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EU manufacturers
Responsible for creating and maintaining the passport of the products they place on the market.
Regulatory dossier · Updated July 2026
No passport, no market.
The Digital Product Passport (DPP) will be mandatory to sell most physical products in the European Union. This guide explains what it is, when it affects you, what data it requires and how to prepare, sector by sector.
[ 00 ] — TL;DR
One digital record per product, accessible via QR, holding its identity, composition, sustainability and circularity data.
- Legal basis: the ESPR Regulation (EU) 2024/1781, in force since 18 July 2024.
- First prioritised sectors (2025–2030 working plan): textiles, furniture, tyres, steel and aluminium. Batteries follow their own regulation from February 2027.
- Obligations arrive through delegated acts, normally with around 18 months of transition after publication.
- Without a valid passport, products cannot be sold in the EU: customs and market surveillance can block them.
[ 01 ] — What it is
/ DPPA verifiable digital record that travels with every product.
It is a structured dataset that accompanies each product — by model, batch or item — throughout its life cycle. It is accessed by scanning a data carrier, typically a QR code with GS1 Digital Link, on the product itself, its packaging or its documentation.
It is not just another label: it is data infrastructure. It connects manufacturer, importer, distributor, consumer, repairers, recyclers and authorities to the same source of information, with different access levels depending on who is looking.
Unique identifierQR · GS1 Digital LinkVerifiable dataEU registryInteroperable
[ 02 ] — Legal framework
The rules
ESPR — Regulation (EU) 2024/1781
The general ecodesign framework that creates the DPP. In force since 18/07/2024, it is rolled out through delegated acts per product group.
Batteries — Regulation (EU) 2023/1542
Creates the battery passport: mandatory from 18/02/2027 for EV batteries, industrial batteries above 2 kWh and light means of transport.
Construction — Regulation (EU) 2024/3110
The new Construction Products Regulation includes its own digital passport, deployed in phases by product family.
Sectoral delegated acts
Define, for each product group, the specific ecodesign requirements and passport data, with transition periods (usually 18 months).
[ 03 ] — Timeline
Key dates
18 · 07 · 2024
ESPR in force. The legal framework of the DPP starts across the EU.
04 · 2025
First working plan 2025–2030. Prioritises textiles and footwear, furniture (including mattresses), tyres, iron and steel, and aluminium, plus horizontal measures on repairability and recycled content for electronics.
2026
Technical preparation. Harmonised standards (CEN/CENELEC), construction of the EU passport registry and first drafts of delegated acts.
2026 – 2027
First sectoral delegated acts. Each sets its data and deadlines; the obligation normally applies 18 months later.
18 · 02 · 2027
Battery passport mandatory for EV, industrial >2 kWh and light transport batteries.
2027 – 2028
First sectoral DPPs enforceable under each delegated act; textiles and steel expected among the first.
2028 – 2030
Progressive extension to more categories, with a working-plan review in 2028.
[ 04 ] — Who is obliged
Who is obliged
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Importers & brands
Whoever brings the product into the EU, or sells it under their own brand, takes on the manufacturer's obligations.
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Retail & marketplaces
Must verify that the products they sell have a valid DPP before offering them.
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Exporters to the EU
Even outside the EU, they will have to supply the data to their importer: no data, no sale.
[ 05 ] — Required data
The data
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Identity
Unique product identifier, GTIN, model, batch or item, and the responsible operator's details.
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Composition
Materials, substances of concern (SVHC / SCIP) and concentration thresholds.
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Sustainability
Carbon and environmental footprint, durability and ecodesign performance results.
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Circularity
Repairability, spare parts, recycled content, disassembly and recycling.
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Compliance
Declaration of conformity, applied standards and related technical documentation.
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Supply chain
Traceability of origin and actors, with different access levels for the public, professionals and authorities.
[ 06 ] — How it works
The architecture
01
Identify
Each product gets a unique identifier tied to a data carrier: QR with GS1 Digital Link, RFID or watermark.
02
Structure
Data is organised according to the harmonised standards and your sector's delegated act.
03
Publish
The passport is hosted on the operator's systems (decentralised model) and registered in the EU central registry.
04
Maintain
Data is updated throughout the product's life: repairs, resale, recycling.
[ 07 ] — Diagnostic
What about my sector?
Pick your sector and we tell you where the regulation stands, what data it will demand and where to start.
[ 08 ] — Roadmap
Six phases
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Data inventory
Gather what you already have: spec sheets, SDS, declarations, certificates and supplier data. Spot the gaps.
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Gap analysis
Compare against your delegated act's requirements (or the closest one) and prioritise by impact and effort.
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Data governance
Define owners, sources of truth (PIM / ERP) and continuous update processes.
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Identifiers & carriers
Adopt GTIN + GS1 Digital Link and choose the physical carrier: QR, RFID or watermark.
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DPP pilot
Issue passports for one product family and validate the flow with customers and auditors.
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Scale & monitoring
Extend to the full catalogue, integrate with your systems and monitor every new delegated act.
[ 09 ] — Risks of non-compliance
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Fines & withdrawal
Each Member State sets effective, dissuasive penalties; products can be withdrawn from the market.
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Blocked at the border
Customs will be able to check the DPP at clearance: without a valid passport, goods do not enter.
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Exclusion & reputation
Loss of access to public procurement and to B2B customers who already demand the data. Plus brand damage.
[ 10 ] — Opportunities
The upside
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Trust that sells
Verifiable transparency as a brand argument for consumers and B2B buyers.
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Data that saves
Tidy product data cuts errors, returns and costs: the DPP pays for the project.
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Access advantage
Those who arrive prepared turn a regulatory barrier into an entry barrier for their competitors.
[ 11 ] — Sources
Official sources
Regulation (EU) 2024/1781 — EUR-Lex ↗ — official and consolidated text of the ESPR.
European Commission — Ecodesign for Sustainable Products ↗ — official ESPR and working-plan page.
Regulation (EU) 2023/1542 — Batteries ↗ — legal basis of the battery passport.
CIRPASS-2 ↗ — European pilots deploying the DPP by sector.
GS1 Digital Link ↗ — identification standard giving access to product data.
Frequently asked questions
What exactly is the Digital Product Passport?+
A structured dataset about a product — identity, composition, sustainability, circularity and compliance — accessible through a carrier such as a QR code and verifiable by consumers, companies and authorities.
When will it be mandatory?+
It depends on the sector. Batteries: 18 February 2027. The rest arrives through ESPR delegated acts: the first sectors (textiles, furniture, tyres, steel, aluminium) will foreseeably face obligations between 2027 and 2028, with about 18 months of transition after each act.
Does it affect me if I do not manufacture in the EU?+
Yes, if you sell in the EU. Your importer takes on the obligations and will pass the data requirement upstream: without DPP data, they cannot buy your product.
What happens if I do not comply?+
The product cannot be marketed: national fines, market withdrawal and possible blocking at customs.
Where is the data stored?+
On the responsible operator's systems (decentralised model), connected to an EU central registry. Data must be interoperable, secure and persist even if the company disappears.
Do DPP and blockchain go together?+
The regulation is technology-neutral. Blockchain fits when you need verifiable data between parties that do not trust each other (chain of custody, certification), but it is not mandatory.
What is GS1 Digital Link?+
The standard that turns a barcode or QR into a smart URL: the same code takes the consumer, the recycler or the authority to the data view that corresponds to them.
Where do I start?+
With the data: inventory, gaps and governance (phases 1–3 of the roadmap). It is 80% of the effort and pays off even if your delegated act takes time.
Glossary
ESPR+
Regulation (EU) 2024/1781 on ecodesign for sustainable products: the framework that creates the DPP.
DPP+
Digital Product Passport: the product's dataset, accessible through a data carrier.
Delegated act+
Commission rule that defines, sector by sector, the ecodesign requirements and passport data.
Working plan+
Document setting which product groups are regulated first; the current one covers 2025–2030.
GS1 Digital Link+
Standard that turns a QR or barcode into a URL giving access to the product's data.
GTIN+
Global Trade Item Number: your product's licence plate in the GS1 system.
Data carrier+
The physical element giving access to the DPP: QR, RFID, NFC or digital watermark.
SVHC+
Substances of Very High Concern under REACH, declarable above 0.1% by weight.
SCIP+
ECHA database where articles containing SVHC are notified.
DoC+
EU Declaration of Conformity: the document stating the product complies with applicable rules.
PIM+
Product Information Management system: the source of truth of your catalogue data.
CBAM+
Carbon Border Adjustment Mechanism: a levy on CO₂-intensive imports (steel, aluminium, cement…).
EU DPP registry+
Central European registry where the identifiers of issued passports are recorded.
Economic operator+
Manufacturer, importer, distributor or authorised representative: whoever bears obligations for their role.
Official partner of
Strategic collaboration in expansion, franchising and the technological transformation of businesses.
Let's talk
Does your product need a passport?
We build DPP infrastructure: data, identifiers, integration and verification. Initial diagnosis at no obligation.
contacto@expandia.tech