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.
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.
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 February 18, 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 fixed dates yet — the first Delegated Acts are expected no earlier than 2028/2029.
- 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 batteries above 2 kWh. 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.
Timeline: When Does What Apply?
The deadlines differ significantly:
Battery Passport (EU Battery Regulation):
- August 2025: Mandatory CO₂ footprint declaration for EV and industrial batteries > 2 kWh
- February 2027: Full digital battery passport becomes mandatory
- August 2028: CO₂ performance classes and limits take effect
Digital Product Passport (ESPR):
- July 2024: ESPR entered into force
- 2025–2027: Drafting of the first product-specific Delegated Acts (likely textiles, electronics, steel/iron)
- 2028–2030: 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 February 18, 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
- However: preparation is worthwhile now, as ESPR Delegated Acts are coming
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.
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 2025–2027, with phased introduction from 2028–2030. 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.