The product’s own information, structured and always available to those entitled to see it.
A digital product passport (DPP) is a set of data about one specific product, stored digitally and linked to the product through a data carrier – in practice a QR code on the product, the packaging or the documentation. Whoever scans it sees what they are entitled to see: consumers see how to use it, what it is made of and where it can be handed in, repairers see spare parts and disassembly, recyclers see substances and composition, and authorities see the conformity documentation.
The idea is simple. Today, information about a product disappears when it leaves the factory: the instructions get lost, the supply chain is unknown, and whoever has to repair or recycle the product does not know what it is made of. The passport makes the information follow the product throughout its life, and lets the EU set requirements for durability, repairability and recycled content that can actually be verified.
What it contains
Identity (manufacturer, model, batch or serial number), materials and substances, origin and supply chain, durability and repair, environmental data such as the carbon footprint, conformity documentation and information on collection and recycling. Which fields are mandatory is decided per product group.
Who sees what
The passport has access levels. Some data is public to anyone who scans, some is for repairers and recyclers, some is only for market surveillance and customs authorities, and some is for the owner of the product. The manufacturer controls what is shown to whom, within what the legislation requires.
Where it lives
The data is held by the manufacturer or by a service provider the manufacturer chooses, not in a central EU database. The EU has a registry that holds the identifier and a few key fields, and a backup copy must be kept by an independent third party so that the passport outlives the manufacturer.
The legislation decides how granular the passport must be. Batteries get one passport per item, steel per batch, toys per model.
Normally a GTIN with a batch or serial number, encoded in the QR code as a GS1 Digital Link. The same code throughout the lifetime.
The passport must remain available for as long as the product exists, and for a set period afterwards. For some groups that means decades.
The manufacturer, or the importer for goods from outside the EU. The operation itself can be outsourced to a service provider.
The ESPR is the law that gives the EU the tools. The product passport is the most important of them.
ESPR stands for the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781. It entered into force on 18 July 2024 and replaces the old Ecodesign Directive from 2009, which only covered energy-related products such as refrigerators and light bulbs.
The new regulation covers almost all physical goods sold in the EU, and empowers the Commission to set requirements for durability, repairability, recycled content, energy use, chemicals and carbon footprint, group by group. The product passport is the mechanism that makes the requirements visible and verifiable.
The ESPR is a framework regulation. It does not itself say what a textile passport or a steel passport must contain. The Commission does that in separate delegated acts per product group, in the order set out in the 2025–2030 working plan. That is why there are so many different dates.
- Who it applies to · everyone who places products on the EU market, including manufacturers based outside the EU. Exceptions: food, feed, medicinal products, living organisms and vehicles, which have their own rules.
- Delegated acts · the Commission’s product rules. Each one sets out which requirements apply, what the passport must contain, and from when – normally at least 18 months after adoption.
- The 2025–2030 working plan · adopted in April 2025. Prioritises steel, aluminium, textiles, tyres, furniture and mattresses, plus horizontal requirements on repairability and recycled content in electronics.
- Ban on destroying unsold goods · the ESPR also bans the destruction of unsold apparel and footwear, from July 2026 for large companies and from 2030 for medium-sized ones. It is the same law, not a different one.
- Outside the ESPR · batteries, construction products, toys and detergents have passports under their own regulations. They follow the same technical standards and the same registry, but have their own dates.
The terms you will come across, explained.
The legislation has its own language. Here are the terms that come up most often, in the meaning they have in the ESPR and the standards.
- DPP Digital product passport
- Structured information about one product, linked to a unique identifier and accessible through a data carrier, with access control per recipient. The requirements are set out in Articles 9–14 of the ESPR.
- ESPR Regulation (EU) 2024/1781
- The Ecodesign for Sustainable Products Regulation. The framework law that empowers the Commission to set product requirements and introduce product passports, group by group.
- Delegated act
- The Commission’s product rules under the ESPR, for example for textiles or steel. Sets the requirements, passport content, access rights and date of application. The European Parliament and the Council can object to it, but cannot amend it.
- Implementing act
- A technical rule that sets out how a regulation is to be applied, without changing its substance, for example the rules for the EU registry. Also used for the data carrier and format under the Batteries and Detergents Regulations.
- Working plan ESPR Working Plan 2025–2030
- The Commission’s plan for which product groups get rules and when. The years are planned adoptions of delegated acts, not dates by which a company must be ready.
- Data carrier
- The physical mark that opens the passport: QR code, Data Matrix, RFID or NFC. It must be on the product, the packaging or the documentation, and comply with ISO/IEC 15459.
- UPI Unique product identifier
- The string that points to exactly one passport, at model, batch or item level. In practice usually a GTIN with a batch or serial number.
- GTIN and GS1 Digital Link
- The GTIN is the product number behind the barcode (EAN). GS1 Digital Link is the standard that packs the GTIN, batch and serial number into a web address in the QR code, so the same code works at the checkout and as the entry point to the passport.
- EU DPP registry The EU registry
- The Commission’s central registry of all product passports. Holds the identifier and a few key fields, not the whole passport. Registration takes place before the product is placed on the market, with a qualified electronic seal. Opened in July 2026.
- DPP service provider
- A company that stores and operates passports on behalf of manufacturers. Under the ESPR, they must meet requirements for security and long-term viability, set out in a separate act announced for 2026–2027. Origo is one such provider.
- Backup copy ESPR Art. 10(4)
- An independent third party must hold a copy of the passport, so that it survives the manufacturer going bankrupt or changing provider. The registry checks that the copy exists.
- Access rights
- Who gets to see which fields: the public, repairers, recyclers, market surveillance authorities, customs authorities, the owner. Set by the legislation per product group, and enforced technically by the passport.
- Harmonised standards EN 18216, 18219–18223 and others
- Technical standards from CEN/CENELEC that specify how identifiers, data carriers, data exchange, storage and access are to be handled. A passport that follows them benefits from a presumption of conformity with the legal requirements.
- Semantic repository
- The EU’s machine-readable dictionary of what each data field in a passport means. The registry checks the passport against it at registration. The battery repository comes first, announced for Q4 2026.
- Economic operator
- Collective term that covers the manufacturer, importer, distributor and authorised representative, among others. Whoever places the product on the market is responsible for the passport.
- Market surveillance authorities
- National authorities that check that products meet the requirements. Each country designates its own authorities, often per product group. They get their own access to the passport.
- Battery passport
- The first mandatory passport, from 18 February 2027, based on the Batteries Regulation and not on the ESPR. One passport per battery, with data that is updated throughout its life, such as the state of health.
- Repairability score
- A rating of how easy a product is to repair, planned as a horizontal requirement under the ESPR from 2027. Mobile phones and tablets already have such a score on the energy label.
- EPREL
- The EU database for the energy labelling of products such as refrigerators and washing machines. Where EPREL already covers the need, it is uncertain whether the product group will get its own passport.
- EEA relevance Text with EEA relevance
- Means that an EU act is to be incorporated into the EEA Agreement and will then also apply in Norway, Iceland and Liechtenstein. The ESPR and the Batteries Regulation are marked as EEA-relevant, but as of October 2026 neither has been incorporated yet.
A year in the EU’s plan is not a deadline.
Most of what is written about DPP mixes up three different points in time. Only once you know which of them a year refers to can you plan around it.
The framework is adopted
The Ecodesign Regulation (ESPR) entered into force in July 2024. It says that there will be product passports, but not for which products or with what content.
Batteries, construction products, toys and detergents have their own regulations with their own passport requirements.
The product rules are adopted
For each product group, the Commission adopts a delegated act: which data fields, who gets to see what, and which data carrier. These are the years in the ESPR working plan 2025–2030.
The obligation applies
The product rules normally give industry 18 months or more before passports become mandatory for products placed on the market. This is the date that decides when you must be ready.
The Commission itself stresses that the years in the working plan are planned adoption dates for the product rules, not the date by which a company must have its passport ready. One exception: the Batteries Regulation sets the obligation directly in the legal text.
Batteries first. Everything else is 2028 or later.
Status as of 3 October 2026. Filled markers are obligations set out in adopted law. Open markers are the Commission’s planned adoptions of product rules, where the obligation comes later.
Passports with a date in the law
Adopted| Product group | Legislation | Status | Obligation applies | What it means |
|---|---|---|---|---|
| Battery passportLMT, EV and industrial batteries above 2 kWh | Batteries Regulation (EU) 2023/1542, Art. 77–78 | Adopted | 18 February 2027 | The first mandatory product passport in the EU. One passport per battery, with data updated throughout its life and registration in the EU registry. The date has not been postponed; only the due diligence obligations were moved to August 2027. The act on access and technical format is delayed and announced for the end of 2026. |
| Battery QR codeAll batteries | Batteries Regulation (EU) 2023/1542, Art. 13(6) | Adopted | 18 February 2027 | All batteries must carry a QR code giving access to information on the manufacturer, chemistry, capacity, separate collection and the EU declaration of conformity. Not a passport, but the same data carrier and the same deadline. |
| DetergentsDetergents, cleaning products and surfactants | Detergents Regulation (EU) 2026/405, Art. 17–21 | Adopted | 23 September 2029 | The content is set out in the law. The data carrier and access will come in an implementing act. Products placed on the market in the first year have a transition period until September 2030. The regulation also allows a digital label instead of a printed one. |
| Environmental Vehicle PassportCars and vans, Euro 7 | Euro 7 Regulation (EU) 2024/1257 | Adopted | 29 November 2026 new types · all new cars 29.11.2027 |
An Environmental Vehicle Passport with emissions, fuel and electricity consumption and battery durability. A separate regime outside ESPR, but the same idea: digital product information that follows the individual vehicle. |
| Toys | Toy Safety Regulation (EU) 2025/2509, Art. 19–21 | Adopted | 1 August 2030 | The passport replaces the EU declaration of conformity and must be registered in the EU registry before the toy is placed on the market. The data carrier and access will come in a delegated act. |
| Construction products | Construction Products Regulation (EU) 2024/3110, Art. 75–80 | Framework adopted | 2028–2029 at the earliest | A separate passport system for construction products, which must be compatible with the ESPR passport. The Commission lists a delegated act in Q2 2027 as an indicative date, and manufacturers get 18 months after each act. Rolled out product family by product family under the CPR working plan 2026–2029, with cement and binders among the first. The declaration of performance and conformity will be the core of the passport. |
The ESPR working plan 2025–2030
Planned adoption of product rules| Product group | Legislation | Status | Product rules · obligation | What it means |
|---|---|---|---|---|
| Iron and steel | ESPR (EU) 2024/1781, delegated act | In preparation | Q4 2026 obligation around 2028 |
The first ESPR group. Public consultation closed in August 2026; the draft act has not been published. The EU’s Joint Research Centre (JRC) has proposed the content: heat number, production route, emissions and recycled content at batch level. |
| Tyres | ESPR, delegated act | In preparation | 2027 obligation around 2029 |
Preparatory study under way. It builds on today’s tyre label and the Euro 7 requirements on tyre abrasion. RFID is being considered as the primary data carrier. |
| Aluminium | ESPR, delegated act | Planned | Q3–Q4 2027 obligation around 2029 |
Included in the working plan. No dedicated preparatory study published yet. Expected to follow the steel model. |
| Textiles and apparel | ESPR, delegated act | In preparation | Q4 2027 obligation around 2029 |
The JRC has published a proposal for the content: fibre composition, supply chain, durability, repair and chemicals. Some secondary sources say 2026; the Commission’s own overview says Q4 2027. |
| Furniture | ESPR, delegated act | Planned | 2028 obligation around 2030 |
Explicitly prioritised in the working plan. A preparatory study on passport content was presented in September 2026. |
| Mattresses | ESPR, delegated act | Planned | 2029 obligation around 2031 |
Included in the working plan. No study published. |
| ICT and electronics | ESPR, delegated act per product group | Planned | 2029–2030 | The Commission’s overview lists ICT in 2029, but in the working plan it is primarily a horizontal requirement on recycled content and recyclability in electronics. Mobile phones and tablets are announced towards the end of 2030. Passports have not been decided for all of them. |
| Energy-related productsHousehold appliances, displays, motors and more | ESPR, delegated act per product group | Planned | 2026–2030 | Around 16 groups are being carried over to the ESPR: dishwashers 2026, chargers, refrigerators and motors 2028. A passport is not a given as long as the EU database EPREL covers the need. |
| Horizontal requirementsApply across product groups | ESPR, delegated acts | In preparation | 2027 · 2029 | Repairability score in 2027 and requirements for recycled content in electronics in 2029. These will probably require the score and material data to be shown in the passport where the product has one. |
Information that goes into the passport
Separate legislation, same data carrier| What | Legislation | Status | Obligation applies | What it means |
|---|---|---|---|---|
| Permanent magnetsMotors, heat pumps, household appliances, vehicles and more | Critical Raw Materials Act (EU) 2024/1252, Art. 28–29 | Adopted | 24 May 2027 or two years after the act in practice 2028 or later |
Products containing permanent magnets must have a data carrier with information on the magnet type, weight, location and how to remove the magnets. If the product already has a passport, the information must be in the passport. The delegated act is delayed and an amendment to the regulation is under negotiation, so the deadline is slipping. |
| PackagingSorting, reuse, substances | Packaging and Packaging Waste Regulation, PPWR (EU) 2025/40, Art. 12 | Adopted | 12 August 2028 reuse 12 February 2029 |
Harmonised material labelling, and a QR code for reusable packaging and certain other cases. Not a passport, but where the product already has a data carrier, the same carrier must provide both product and packaging information. The deadline is 12 August 2028 or 24 months after the implementing acts, which were due to be adopted in August 2026, so the date is slipping. |
“Obligation around” for the ESPR groups is our estimate: the Commission’s planned year of adoption plus the transition period of at least 18 months that the ESPR assumes. The dates only become binding once each delegated act has been adopted and published.
The registry and the standards are in place before the product rules.
The passport itself is only half of it. At the same time, the EU is building a central registry, a common portal and a set of harmonised standards that all passports must follow. This is what allows a passport issued in one country to be read and checked across the entire EU and EEA.
What remains in 2026 and 2027 are the rules for the service providers that will operate passports on behalf of manufacturers, and the semantic repositories the registry checks passports against.
- EU DPP registry · opened on 20 July 2026, within the deadline set by the ESPR, under Implementing Regulation (EU) 2026/1778. Registration with a qualified electronic seal, a check of the backup copy and a hash of every passport version.
- Harmonised standards · EN 18216 and EN 18219–18223 were published in May 2026 and cited in the Official Journal in July 2026. EN 18239 and 18246 on access, security and authenticity have been announced but not yet cited. The standards give a presumption of conformity.
- Semantic repository · the data models the registry checks against, announced for publication in Q4 2026. Batteries first.
- Rules for service providers · a delegated act under ESPR Art. 11, announced for the end of 2026 or the first half of 2027. It will set requirements for information security and long-term viability for whoever operates the passport.
If you sell into the EU, it applies from day one.
Exporting to the EU
The requirements apply to products placed on the EU market, regardless of where the manufacturer is based. Manufacturers in Norway, Switzerland, the United Kingdom or anywhere else must have passports ready by the same date as their competitors in the EU, and for goods from outside the EU the importer is responsible.
The EEA
The ESPR and the Batteries Regulation are EEA-relevant, but as of October 2026 neither has been incorporated into the EEA Agreement. Once the EEA Joint Committee decides to incorporate them, they will also apply to sales in Norway, Iceland and Liechtenstein. Norway will implement the ESPR by amending its 2024 Act on sustainable products and value chains.
National authorities
In the EU, the regulations apply directly, but each country designates its own market surveillance authorities and sets penalties. In Norway, the Norwegian Environment Agency is preparing new battery regulations and consulted in spring 2026 on rules for using the EU registry for battery passports. Formal implementation in the EEA EFTA states follows incorporation.
The data takes the longest. Start there.
The technology to publish a passport exists. What takes time is collecting the right data from the supply chain and getting it into a structure that holds up.
Find your product group
Which row in the table applies to you, and is it one or several? A product with a battery, magnets and packaging is covered by three pieces of legislation at once, with the same data carrier.
Get your identifiers in place
Every passport needs a unique product identifier, normally a GTIN with a batch or serial number, encoded as a GS1 Digital Link in the QR code. It is the same code that opens the digital home today.
Map your data
Materials, origin, emissions, repair, recycling. The EU’s proposed content per group already exists for steel, textiles, tyres and furniture, and the content of the battery, toy and detergent passports is set out in the law.
Start with what is already required
Instructions, the declaration of conformity and safety information must already accompany the product. Put them behind the QR code now, and the passport becomes an extension of something that works, not a new project.
Read the legal texts yourself.
The overview has been checked against the primary sources. Secondary sources are only used where the Commission has not yet published anything itself, and the comment then says so.
- Ecodesign for Sustainable Products Regulation, ESPR (EU) 2024/1781, Art. 9–14 and Annex III. eur-lex.europa.eu
- ESPR Working Plan 2025–2030, COM(2025) 187, April 2025. environment.ec.europa.eu
- Batteries Regulation (EU) 2023/1542, Art. 13 and 77–78, Annexes VI and XIII. eur-lex.europa.eu
- The Commission’s questions and answers on the battery passport. single-market-economy.ec.europa.eu
- Construction Products Regulation (EU) 2024/3110, Chapter X, Art. 75–80. data.europa.eu
- Toy Safety Regulation (EU) 2025/2509, Art. 19–21 and Annex VI. data.europa.eu
- Detergents Regulation (EU) 2026/405, Art. 17–21 and Annexes V–VI. data.europa.eu
- Critical Raw Materials Act (EU) 2024/1252, Art. 28–29. data.europa.eu
- Packaging and Packaging Waste Regulation, PPWR (EU) 2025/40, Art. 12. data.europa.eu
- Implementing Regulation (EU) 2026/1778 on the EU DPP registry. data.europa.eu
- Implementing Decision (EU) 2026/1736 on harmonised DPP standards. data.europa.eu
- JRC, proposed passport content for iron and steel (March 2026) and textiles (May 2026). susproc.jrc.ec.europa.eu
- The Commission’s page on the digital product passport, with an indicative timeline per product group. single-market-economy.ec.europa.eu
- Euro 7 Regulation (EU) 2024/1257, Environmental Vehicle Passport. eur-lex.europa.eu
- CEN-CENELEC JTC 24, published DPP standards. cencenelec.eu
- EFTA, EEA-Lex: incorporation status in the EEA Agreement for the Ecodesign Regulation and the Batteries Regulation. efta.int · efta.int
- Norwegian Environment Agency, consultation on amendments to the Norwegian battery regulations (April 2026) and guidance on the registry of digital product passports (May 2026), in Norwegian. miljodirektoratet.no
Want to talk to one of our DPP experts? We are glad to advise you.
We work with this every day: reading the legal texts, building passport types to match them and following the EU registry and standards closely. We are happy to share that knowledge. Tell us briefly what you make, and we will set aside time to go through what applies to your products, when it applies, and what is wise to do first.
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