Digital Product Passport: what is in it, who needs it, from when
The digital product passport makes product data available across the entire life cycle. This page explains the legal basis, the product groups affected, the access levels and the current status of the EU registry, each with its reference in the regulation or a Commission publication.
What a digital product passport is, and what it is not
A digital product passport, DPP for short, is a data record for one specific product that is retrieved through a data carrier on the product, usually a QR code. Anyone scanning the code does not land in a brochure but on verified details about origin, composition, repair and disposal. The passport accompanies the product throughout its life and is updated when something changes.
Equally important is what it is not. It does not replace CE marking and is not a declaration of conformity, it is not a central database in which the EU collects your product data, and it is not a marketing tool. The data stays with the economic operator; only a manageable set of identifying details is registered centrally.
For batteries the most concrete form of the passport already exists, and there it is called the battery passport. If you want to go straight there: everything about the battery passport.
Why the EU is introducing the passport
Four goals sit behind the passport, and they appear in the recitals of the Ecodesign Regulation. First, supply chain transparency: whoever buys, processes or recycles a product should see the same reliable details. Second, the circular economy: repair, refurbishment and recycling often fail today because nobody knows what is inside a product.
Third, reliable consumer information: statements about durability and repairability should become comparable and verifiable instead of freely worded. And fourth, more efficient market surveillance: authorities should be able to retrieve product data without requesting documents for every suspicion.
For companies the fourth point is the most uncomfortable and at the same time the most honest reason to start early. Anyone who first gathers the data when an authority asks has picked the worst possible moment.
The legal basis: ESPR as the frame, acts per product group
The general frame sits in the Ecodesign Regulation, officially Regulation (EU) 2024/1781, ESPR for short. It establishes that product passports will exist, how they work technically and who may access what. What exactly belongs in the passport is not in the ESPR itself.
Those details are set by delegated acts per product group. Only once such an act exists for your product group are your mandatory fields and your deadline fixed. This is precisely why blanket statements such as "from 2027 every product needs a passport" are wrong.
And one point many overviews leave out: not every product passport comes from the ESPR. The battery passport comes from Battery Regulation (EU) 2023/1542, with its own deadlines and its own data requirements. Anyone placing batteries on the market follows that regulation, not the ESPR.
Which products are covered, and when
In April 2025 the Commission presented its first working plan for the years 2025 to 2030. Priority goes to textiles, furniture, tyres, mattresses, iron and steel as well as aluminium, complemented by horizontal measures. For textiles the delegated act is planned for the fourth quarter of 2027.
The only area with a deadline that is fixed today is batteries. From 18 February 2027 every battery for light means of transport, every industrial battery above 2 kilowatt hours and every electric vehicle battery placed on the EU market needs a battery passport. That is the literal wording of Article 77 of the Battery Regulation and it does not depend on any further act.
In practice this means: anyone manufacturing, importing or selling batteries under their own name has a hard deadline. Anyone making textiles or furniture has time to prepare but no certainty about the details while the respective act is missing.
What belongs in the passport
The data fields differ per product group, but the structure is similar. This is easiest to show with the battery passport because the fields are already fixed there. Annex XIII of the Battery Regulation splits them into details about the model and details about the individual battery.
These include identification and manufacturer, material composition including critical raw materials, carbon footprint details, supply chain due diligence, circularity with recycled content and dismantling information, performance and durability as well as labelling.
Important for planning: not every field has to be filled by the deadline. Under Article 7 of the Battery Regulation the carbon footprint declaration applies from 18 February 2025 or twelve months after the delegated act on the calculation method enters into force, whichever is later. That act has not been adopted to date, so the obligation is not triggered.
Who sees what: the three access levels
A common misconception is that the passport makes everything public. The opposite is true, access is tiered. Article 77(2) of the Battery Regulation assigns exactly which parts of Annex XIII belong to each level.
Publicly accessible are the details under Annex XIII point 1, the part anyone sees via QR code. Notified bodies, market surveillance authorities and the Commission additionally receive the details under points 2 and 3. Anyone demonstrating a legitimate interest, such as a recycling or repair operation, receives the details under points 2 and 4.
For implementation this means your software must serve the same data differently depending on the viewer. Building only a public product page does not meet the requirement.
How the passport works technically
A data carrier sits on the product, usually a QR code, less often NFC or RFID. It points to a unique identifier of the individual product, not of the model. For 10,000 batteries that means 10,000 passports with 10,000 identifiers, and this serialisation is what many projects underestimate.
For identifiers and code structure the GS1 standards have prevailed, in particular the GS1 Digital Link, which turns a classic article number into a resolvable address. The data itself stays with the economic operator or its service provider; only where the passport can be found is stored centrally.
In parallel the European standardisation bodies are working on technical standards, led by the joint committee CEN/CENELEC JTC 24 and accompanied in Germany by DIN and DKE. For batteries the DIN DKE SPEC 99100 describing the data attributes has been available since February 2025; it was created in the PAS procedure and is therefore a specification rather than a standard in the narrow sense.
The EU registry: status today
On 20 July 2026 the European Commission put the central registry for digital product passports into operation, together with a testing environment. Registration is possible both through a web interface and through an interface so companies can embed it in their own systems.
The rules for it are set out in Implementing Regulation (EU) 2026/1778, which has applied since 6 August 2026. What is registered is not the entire passport content but a lean set of identifying details through which authorities can locate the passport.
Registration becomes mandatory with the first deadline, that is 18 February 2027 for the batteries concerned. The time until then is the testing phase, and it is the real reason to start now: anyone sorting their data only in February 2027 is no longer testing but shipping blind.
Digital product passport or battery passport: the difference
The two terms are often used interchangeably, and they are not the same. The digital product passport is the umbrella term for all product groups and comes from the Ecodesign Regulation. The battery passport is the first concrete form and comes from the Battery Regulation.
In practice they differ in three ways. The battery passport has a fixed deadline, 18 February 2027, while other product groups wait for their act. Its mandatory fields are already set out in Annex XIII. And it requires details that do not exist for other products, such as the state of health of a battery in operation.
If you place batteries on the market, the battery passport is your topic, not the general DPP. The details are in the battery passport overview, and the software page is at battery passport software.
The real bottleneck: data quality and supplier data
In projects the passport rarely fails on technology. It fails because the data sits scattered across the company: material details in purchasing, test values in engineering, recycled content at the supplier, and that supplier may not have them either.
Plan months rather than weeks for data collection. The route back through the supply chain is the slowest part, particularly for critical raw materials and for intermediates from third countries.
In parallel, data spaces are emerging for exchange between companies, in the vehicle and battery environment above all Catena-X. These networks solve how data flows between partners, but they do not replace the passport itself and are usually oversized for smaller manufacturers.
What the passport delivers beyond compliance
The passport is first of all an obligation, and nobody should talk that away here. Once the data is clean, however, side effects appear that do pay off.
Service benefits fastest: seeing type, year and composition by scanning saves queries during repair and complaints. In sales the origin details become an argument, especially in tenders with sustainability criteria. And in purchasing the data collection often reveals for the first time which suppliers document reliably and which do not.
One should stay honest about timing: these effects come after the data work, not before it. Anyone starting the passport purely for the side effects underestimates the first step.
What you can prepare now
Regardless of your product group, five steps are worth taking because they are needed in any case and can take months.
- Clarify the legal basis. Battery Regulation with a fixed date or ESPR with a later act: everything else follows from this.
- Assign responsibility. Clarify who in the company carries the role of the economic operator, because that person or company is legally responsible for the passport.
- Collect the data. Material composition, supplier details, technical values. Experience shows supplier data takes longest.
- Settle the identifier. Who assigns serial numbers, are GS1 identifiers already in house, and how does the code get onto the product.
- Create a test passport. Create a passport and scan it yourself. Nothing exposes missing data faster than looking at your own public view.
The last point is the cheapest and the most effective. With DPP Hero you create an account for this and work through the guided data categories without paying anything first.
What a finished passport looks like
A passport consists of three parts that belong together: the public view anyone sees by scanning, the protected areas for authorities and for operations with a legitimate interest, and the entry in the EU registry through which the passport can be found.
In practice this leads to a sober page with data blocks rather than an advertising page. That is exactly how it should be, because the passport is read by people who need something specific: a recycler looks for the composition, an authority for the conformity details, a buyer for the origin.
How to capture, export and publish all this with finished software is shown on the DPP software page; terms can be looked up in the glossary.
Frequently asked questions
What is a digital product passport in one sentence?
A data record for one individual product, retrievable via QR code, that documents origin, composition, repair and disposal across the entire life cycle.
From when is the digital product passport mandatory?
So far there is a fixed date only for batteries: from 18 February 2027 for batteries for light means of transport, industrial batteries above 2 kilowatt hours and electric vehicle batteries. For other product groups such as textiles or furniture the obligation starts with the respective delegated act; for textiles it is planned for the fourth quarter of 2027.
Who has to create and provide the passport?
The economic operator placing the product on the EU market. Depending on the case that is the manufacturer, the importer or whoever sells the product under their own name. The responsibility stays there even when a service provider supplies the software.
Is all data in the passport public?
No. There are three levels: public details, details for notified bodies, market surveillance authorities and the Commission, and details for persons with a legitimate interest such as recycling and repair operations. For the battery passport this is governed by Article 77(2) together with Annex XIII.
Is the EU registry already in operation?
Yes. The Commission put the registry into operation on 20 July 2026 together with a testing environment, and registration is possible through the interface as well as the web front end. Implementing Regulation (EU) 2026/1778 has applied since 6 August 2026. Registration becomes mandatory with the first deadline on 18 February 2027.
What happens if the passport is missing?
Without a valid passport the product may not be placed on the market, which in practice works like a sales ban. The sanctions themselves are set by the member states under Article 93 of the Battery Regulation, so there is no EU-wide uniform fine.
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