A Digital Product Passport (DPP) is a digital record of a product’s composition, sustainability, repair and compliance information. People open it through a carrier such as a QR code. The EU is making it mandatory product group by product group, starting with batteries in February 2027. Most of the work is product data you already hold, collected from suppliers and governed in one place.
What is a Digital Product Passport?
The DPP is the information backbone of the EU’s Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. The ESPR entered into force on 18 July 2024. It lets the Commission set ecodesign rules for almost any physical product, one product group at a time. Where those rules call for a passport, Article 9 is blunt. The product can only be placed on the market or put into service if a digital product passport is available.
The point is to move product information out of PDFs and paper inserts and into structured data that travels with the product. The European Commission describes the DPP as a digital container for products, components and materials. Depending on the product group, it holds information on safety, origin, materials, repairability, environmental performance, reuse and recycling. The EU-funded CIRPASS project defines it as a structured collection of product data with a predefined scope and agreed rules for access.
Four mechanics matter if you are the one holding the data.
- A carrier and an identifier. Each passport connects through a data carrier to a persistent unique product identifier. The carrier sits on the product, its packaging or the documents that come with it. For batteries, it is a QR code.
- Model, batch or item level. The rules for each product group decide whether one passport covers a whole model, a production batch or every individual item.
- Different views for different people. Customers, repairers, recyclers, market surveillance authorities and customs all get access. Each sees only what their access rights allow.
- Stored by you, registered centrally. The economic operator that creates the passport stores it, either in its own systems or through a DPP service provider. A back-up copy must also be held by a DPP service provider.
The ESPR required the Commission to set up a digital registry by 19 July 2026, and it now exists. Commission Implementing Regulation (EU) 2026/1778, adopted on 16 July 2026, sets out how it works. The Commission lists the registry as operational from 20 July 2026. According to the Commission’s DPP registry page, it stores unique identifiers, registration data and high-level metadata. It does not hold the passport content itself. Customs authorities use it to check that imported products have a valid registered passport.
When does the Digital Product Passport become mandatory?
There is no single DPP deadline. Each product group gets its own date, set by its own legal act. Batteries come first because the Batteries Regulation wrote the passport directly into law. ESPR product groups follow as the Commission adopts delegated acts. Under Article 4 of the ESPR, a delegated act cannot apply earlier than 18 months after it enters into force, except in duly justified cases.
The table below draws on EUR-Lex and the Commission’s DPP timeline, checked in October 2026. Dates marked indicative are the Commission’s planning dates, not legal deadlines, and they can move.
| Date | What happens | Status |
| 18 July 2024 | ESPR, Regulation (EU) 2024/1781, enters into force. | In force |
| 16 April 2025 | First ESPR and Energy Labelling Working Plan (2025 to 2030) adopted. | Done |
| 16 July 2026 | Implementing Regulation (EU) 2026/1778 sets the rules for the DPP registry. | Adopted |
| 20 July 2026 | EU DPP registry operational. | Live, enrolment open |
| November 2026 | Decision on the last two harmonised DPP standards. | Indicative |
| Q4 2026 | Iron and steel delegated act; implementing act on battery passport access rights. | Indicative |
| 18 February 2027 | Battery passport mandatory for electric vehicle, light means of transport and industrial batteries over 2 kWh. | Set in law |
| Q2 to Q3 2027 | Delegated acts for DPP service providers and for construction products under the Construction Products Regulation. | Indicative |
| Q3 to Q4 2027 | Delegated acts for textiles, aluminium and tyres. | Indicative |
| 2028 | Delegated act for furniture. | Indicative |
| 2029 | Delegated acts for mattresses and for recycled content. | Indicative |
Batteries: Regulation (EU) 2023/1542
The Batteries Regulation creates the battery passport in Article 77. It covers electric vehicle batteries and industrial batteries with a capacity above 2 kWh. It also covers light means of transport (LMT) batteries, such as those in e-bikes and e-scooters. The Commission’s battery passport guidance confirms it becomes mandatory for those batteries placed on the EU market from 18 February 2027. A QR code on the battery gives access to it.
Responsibility sits with the economic operator placing the finished battery on the EU market. It does not pass down to the suppliers of cells or modules. When a product arrives from outside the EU with a battery already fitted, the Commission’s battery passport FAQ says responsibility lies with the importer. Part of each passport is public. Another part is restricted to notified bodies, market surveillance authorities and the Commission. A further implementing act will define who else has a legitimate interest in the rest.
The data load is heavy. The Commission’s battery data point guidance lists 71 data points, from chemistry and capacity to state of health and charge cycles. Some arrive later than others. The FAQ confirms that carbon footprint, recycled content and due diligence information are not yet required in February 2027. The due diligence report follows from August 2027. A repurposed or remanufactured battery needs a new passport, linked to the previous one.
ESPR product groups: the working plan
The first ESPR and Energy Labelling Working Plan 2025 to 2030, adopted on 16 April 2025, sets the queue. It prioritises steel and aluminium, textiles (apparel in particular), furniture, tyres and mattresses. It also brings horizontal measures, including a repairability score and recyclability requirements for electrical and electronic equipment. The Commission’s DPP page adds energy-related products between 2026 and 2029, and ICT products in 2029.
Each delegated act sets the passport rules for its product group. Under Article 9 of the ESPR, that means the data to include and the carriers to use. It also fixes whether passports sit at model, batch or item level, who can see which data, and how long the passport must stay available. That period must cover at least the product’s expected lifetime. Once an act is adopted, you normally get at least 18 months before it applies. That sounds generous until you count the supplier data requests involved.
Batteries and the ESPR are not the only routes in. The Commission’s DPP page lists five other laws with product-specific requirements of their own. They are the Toy Safety Regulation, the Construction Products Regulation and the Packaging and Packaging Waste Regulation. The Critical Raw Materials Act and the Detergents and Surfactants Regulation complete the list.
Does the DPP apply to UK businesses?
Yes, for every product placed on the EU market. The passport follows the product, not the seller’s address. A UK manufacturer, brand or distributor selling batteries, textiles or furniture into the EU faces the same requirements as an EU competitor. That applies as soon as its product group is in scope.
Who holds the legal obligation depends on your role in the chain. The data, though, has to come from you either way. Where an EU importer or distributor places your product on the market, they carry the duty and will ask you for the data. For batteries, the Commission’s FAQ says non-EU operators can open a registry account once verified. Registration itself must be done by the operator placing the battery on the EU market.
Northern Ireland is a special case. The UK government’s own call for evidence on digital product record policy says so directly. The EU’s Digital Product Passport will apply in Northern Ireland under the Windsor Framework. If you sell into Northern Ireland, plan for EU passport rules on those products.
Great Britain has no passport requirement yet. That call for evidence ran from 27 July to 21 September 2026. It asked how digital product records could improve the sharing of product information across supply chains. It also asked how they could reduce regulatory burden, support market surveillance and affect businesses selling into the EU and Northern Ireland. The call is now closed, and the gov.uk page showed no government response when we checked in October 2026.
Our advice to UK businesses is simple. Build your passport data to the EU specification, because that is the requirement you can already read. Great Britain may follow with its own digital product records. If it does, a governed data set built for the EU will be far easier to adapt than starting again.
What data does a Digital Product Passport need?
The exact fields are set product group by product group, so there is no universal DPP template. Across the Batteries Regulation, the ESPR and the Commission’s sector guidance, the same families of data keep appearing.
- Unique identifiers. A persistent unique product identifier at model, batch or item level, plus identifiers for the operators and facilities involved.
- Materials and composition. For batteries, this goes down to the composition of the cathode, anode and electrolyte.
- Substances of concern. The ESPR requires enough detail to track them through the life cycle. That means the substance name, its location in the product, its concentration, safe-use instructions and end-of-life handling.
- Environmental footprint. Carbon footprint, recycled content and similar measures, where the product group’s rules ask for them.
- Repair and end-of-life information. Spare parts, dismantling information, safety measures and recycling instructions.
- Compliance documents. The EU declaration of conformity, test reports and instructions for use all appear in the battery data points.
- Economic operator details. Who made the product and who is responsible for it on the EU market.
Batteries add a category most product teams have never managed: data that changes after sale. State of health, charge cycles and negative events such as accidents sit in the battery passport alongside the static specification.
If this list looks familiar, it should. Most of it is product attributes and documents you already hold somewhere. The passport changes how complete, structured and current they must be, and who can check them.
Why the data is the hard part
The passport technology is the easier half. Carriers, identifiers and registries are being standardised at EU level. The Commission’s timeline shows six harmonised DPP standards in its July 2026 decision, with the last two due in November 2026. The data is where DPP projects stall, for four reasons that compound.
It is scattered. Composition sits in PLM or engineering files. Weights, origins and commodity codes sit in the ERP. Test reports and declarations of conformity sit in PDFs on a shared drive. Marketing content sits in the PIM. No single system holds the passport today.
Much of it belongs to suppliers. Brands and distributors rarely know the substance content of a component they buy in. That information sits two or three tiers back in the supply chain. Getting it means structured requests, chasing and validation. On the supplier projects we run, that takes months, not weeks.
It must stay current. Article 9 of the ESPR requires passport data to be correct, complete and up to date. The passport must stay available for at least the product’s expected lifetime. A one-off data collection exercise will not survive the first change of supplier or specification.
The granularity may not match your systems. Most PIMs model products at SKU or model level. Batch and item-level passports need batch and serial data from manufacturing and logistics systems. Decide early which system owns which level, and how they join up.
This is why we treat the DPP as a product data problem first and a technology problem second. The PIM is the governed source. The passport is another channel it feeds, alongside your website, marketplaces and print.
How to prepare: a staged plan
You do not need to wait for your product group’s delegated act. The data families are clear enough to start now. This is the sequence we use.
1. List the affected SKUs. Map your range against the battery categories and the working plan’s product groups. Include products that contain an in-scope battery, such as e-bikes. Flag which ones you sell into the EU or Northern Ireland. For most businesses the in-scope list is far shorter than the full catalogue, and it sets the size of the job.
2. Run a gap assessment. Compare what you hold for each in-scope SKU with what the rules ask for. Our DPP readiness assessment tool gives you a structured starting point. Score each attribute as held and governed, held but scattered, or missing. The missing column becomes your supplier request list.
3. Send supplier data requests early. Your suppliers will get the same questions from every customer. The businesses that ask first, with a clear template, defined fields and units, get answers first. Build the request into your supplier onboarding process, so new products arrive passport-ready instead of needing a retrofit. If you need extra hands, our supplier data onboarding service runs the collection and validation for you.
4. Extend the PIM data model. Add the passport attributes, with data types, units and value lists. Add document assets for declarations and test reports. Add the identifiers and the granularity rules. Then set completeness rules, so a product with gaps cannot be published to the passport channel. If your current PIM cannot carry this, look at PIM implementation before the deadline, because a passport built from spreadsheets will not stay current.
5. Choose the carrier and connect to the registry. Decide who hosts the passport: your own systems or a DPP service provider. Agree the identifier scheme and how the QR code resolves. Enrol in the EU registry and use its test environment before your first in-scope product ships. Do this last, because it depends on everything before it.
For battery businesses, the end of step five has a fixed date: 18 February 2027. For everyone else, the clock starts when your product group’s delegated act is adopted. Our Digital Product Passport services cover each of these stages, from scoping the affected range to keeping passport data current after launch.
Frequently asked questions
A digital record for a product, batch or item, opened through a QR code or similar carrier. It holds information on materials, sustainability, repair, recycling and compliance, with different parts visible to different users.
It is phased in by product group. Batteries come first, from 18 February 2027, for electric vehicle, light means of transport and industrial batteries over 2 kWh. Other groups follow as the EU adopts delegated acts under the ESPR, normally with at least 18 months before each one applies.
It applies to products placed on the EU market, so UK manufacturers, brands and distributors selling into the EU need to comply. It also applies in Northern Ireland under the Windsor Framework. The UK government ran a separate call for evidence on digital product records, which closed on 21 September 2026.
Typically a unique product identifier, materials and composition, substances of concern and environmental footprint. Add repair and end-of-life instructions, compliance documents and details of the responsible economic operator. The exact fields are set for each product group.
You need one governed place where passport data is collected, checked and kept current. For most businesses with large catalogues, that is a PIM, fed by supplier data and connected to the passport carrier.
The economic operator placing the product on the EU market. For batteries fitted in an imported product, that is normally the importer. Much of the data comes from suppliers, so supplier data requests need to start early.
Start with a free Product Data Performance Snapshot, which shows where your catalogue data is holding back compliance, discovery and launches. We score 50 of your SKUs and send the results within five working days. Request your free Snapshot, or see how our Digital Product Passport support works.