Short answerThe EU Digital Product Passport (DPP) is a structured, machine-readable record of a product's sustainability, composition and compliance data, reached by scanning a data carrier such as a QR code. ESPR delegated acts define its content per product group. Batteries go first in February 2027, followed by textiles, steel and other priority groups.
Key takeaways
- The DPP legal basis is the Ecodesign for Sustainable Products Regulation (EU) 2024/1781, in force since 18 July 2024.
- Access is tiered: consumers see public data, while authorities, recyclers and repairers receive additional fields based on a legitimate interest.
- The battery passport becomes mandatory on 18 February 2027 and acts as the first large-scale DPP in the EU.
A passport is a data obligation per product group
The Digital Product Passport turns product information into a regulated deliverable. The Ecodesign for Sustainable Products Regulation (ESPR) sets the general framework, and each delegated act decides which data a product group must carry, at which granularity and from which date. A detailed view of that framework sits in the ESPR guide.
The practical consequence is that no single DPP template exists. A sofa, a T-shirt and a steel beam will each receive their own attribute list. Companies that model the passport as a fixed form will rebuild it for every new act, while companies that model it as a configurable set of attributes on top of governed master data can reuse most of the plumbing.
The passport holds sustainability, composition and compliance data
Delegated acts draw from a common menu of information requirements. Typical content includes:
- Identification: unique product identifier, model, batch or serial number, manufacturer and importer details, facility identifiers.
- Composition: materials, recycled content, substances of concern and their location in the product.
- Performance: durability, reparability score, energy use, expected lifetime.
- Environmental footprint: carbon or environmental footprint where the act requires it.
- Circularity: disassembly instructions, spare part availability, end-of-life and sorting guidance.
- Compliance: declarations of conformity, technical documentation references, user manuals and safety information.
Most of these attributes already exist somewhere in the organisation, spread across PLM, ERP, supplier portals and spreadsheets. The hard work lies in proving them at the required granularity.
Access rights follow the reader's role
The DPP separates audiences, and each one sees a different slice of the record.
| Reader | Typical access | Purpose |
|---|---|---|
| Consumers | Public fields | Purchase decisions, care, repair |
| Market surveillance and customs | Public plus restricted fields | Enforcement and border checks |
| Repairers and refurbishers | Public plus technical fields | Repair, spare parts, second life |
| Recyclers and waste operators | Public plus composition fields | Sorting, dismantling, material recovery |
| Commission and notified bodies | Fields defined by the act | Oversight and conformity |
The economic operator placing the product on the market remains responsible for the accuracy and availability of all fields, including restricted ones. Data must stay accessible for the period set in the delegated act, which can exceed the commercial life of the product.
Data carriers and unique identifiers make the passport reachable
Every passport is reached through a data carrier physically placed on the product, its packaging or accompanying documents. QR codes are the most likely default, with RFID and NFC possible where a delegated act allows them. The carrier resolves to a unique product identifier that complies with recognised standards such as ISO/IEC 15459.
Granularity is a decision with large cost effects. A model-level passport needs one record per product type, a batch-level passport one record per production lot, and an item-level passport one record per unit. Each step down multiplies data volume and forces serialisation into production and packaging lines. The technical side of identifiers and resolvers is covered in the DPP data architecture article.
The Commission also operates a central DPP registry, which went live in July 2026 to meet the 19 July 2026 deadline in ESPR and stores identifiers and links. Implementing Regulation (EU) 2026/1778 sets its operating rules, and the first mandatory registrations start with batteries in February 2027. The passport data itself stays decentralised with the economic operator or a DPP service provider.
The rollout runs sector by sector from 2027
Batteries come first. The battery passport under Regulation (EU) 2023/1542 applies from 18 February 2027 to EV, light means of transport and industrial batteries above 2 kWh. The ESPR working plan adopted in April 2025 then prioritises iron and steel, aluminium, textiles, furniture, tyres and mattresses, alongside energy-related products and horizontal rules on reparability and electronics recyclability.
Delegated acts generally leave a transition period, typically around 18 months, between adoption and application. Iron and steel is first in line, with adoption indicated for late 2026, and textiles follow with an act indicated for 2027, so application dates are likely from 2028 onwards. As of October 2026 no product-specific ESPR delegated act had been adopted. Dates remain subject to the final acts, so planning should anchor on adoption milestones.
Treat the DPP as a master data programme
The central insight is that the DPP rewards companies with governed product data and penalises those relying on manual collation. The passport is an output channel, comparable to a retailer feed or a GDSN message, and its quality depends entirely on upstream ownership. Organisations that assign attribute ownership across PLM, PIM and ERP now, and start supplier data collection early, will treat each new delegated act as a configuration task. A phased plan is outlined in the DPP readiness roadmap, and platform options are listed under PIM and PXM suites.
Frequently asked questions
Is the Digital Product Passport mandatory for all products?
No. The DPP becomes mandatory only for product groups covered by an ESPR delegated act or by sector law such as the Batteries Regulation. Food, feed, medicinal products and living organisms fall outside ESPR scope. Each act states its own application date and data requirements.
Who is responsible for creating the passport?
The economic operator placing the product on the EU market, usually the manufacturer or importer, is responsible. It may use a DPP service provider to host and serve the data, but legal responsibility for accuracy, completeness and continued availability stays with the operator.
Does the DPP have to be stored in an EU database?
No. The passport data stays decentralised, hosted by the operator or a DPP service provider. The EU registry stores the unique identifiers and the link to the data, which lets customs and market surveillance authorities verify that a passport exists for a product.