A digital product passport (DPP) is a structured set of product-specific data, linked to a unique identifier and reached through a data carrier such as a QR code. ESPR (EU) 2024/1781 sets the general framework, the EU DPP registry went live on 20 July 2026 and the first mandatory passports are battery passports from 18 February 2027. Toys follow from 1 August 2030 and ESPR product groups follow their delegated acts.
A digital product passport (DPP) is a structured set of product-specific data, linked to a unique product identifier and reached through a data carrier such as a QR code on the product, its packaging or its documentation. The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) sets the general EU framework, and the first mandatory passports are battery passports from 18 February 2027.
What is a digital product passport?
A DPP gives customers, repairers, recyclers and authorities access to defined information about a specific product. Its content is set by the legal act for the product group, and it typically covers identity, composition, substances of concern, environmental performance, compliance documents, and instructions for use, repair and end of life.
Four elements define every passport under ESPR:
- Unique product identifier at model, batch or item level, as set by the delegated act.
- Data carrier, such as a QR code, NFC tag or RFID, physically linked to the product.
- Passport data, hosted by the economic operator or a DPP service provider, with a back-up copy held by a third-party DPP service provider.
- Access rights, separating public information from data reserved for authorities, recyclers or other actors.
Which EU laws require a digital product passport?
Several EU laws now require or enable passports, each with its own scope and timing.
| Legal act | Products | Passport status as of October 2026 |
|---|---|---|
| Batteries Regulation (EU) 2023/1542, Article 77 | LMT batteries, industrial batteries above 2 kWh, electric vehicle batteries | Mandatory from 18 February 2027 |
| ESPR (EU) 2024/1781 | Product groups covered by delegated acts | No product-group delegated act adopted; iron and steel targeted for Q4 2026 |
| Toy Safety Regulation (EU) 2025/2509 | All toys | Applies from 1 August 2030; DPP replaces the separate declaration of conformity |
| Construction Products Regulation (EU) 2024/3110 | Construction products, via delegated acts | Framework in force, details pending |
The ESPR working plan of 16 April 2025 lists iron and steel, textiles (starting with apparel), tyres, aluminium, furniture and mattresses as the first product groups. A transition of generally at least 18 months applies after each delegated act. Details are covered in ESPR ecodesign regulation.
What infrastructure is already in place?
The legal and technical foundation for passports was largely completed in July 2026:
- DPP registry: the Commission launched the registry on 20 July 2026, meeting the ESPR Article 13 deadline of 19 July 2026. Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026, in force since 6 August 2026, sets the registration and access arrangements. The registry stores identifiers and passport locations, not the passport content.
- Harmonised standards: six CEN and CENELEC standards (EN 18216 and EN 18219 to EN 18223) on data exchange, unique identifiers, data carriers, storage, APIs and interoperability were cited in the Official Journal in July 2026. Two standards on access rights and user verification were still drafts.
- Customs link: products subject to a passport must be registered so that customs can verify the identifier at import.
No business had to register products on 20 July 2026. Registration obligations arise when a delegated act or the Batteries Regulation makes a passport mandatory.
What does a DPP mean for PIM and product data teams?
A passport is a regulated output that draws on several systems. PLM and compliance tools usually provide composition, substances and test evidence, ERP provides batch and serial data, LCA tools provide footprint values, and PIM provides identity, classification, multilingual texts and links to assets. The design of this flow is described in DPP data architecture, and the engineering side in PLM and ecodesign data.
Data owners should expect three changes:
- Granularity: some passports require batch or item-level data, which most PIM models do not hold today.
- Persistence: passports must stay available for the period set in the legal act, including after a product is discontinued or the operator ceases trading.
- Accountability: published values become regulatory statements, so approval workflows and evidence links are required.
Practical next steps
- Identify which products fall under the Batteries Regulation, the Toy Safety Regulation or an ESPR working plan group.
- Agree identifier rules at model, batch and item level, ideally aligned with GS1 identifiers described in GS1 GDSN explained.
- Map passport content requirements to source systems and assign one owner per attribute.
- Assess whether to build passport hosting or use a DPP service provider, and test the registry environment.
PIM and PXM platforms with published DPP capabilities are profiled in the vendor directory.
Frequently asked questions
When does the digital product passport become mandatory?
The first mandatory passports are battery passports from 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. ESPR passports follow product-group delegated acts, and toys need a DPP from 1 August 2030.
Does the EU host the passport data?
No. The economic operator, or a DPP service provider on its behalf, hosts the passport. The EU registry holds the unique identifiers and links needed to find and verify passports.
Is a DPP the same as a PIM?
No. A PIM is a system that manages product data, while a DPP is a regulated output with defined content, access rights and retention. A PIM can be one of the sources that feeds a passport.
Sources
- Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation), EUR-Lex
- Commission Implementing Regulation (EU) 2026/1778 on the digital product passport registry, EUR-Lex
- Regulation (EU) 2023/1542 concerning batteries and waste batteries, EUR-Lex
- European Commission: Digital Product Passport for iron and steel