Digital product passport (DPP): what the EU requires and when

Under Article 10 of the ESPR, a passport must be connected through a data carrier to a persistent unique product identifier. The data carrier sits on the product, its packaging or the documents that come with it. The data itself must use open standards and be machine-readable and transferable without vendor lock-in. Depending on the product group, a passport covers a model, a batch or a single item.

The passport is not one central EU database. The economic operator that creates it, or a DPP service provider acting for it, stores the data (Article 11). The EU registry stores at least the unique identifiers, and the Commission's DPP page describes how the registry then issues a unique registration identifier that customs can check. Customers, repairers, recyclers and authorities each see the part of the passport their access rights allow.

The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, was signed on 13 June 2024, published in the Official Journal on 28 June 2024 and, according to the Commission's ESPR page, has been in force since 18 July 2024. It is a framework: it does not set requirements for any product by itself. Those come in delegated acts, one per product group or one horizontal act for a group of similar products, and each act decides whether a passport is needed and what goes in it.

That is why there is no single DPP deadline. The Commission's DPP timeline says economic operators get a transition period of at least 18 months after a delegated act is adopted. One ESPR obligation already applies without a delegated act: since 19 July 2026, large companies may not destroy unsold clothing and footwear (Article 25 and Annex VII), with medium-sized companies following from 19 July 2030.

The table combines dates fixed in law with the Commission's indicative planning. The product groups come from the first ESPR and Energy Labelling Working Plan 2025-2030, adopted on 16 April 2025: textiles (apparel), furniture, tyres and mattresses as final products, iron and steel and aluminium as intermediate products, plus horizontal rules on repairability and on recycled content and recyclability of electronics.

As of 11 October 2026, the Commission's ESPR implementation page lists no adopted product-group delegated act. The acts for iron and steel, textiles and the other groups are still pending, so the dates for those rows are plans, not obligations.

Batteries have their own law. Article 77 of the Battery Regulation, Regulation (EU) 2023/1542, says that from 18 February 2027 every LMT battery (light means of transport, such as e-bikes and e-scooters), every industrial battery with a capacity above 2 kWh and every electric vehicle battery placed on the market must have a battery passport. Part of the passport is public, part is only for authorities, and part is for parties with a legitimate interest such as repairers and recyclers.

If you sell e-bikes, scooters or home storage batteries, this is the date to plan for. Ask your suppliers now how they will create the passport and how the data carrier will appear on the battery. The Commission published updated guidance on the battery passport on 21 August 2026, linked from its DPP page.

Each delegated act picks the exact fields. Annex III of the ESPR lists what an act can choose from, and Article 7 adds the product information an act may require. Together they show the kind of data to prepare.

You cannot build a compliant passport for textiles or furniture yet, because the fields are not final. You can make sure the data exists and has one home, so you are not chasing suppliers when an act is adopted and the transition period starts.

A passport draws on the same product data you already manage for your webshop and channels: identifiers, attributes, materials and documents. Keeping that data in one place now makes the passport a matter of export when the rules are final.