Digital Product Passport: what is in it, who needs it, from when
The digital product passport makes product data retrievable across the life cycle. This page explains the legal basis, the product groups affected, the access levels and the state of the EU registry. Every statement with a source.
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. It is retrieved through a data carrier on the product, usually a QR code. Anyone scanning does not land in a brochure. They see details on origin, composition, repair and disposal. The passport travels with the product through its lifetime and is updated when something changes.
Just as important is what it is not. It replaces neither the CE marking nor the declaration of conformity. It is not a central database in which the EU collects your product data. And it is not a marketing instrument. The data stays with the economic operator, only a manageable set of key data 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 stand behind the passport, taken from the recitals of the Ecodesign Regulation. First, transparency in the supply chain. Whoever buys, processes or recycles should see the same data. Second, circularity. Repair and recycling often fail today for lack of knowledge about the contents.
Third, reliable consumer information: durability and repairability should become comparable and verifiable. Fourth, more efficient market surveillance: authorities should be able to retrieve product data without requesting documents on every suspicion.
For companies the fourth point is the most uncomfortable reason to start early. Collecting the data only once an authority asks is 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.
These details are set by delegated acts per product group. Only with the act for your product group are mandatory fields and deadline fixed. That is why blanket claims like “from 2027 all products need a passport” are wrong.
One point many overviews leave out: not every product passport comes from the ESPR. The battery passport comes from Battery Regulation (EU) 2023/1542. It has its own deadlines and its own data requirements. Anyone placing batteries on the market follows that regulation.
Which products are covered, and when
In April 2025 the Commission adopted its first working plan for 2025 to 2030. It names iron and steel for 2026. Aluminium, textiles and tyres follow in 2027. Furniture comes in 2028, mattresses in 2029. Energy-related products and horizontal measures come on top.
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 that means: anyone making, importing or selling batteries under their own name has a hard deadline. Anyone making textiles or furniture has time to prepare. Certainty about the details only comes with the respective delegated act.
What belongs in the passport
The data fields differ per product group, the structure is similar. The battery passport shows it best, because the fields are settled there. Annex XIII of the Battery Regulation splits them into model data and data on the individual battery.
The model data covers identification and manufacturer, the material composition with the critical raw materials and the carbon footprint. Supply chain due diligence follows, then circularity with the recycled content, and finally performance, durability and labeling.
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.
Public are the details under Annex XIII point 1. That is the part anyone sees via QR code. Notified bodies, market surveillance and the Commission additionally receive points 2 and 3. Anyone proving a legitimate interest, a recycler or repair shop for example, gets 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 the model. With 10,000 batteries that means 10,000 passports with 10,000 identifiers. Many projects underestimate exactly this serialization.
For identifiers and code structure the GS1 standards have prevailed. Above all the GS1 Digital Link turns an article number into an address you can call up. The data itself stays with the economic operator or its service provider. Only the location of the passport is held centrally.
The European standardisation bodies have produced eight standards for the product passport. The lead lies with the joint committee CEN/CENELEC JTC 24, whose secretariat is held by DIN. Six of the eight have been cited in the Official Journal of the EU since July 2026. They apply to product passports under the ESPR, not to the battery passport. For batteries, DIN DKE SPEC 99100 has been available since February 2025, produced in the PAS procedure and therefore a specification.
The EU registry: status today
On 20 July 2026 the European Commission put the central registry for digital product passports into operation. A testing environment stands alongside it. You can register through a web interface or through an API. That way the route fits into your own systems.
The rules for it are set out in Implementing Regulation (EU) 2026/1778, which has been in force 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. The general DPP is not. Details are in the battery passport overview, the software under battery passport software.
The real bottleneck: data quality and supplier data
In projects the passport rarely fails on technology. It fails on scattered data: material details in purchasing, test values in development, recycled content at the supplier. And that supplier may not have them either.
Count on months for sourcing the data, not weeks. The way back through the supply chain is the slowest part. It gets particularly tough with critical raw materials and intermediates from third countries.
In parallel, data spaces are emerging for exchange between companies, in the vehicle and battery field above all Catena-X. These networks govern how data flows between partners. They do not replace the passport. For smaller manufacturers they are usually oversized.
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 scan saves queries during repair and complaints. In sales the origin data becomes an argument, especially in tenders with sustainability criteria. In purchasing the data collection shows which suppliers document reliably.
On timing one should stay honest. These effects come after the data work, not before. Starting the passport for the side effects alone underestimates the first step.
What you can prepare now
Five steps are worth taking whatever your product group. 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 delegated act. Everything else follows from that.
- Assign responsibility. Settle who in the company holds the role of economic operator. That person or firm 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 issues the serial numbers? Are there GS1 identifiers in house already? 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 set up an account and work through the guided data categories. You pay nothing for that. How a passport comes out of it step by step is shown in the guide: create a battery passport.
What a finished passport looks like
A passport has three parts. Public is the view anyone sees by scanning. Protected are the areas for authorities and for operators with a legitimate interest. On top comes the entry in the EU registry that makes the passport findable.
In practice this creates a plain page of data blocks, not an advertisement. That is how it should be. The passport is read by people looking for something specific: a recycler wants the composition, an authority the conformity data, a buyer the origin.
How to capture 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. It 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; the Commission working plan names 2027 for textiles and 2028 for furniture.
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 it under their own name. The responsibility stays there, even if 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 been in force 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. In practice that works like a sales ban. The sanctions are set by the member states under Article 93 of the Battery Regulation. So there is no EU-wide uniform level of fines.
Create your first product passport
Create an account, capture the data, publish the passport. Getting started is free.