The EU Digital Product Passport, Explained

The EU Digital Product Passport (DPP) is a digital record, tied to a unique identifier, that carries a product's composition, sustainability and compliance data through its life — for whoever is entitled to read it, from a customs officer to a recycler. It is not a single document or app: it is a legal framework, one that fills in its own detail one product category at a time, and understanding that structure is the difference between reading the regulation correctly and reading it the way most explainers do.

This is the pillar page for that framework. If you came here for the battery-specific version, the battery passport vs Digital Product Passport post and the EU Battery Regulation guide go deeper on Article 77. Everything below is the general, cross-sector picture.

The legal basis: a framework, not a single rulebook

The DPP's legal basis is Regulation (EU) 2024/1781 of 13 June 2024 (OJ L, 2024/1781, 28.6.2024; CELEX 32024R1781) — the Ecodesign for Sustainable Products Regulation, universally shortened to ESPR. It was published on 28 June 2024 and entered into force on 18 July 2024, repealing the old Ecodesign Directive 2009/125/EC, which only ever reached energy-related products such as washing machines and light bulbs. ESPR's ambition is much broader: it applies, in principle, to almost any physical good placed on the EU market, with a short list of exclusions (food, feed, medicinal products, living organisms and a few categories already governed by their own product law, such as vehicles). It also directly amends Regulation (EU) 2023/1542, the Batteries Regulation — the hinge that ties the passport you may already know about to this wider system.

What a passport actually carries

Because the detail sits in product-specific delegated acts, the exact fields differ by category. But across every delegated act adopted or drafted so far, a passport is built from the same broad buckets: identity and origin (manufacturer, model, batch), material composition and substances of concern, environmental performance (durability, recyclability, and — where a methodology exists — carbon footprint), repair and end-of-life information, and the compliance documentation a market surveillance authority would ask for. For the one product group where this is already fully specified — batteries — the Annex XIII data requirements page walks through every field and who is allowed to see it. It is the most concrete preview available today of what a mature ESPR delegated act will eventually demand from other sectors.

Which products, and when

1. 28 June 2024In force

   ESPR published in the Official Journal

2. 18 July 2024In force

   ESPR enters into force

   The framework becomes law. No product-specific DPP obligation exists yet.

3. 16 April 2025In force

   First ESPR working plan adopted

   Communication COM(2025) 187 final (CELEX 52025DC0187) names textiles, furniture, mattresses, tyres, iron & steel and aluminium as priorities for a delegated act by 2030. This is an indicative plan, not a legally binding date.

4. 2026 (indicative)Expected

   Iron & steel — first product-specific delegated act targeted

   Not adopted as of July 2026. Nothing under Article 4 has been adopted for any product group yet.

5. 18 February 2027Due

   Battery passport obligation begins

   LMT batteries, industrial batteries above 2 kWh and EV batteries need a battery passport under Article 77(1) of Regulation (EU) 2023/1542 — a sectoral obligation that predates ESPR, not an ESPR delegated act.

6. 2027–2028 (indicative)Expected

   Textiles, tyres, aluminium, furniture, mattresses

   Working-plan targets only. No delegated acts have been adopted or formally proposed for these groups as of July 2026.

The one date on that list a compliance team can actually plan against today is the battery one:

Every other date above is a Commission target, not a legal deadline — worth tracking, not worth building a project plan around. Our compliance timeline keeps the battery-specific dates current against the Official Journal as they move.

Is your product in scope yet?

The registry: where identifiers get uploaded, not where the data lives

Article 13 of ESPR establishes a central EU Digital Product Passport registry. It does not store passport content — it is a directory that resolves a product's unique identifier to the location where the operator's own passport data is hosted. Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 (OJ L, 2026/1778, 17.7.2026; CELEX 32026R1778), in force since 6 August 2026, lays down how that registry actually operates — and it expressly puts batteries covered by Article 77 of Regulation (EU) 2023/1542 inside its scope alongside future ESPR product groups. It also requires each Member State to appoint a designated national registry administrator by 18 February 2027, the same date the battery passport obligation itself begins.

How the Digital Product Passport and the battery passport relate

The battery passport is the most mature part of this whole system, and it is easy to mistake it for a preview of an ESPR delegated act. It is not. Article 77 of the Batteries Regulation is its own, older obligation — the Batteries Regulation was adopted in 2023, before ESPR existed, and it is treated as lex specialis: the specific sectoral rule that governs batteries in preference to the general framework. What ESPR added, when it amended Regulation (EU) 2023/1542, was the shared plumbing — the registry, and the requirement (Article 77(10)) to upload the battery passport's unique identifier into it.

For the full walk-through of what that means in practice — including where the two obligations genuinely diverge — see battery passport vs Digital Product Passport, and for the wider battery compliance picture, the EU Battery Regulation guide.

What to do now

• Check whether a delegated act already covers you. If your product isn't a battery, iron & steel, textiles, tyres, furniture, mattresses or aluminium, no DPP obligation exists yet — but the working plan tells you roughly when one might.
• Don't wait for the delegated act to start on identifiers. Whatever your sector, a passport needs a unique identifier scheme and a data carrier (typically a QR code resolving through GS1 Digital Link). That work doesn't depend on which fields a future delegated act ultimately requires.
• Use the battery passport as your working model. It's the only fully specified instance of this framework today. The data requirements and battery categories pages show what "fully specified" actually looks like field by field.
• Keep a single source of truth for dates. Working-plan targets move; the FAQ and compliance timeline track what's confirmed against the Official Journal versus what's still indicative.

The single most useful habit for a compliance team right now is treating "named in the working plan" and "legally required" as two different sentences. Almost everything published about the Digital Product Passport blurs them. This page, and the regulation itself, does not.