serve both and you plan the QR code as the lowest common denominator.
The product groups. Which groups the ESPR covers and when is set out in the Ecodesign Working Plan 2025 to 2030 (COM(2025) 187 final of 16 April 2025): iron and steel in 2026, textiles and clothing plus tyres and aluminium in 2027, furniture in 2028, mattresses in 2029. Two horizontal requirements come alongside: repairability in 2027, recycled content and recyclability of electrical and electronic equipment in 2029.
The roles. Both acts allocate duties by role but name them differently. The ESPR groups under “economic operator”: the manufacturer, the authorised representative, the importer, the distributor, the dealer and the fulfilment service provider. What matters for your exposure is therefore not what your invoice says, but which of these roles you occupy in the specific transaction.
Frequently Asked Questions
Is the battery passport a Digital Product Passport?
Yes, the battery passport is a specific implementation of the Digital Product Passport. It follows the DPP framework of the ESPR but is defined by the EU Battery Regulation with its own battery-specific data requirements.
When will the Digital Product Passport become mandatory for other products?
The first DPP Delegated Acts under the ESPR are expected to be adopted between 2025 and 2027, with phased introduction from 2028 to 2030. For a complete overview of all product categories and deadlines, see our ESPR Timeline. The battery passport remains the frontrunner with a mandatory date of February 2027.
Is there a unified data standard for all DPPs?
No. Each product category will receive its own data requirements. The battery passport already has DIN DKE SPEC 99100 as a technical standard. For other categories, CEN/CENELEC standardization groups are working on comparable specifications.
Can companies prepare for the general DPP now?
Yes, and it makes sense to do so. Companies should start structuring their product data, documenting supply chain information, and building internal processes for data collection. Those who start with the battery passport today will have a significant experience advantage for future DPP requirements.
What happens if a manufacturer doesn't provide a battery passport?
From February 2027, affected batteries without a valid battery passport may no longer be placed on the EU market. Violations can lead to market surveillance actions, recalls, and fines. The specific sanctions are determined by EU member states.
