What is a Digital Product Passport
A Digital Product Passport (DPP) is an electronic set of product data, linked to the product's unique identifier through a data carrier such as a QR code on the product, its packaging or its documentation (Article 10(1)). It holds the information customers, repairers, recyclers and authorities need: materials, substances, repair, recycling, compliance and documents.
The Regulation names three aims of the passport (Article 9(3)): easy access for actors along the value chain to the information relevant to them, easier compliance checks by national authorities, and better traceability of products.
A product covered by the requirement may be placed on the market only if a passport is available, and the passport data must be correct, complete and up to date (Article 9(1)).
When the passport becomes mandatory
The ESPR itself does not impose the obligation on specific products. Delegated acts adopted by the Commission for individual product groups do. An act applies no earlier than 18 months after its entry into force, except in duly justified cases (Article 4(4)).
The first ESPR Working Plan of April 2025 gives indicative years for adopting the acts:
| Year | Product group |
|---|---|
| 2026 | Iron and steel |
| 2026–2029 | Energy-related products |
| 2027 | Textiles, tyres and aluminium |
| 2028 | Furniture |
| 2029 | Mattresses and ICT products |
These are adoption years, not compliance dates. Being in the Working Plan does not automatically make a passport mandatory: the Commission first runs studies and an impact assessment for the product group.
Passports under other EU laws
Separate regulations also require a passport, and their identifiers go to the same EU registry (Implementing Regulation (EU) 2026/1778, Article 1):
- batteries: Regulation (EU) 2023/1542, from 18 February 2027 (battery passport guide);
- construction products: Regulation (EU) 2024/3110;
- toys: Regulation (EU) 2025/2509;
- detergents and surfactants: Regulation (EU) 2026/405.
What a delegated act sets out
For each product group, the delegated act sets out (Article 9(2)):
- what data the passport contains, based on Annex III;
- which data carrier to use, how to present it and where to place it;
- whether the passport is created at model, batch or item level;
- how the passport is made available to customers before purchase, including distance sales;
- who has access to which data, and who may enter and update it;
- how long the passport must remain available: at least the expected lifetime of the product.
Requirements for every passport
Whatever the product group, the passport must meet the essential requirements of Articles 10 and 11:
- a persistent unique product identifier, linked to a data carrier on the product, its packaging or documentation;
- data based on open standards, structured, machine-readable, searchable and transferable without vendor lock-in;
- no personal data about customers without their explicit consent;
- free and easy access for customers, repairers, recyclers, market surveillance and customs authorities and other relevant actors, according to their access rights;
- availability for the whole required period, including after insolvency, liquidation or the responsible operator ceasing activity in the EU;
- a backup copy of the passport made available through a digital product passport service provider (Article 10(4));
- authentication, reliability and integrity of data, and a high level of security and privacy.
The operator placing a product on the market also gives dealers and online marketplaces a digital copy of the data carrier or the product identifier, free of charge and within five working days of a request (Article 10(3)). This lets customers see the passport in online shops too.
The digital product passport registry
By 19 July 2026 the Commission was to set up a registry that stores at least the unique identifiers and, for products to be released for free circulation, the commodity code (Article 13). The registry does not store the full passport data. The data stays with the economic operator or its service provider, and the registry links the product identifier to where the passport is.
The detailed rules, covering access to the registry, verification of operators, registration of identifiers, the passport level and its statuses, are set by Implementing Regulation (EU) 2026/1778.
Harmonised standards
With Implementing Decision (EU) 2026/1736 of 14 July 2026, the Commission published references to six standards. A passport that conforms to them is presumed to meet the requirements of ESPR Articles 10 and 11.
| Standard | Scope |
|---|---|
| EN 18216:2026 | Data exchange protocols |
| EN 18219:2026 | Unique identifiers |
| EN 18220:2026 | Data carriers |
| EN 18221:2026 | Data storage, archiving and persistence |
| EN 18222:2026 | APIs for passport life cycle management and searchability |
| EN 18223:2026 | System interoperability |
Who creates the passport
The passport must be active and registered when the product is placed on the EU market. It is created by the economic operator placing the product on the market: most often the manufacturer, or the importer for products from outside the EU. Depending on the case, it can also be the authorised representative, distributor, dealer or fulfilment service provider.
The passport is stored by the operator itself or by a digital product passport service provider. The provider may not sell or use the data beyond the agreed scope of the service (Article 11). When a product gets a new passport, e.g. after remanufacturing, the new passport must be linked to the original one (Article 11(d)).
How to prepare your company
- Check which rules apply to you. ESPR, batteries, construction products and toys have different deadlines. The obligations survey shows what applies to your company.
- Collect product data. Materials, substances including SVHCs, compliance documents, repair and recycling instructions, and supplier data.
- Sort out identifiers. Model, batch and serial numbers. Consider a GS1 GTIN, which Annex III names explicitly. How a GS1 Digital Link code works.
- Assign responsibility. Decide who in your company and at your suppliers fills in the data and keeps it up to date.
- Choose a system. Check open-format data export, access rights, backups and conformity with EN 18216–18223.
Digital Product Passports in PassTrace
PassTrace is a platform for creating and publishing passports across industries. We start with the battery passport and will align the furniture, electronics, textiles and chemicals templates with the delegated acts once the Commission adopts them. Every passport has a GS1 Digital Link QR code, a public page for customers and data visible only to authorised parties.
Frequently asked questions
Is the Digital Product Passport already mandatory?
Not for most products yet. The first obligation covers LMT, EV and industrial batteries above 2 kWh from 18 February 2027. For product groups under ESPR, the obligation starts after a delegated act is adopted, usually no earlier than 18 months after it enters into force.
Is the passport the same as the QR code?
No. The QR code is the data carrier that leads to the passport. The passport is the product data kept by the economic operator or its service provider.
Are small companies exempt from the passport?
The ESPR does not exempt SMEs from the passport. The Commission must, however, take the needs of SMEs, in particular microenterprises, into account when setting deadlines in delegated acts (Article 4(4)). Exemptions for micro and small enterprises concern other obligations, such as disclosing information on destroyed unsold products.
Where is passport data stored?
With the economic operator or a service provider acting on its behalf. The EU registry stores identifiers and any data named in the delegated acts, not the full passport. In addition, the operator must make a backup copy of the passport available through a service provider.
Is the passport created for the model or for each unit?
That depends on the delegated act: the passport can be at model, batch or item level (Article 9(2)(d)). Battery passports are kept for each battery individually.
Sources
- Regulation (EU) 2024/1781 (ESPR) on ecodesign requirements for sustainable products
- Implementing Regulation (EU) 2026/1778 on the digital product passport registry
- Implementing Decision (EU) 2026/1736 on harmonised standards for digital product passports
- Regulation (EU) 2023/1542 concerning batteries and waste batteries
- European Commission Ecodesign and Energy Labelling Working Plan 2025–2030 (April 2025)
This guide is based on the texts of acts published in the Official Journal of the EU and is not legal advice.