Regulatory Alert: EU Digital Product Passport (DPP)

The EU Digital Product Passport (DPP) is being introduced as a mandatory requirement for products placed on the EU market, formally established and referenced in Regulation (EU) 2024/1781 – the Ecodesign for Sustainable Products Regulation (ESPR), which entered into force in July 2024.

The DPP creates a structured digital record for products, enabling authorities, supply-chain actors, and consumers to access sustainability, safety, and compliance information throughout the product lifecycle. It also supports digital compliance obligations under the General Product Safety Regulation (GPSR).

The rollout of the DPP will occur in phases.

1. 2025–2026 – Preparation phase only-

   • The EU is finalising technical standards, digital infrastructure, and interoperability frameworks.

   • No product category is yet legally required to have a DPP.

2. 2026 – Delegated acts adoption phase-

   • The Commission is expected to adopt delegated acts for certain product groups (e.g., batteries, electronics).

   • This does not create legally binding obligations yet; it sets the rules and deadlines that will later trigger enforcement.

3. 18 February 2027 – First legally binding enforcement-

   • Battery passports for industrial batteries, EV batteries, and LMT batteries must be in place under Regulation (EU) 2023/1542.

   • This is the first enforceable DPP obligation in EU law.

Other product categories, including textiles, electronics, and metals such as steel, do not yet have fixed enforcement dates. Their DPP obligations will be introduced through delegated acts under Regulation (EU) 2024/1781 – the ESPR, with compliance typically required 18 months after each delegated act comes into force.

Key Components of the Digital Product Passport

• Unique Digital Product Identifier
  Each product must be linked to a unique digital identifier, typically accessed via a QR code, DataMatrix, or similar data carrier placed on the product, packaging, or accompanying documentation. This identifier connects the physical product to its digital passport.

• Product Identification & Traceability Data
  The DPP must include core identification details such as product model, batch or serial number, and manufacturer or importer information. This enables traceability across the supply chain and supports market surveillance and recalls.

• Materials & Substances Information
  Manufacturers must disclose material composition and the presence of substances of concern, supporting EU chemical compliance and circular economy objectives. Data depth will be defined in sector-specific delegated acts.

• Environmental & Sustainability Information
  The passport will contain environmental performance data, which may include durability, recycled content, energy efficiency, carbon footprint indicators, or other sustainability metrics, depending on the product group.

• Repair, Reuse & End-of-Life Instructions
  DPPs must provide information to facilitate repair, refurbishment, reuse, and recycling, including disassembly instructions where relevant, supporting EU right-to-repair and waste reduction policies.

• Regulatory Compliance Documentation
  The DPP will provide digital access to required EU compliance documentation, such as the EU Declaration of Conformity, applicable standards, and conformity assessment details.

• Access Control & Data Availability
  Not all DPP data will be publicly accessible. Access rights will vary by user type, with consumers, supply-chain partners, and market surveillance authorities granted different levels of visibility as defined by EU rules.

Companies placing products on the EU market should begin preparing by mapping product data, assessing supply-chain data availability, and aligning internal systems with emerging DPP standards. Early action will help minimise compliance risk and ensure continued EU market access as DPP obligations become enforceable.