News & Insights

Digital Product Passport (DPP)

Batteries

Electronics

Metal

Plastic

Retail

The Digital Product Passport has been discussed as "something coming" for several years. On 20 July 2026 the European Commission launched the EU DPP Registry, and DPP obligations for large batteries – the first products that legally need a passport – and for several more products are around the corner.

What is a Digital Product Passport?

A Digital Product Passport (DPP) is a standardised digital record for products, components and materials, that will include information related to a product's safety, origin, materials, repairability, environmental performance, reuse and recycling, among others. The Ecodesign for Sustainable Products Regulation (ESPR, in force since July 2024) creates the legal basis for it and will extend it to most physical products sold in the EU market over time.
The DPP will be introduced progressively across selected product groups, starting with certain battery types (18 February 2027), with additional product groups expected to follow, such as textiles, iron and steel and construction products. What information a DPP must contain is decided per product group – i.e., a battery passport and a textile passport will look quite different.

Apart from collecting product data, getting suppliers to share it, being able to prove environmental claims etc, the real challenge for companies is understanding if they are affected, what they have to do, how, and when.

What's the purpose of DPP?

A simple example - imagine a washing machine sold in 2030:

A procurement manager or customer in the shop scans the QR code and can see the energy performance, the expected lifetime, recycled content, etc., to compare and make informed choices.
A repair shop - e.g. five years later - scans the same code and gets information about spare parts, disassembly, and the tools needed.
A market surveillance inspector - at any point - can reach the test reports and compliance documentation sitting behind the public claims.
A recycler - e.g. fifteen years later - scans it and sees which plastics were used, how much aluminium it contains, and where any substances of concern are located. The recycler can also ensure that the passport is deactivated at end-of-life.

In other words, a DPP boosts competitiveness since information that used to be invisible are now available to the buyers, and promotes circularity by providing repairers and recyclers the information they need – previously lost after the design stage. It also lets buyers compare products, it turns environmental claims into something anyone can check, it facilitates accessibility and interoperability of product data across regulatory frameworks, and gives authorities a way to spot products that break the rules.

For products that don’t comply, fines are set country by country while the sharper consequence is market access: once a passport is required for a product group, a product without a valid one cannot lawfully be placed on the EU market.

Product groups for which a DPP is foreseen

The product groups listed below fall outside the upcoming ESPR product groups and are expected to require a DPP through other product-specific legislation or regulatory frameworks. For example:

Batteries: EU Battery Regulation makes a product passport for EV, LMT, and industrial batteries above 2 kWh mandatory from 18 February 2027.
Construction products: Construction Products Regulation (CPR) general application started in January 2026 – delegated acts not yet adopted. Examples of product families that are prioritised in the PCR Working Plan are precast concrete and structural metallic products, doors and windows, thermal insulation, floorings, and around thirty other families.
Packaging: the Packaging and Packaging Waste Regulation (PPWR) requires a harmonised digital labelling system from August 2028.
Energy-related products: Fridges, motors, lighting, heat pumps and similar already have ecodesign and energy labelling rules, which ESPR now takes over. The existing rules stay valid until they are reviewed, and the Commission works through them between 2026 and 2029, adding passport requirements as it goes.
Other: Toys, detergents, and products containing critical raw materials

EU DPP Registry: the infrastructure

The Registry is the central EU index that ties the system together and went live on 20 July 2026. It stores the unique product identifier, a pointer to where that product's passport actually lives, associated metadata, and commodity codes for imported goods, but does not store product data – that is owned by and stays decentralised on the economic operator’s system (i.e., producer, importer, third-party DPP service provider etc.).

How to tell if your products are affected by DPP

Does your product already have its own passport-law?
EV, LMT, and industrial batteries above 2 kWh (mandatory in 2027), construction products, toys (August 2030) and detergents (September 2029) do.

Is your product included in the ESPR working plan?
The ESPR working plan is the EU Commission's rolling schedule of which product groups get rules, and when. The first priority groups are iron and steel (development of delegated acts expected from 2026), energy-related products, textiles, tyres, and aluminium (from 2027), furniture (from 2028), and mattresses and ICT products (2029).

Note that inclusion of a product group in the ESPR working plan does not automatically mean that a DPP will be required – it means the group is queued for a study that decides whether requirements apply at all. And those years are when the rules are adopted, not when you must comply: real obligations usually follow 18–36 months later.

What makes DPP implementation difficult?

Handling passports from many providers. Recyclers already see, for example, battery passports on different platforms, laid out differently. The standards should fix this for systems reading passports by machine, but not for people reading them one by one, and not the content, which varies per product group.
The data exists, but not as a set. Material composition sits in design files, carbon data in a consultant's report, supplier declarations in an email, etc. Putting all this together the first time is a bigger job than maintaining it afterwards.
You can only publish what your suppliers tell you. Material composition and recycled content cannot be produced internally. They depend on supply chain relationships, contract clauses and verification routines that take time to establish, which is why this is the work to start first.

You are preparing against requirements that are not final. For most ESPR product groups the delegated act does not yet exist, so the exact data fields are unknown. CEN and CENELEC, the European standardisation bodies, have set up a joint technical committee, JTC 24, to define the technical standards for DPPs. All eight standards were published in 2026, with EN 18239 on access rights management and EN 18246 on data authentication completing the set in September. Presumption of conformity requires separate citation in the EU Official Journal, which follows after the publication of each standard. You can build the structure for a DPP now, but you will be filling it in as the rules land. For batteries, the data points required in the DPP are already published.
What was once internal information becomes visible. Material composition and disassembly instructions are now only a scan away. Much of this information sits in the restricted layer rather than the public one, but it is still visible to the repairers and recyclers.

Six steps to get Digital Product Passport-ready

Establish which rule applies to you, and when

Battery Regulation, CPR, or a future ESPR delegated act? Find your product group in the Working Plan and set a realistic internal date, remembering the gap between adoption and compliance.

Pilot product passport & data inventory

Select the product with the cleanest available data and use it as a representative pilot to build a Product Passport and gain practical insights into the process. Conduct a data inventory by listing every data point the passport would likely require. For each data point, assess three key questions: Do we have it? Where does it live? Who owns it?

Close the supply chain data gaps

Material composition and recycled content have the longest lead times. Start the supplier conversations and get the requirements into contracts now.

Get your environmental data in order

Carbon footprint and life cycle data will be needed for the passport, but also for customers and your own reporting. Data produced through an established method (e.g., LCA to ISO 14040/14044, product carbon footprint to ISO 14067) is reusable across all three.

Assess recyclability and design for disassembly

Dismantling information is mandatory in the battery passport and likely in others. A recyclability assessment tells you what that information will actually say about your product and where design changes would improve it.

Sort out ownership and structure

Decide who owns passport data quality and update frequency. And note that you do not have to wait for your delegated act to start building: the European standards are already published, so a passport built to them is presumed to meet the ESPR requirements they cover.