The EU's Digital Product Passport is coming, starting with batteries in February 2027 and expanding to textiles, electronics, furniture, and other product categories through 2030. This guide explains what a DPP is, which regulations mandate it, what data it must include, and how it connects to the broader EU compliance ecosystem including the Packaging and Packaging Waste Regulation (PPWR), CSRD, and the EU Taxonomy.

What is a Digital Product Passport?

A Digital Product Passport (DPP) is a structured digital record that contains information about a product's composition, origin, environmental impact, repairability, and recyclability across its entire lifecycle. It gives consumers, recyclers, repair technicians, and regulators access to standardized product data in support of the EU's circular economy goals.

The DPP works through a data carrier, typically a QR code, physically attached to the product. Scanning the carrier links to a digital record accessible to any authorized party, from the manufacturer to the end-of-life processor.

The EU's Ecodesign for Sustainable Products Regulation (ESPR), adopted in 2024, is the primary legal framework mandating Digital Product Passports across product categories. ESPR applies to virtually all physical products sold on the EU market, with food, feed, and medicines as the main exceptions.

Why the DPP matters for manufacturers and importers

Companies that manufacture or import physical products into the EU will need to create and maintain a DPP for each relevant product category once the applicable delegated acts come into force. The DPP becomes the primary document for demonstrating compliance with product sustainability requirements, covering recycled content, repairability scores, and carbon footprint data.

The compliance burden is significant, but the data work required for a DPP overlaps with obligations under the Packaging and Packaging Waste Regulation (PPWR) and with CSRD reporting requirements under ESRS E5 (Resource Use & Circular Economy). Companies that align their data collection efforts across these frameworks will cover multiple compliance obligations with a single infrastructure investment.

The legal framework: ESPR, Battery Regulation, and PPWR

Three EU regulations create DPP requirements and connect them to packaging and corporate reporting obligations. Understanding how they interact is essential for compliance planning.

ESPR (Ecodesign for Sustainable Products Regulation)

The Ecodesign for Sustainable Products Regulation (ESPR) is the umbrella regulation mandating Digital Product Passports across EU product categories. Adopted in 2024, ESPR replaces the earlier Ecodesign Directive, which only covered energy-related products.

Under ESPR, product-specific requirements, including which data must go into a DPP and how it must be structured, are set through delegated acts. Product categories are addressed one by one through these acts, each defining the exact data fields, data carriers, and access rules for the relevant sector.

The European Commission published the first ESPR Working Plan in April 2025, identifying textiles and apparel, furniture, mattresses, tyres, iron, steel, and aluminium as priority product groups. The Working Plan confirmed that up to 30 delegated acts are expected by 2030, covering most physical products sold on the EU market.

The April 2025 Working Plan also launched a public consultation on requirements for DPP Service Providers, which closed in July 2025. The outcome of this consultation will determine how companies and technology providers must implement, host, and update DPPs in practice.

EU Battery Regulation (2023/1542)

The EU Battery Regulation (Regulation (EU) 2023/1542) is the first EU law to impose a mandatory DPP requirement and the only confirmed deadline as of early 2026. Under this regulation, a battery passport is required for electric vehicle (EV) batteries, light means of transport (LMT) batteries, and industrial batteries with a capacity above 2 kWh from 18 February 2027.

The battery DPP must include data on the battery's chemistry, capacity, state of health, carbon footprint per kWh, recycled content of cobalt, lithium, nickel, and lead, and supply chain due diligence information. Battery manufacturers and importers placing these products on the EU market should already be mapping their data assets against these requirements.

The battery passport is technically the most advanced DPP requirement in force. It requires the battery to carry a QR code linked to a digital record hosted by a service provider certified under the regulation's requirements.

The PPWR connection

The Packaging and Packaging Waste Regulation (PPWR) sets requirements for packaging composition, recyclability, and recycled content that overlap directly with the type of structured product data a DPP is designed to carry. Packaging material composition, recyclability grades, and recycled content percentages involved in PPWR are exactly the kind of product attributes a DPP records.

For companies subject to both PPWR and ESPR, the DPP creates an opportunity to centralize product-level compliance data. The structured data workflows required for PPWR documentation, including supplier declarations and recyclability assessments, form the foundation of what a DPP data architecture will require.

For a detailed breakdown of PPWR obligations and their deadlines, see PPWR compliance deadlines explained.

DPP timeline: when does it apply to your products?

The DPP rollout follows the ESPR delegated act schedule, with batteries as the only confirmed mandatory category so far. For all other product groups, requirements are published on a rolling basis as delegated acts are finalized.

Confirmed:

• Batteries (EV, LMT, industrial batteries above 2kWh): mandatory from 18 February 2027 under Regulation (EU) 2023/1542

Expected from 2027 (ESPR Working Plan, April 2025):

• Textiles and apparel: delegated act expected 2027–2028
• Furniture and mattresses: delegated act expected 2027–2028
• Tyres: delegated act expected 2027–2028
• Iron, steel, and aluminium: 2026 onwards under ESPR

Under development (timeline to be confirmed):

• Electronics and electrical equipment: targeted in the EU-funded CIRPASS-2 pilot project running to April 2027; delegated act expected 2028–2030
• Construction products: under separate regulatory development
• Footwear, detergents, and chemicals: study phases underway; delegated acts expected between 2028 and 2030

The European Commission's April 2025 Working Plan confirmed that DPP requirements will expand to cover most physical product categories on the EU market by 2030. Companies should not wait for their specific delegated act to start building the product data infrastructure DPP compliance requires.

What data must a Digital Product Passport contain?

DPP data requirements vary by product category and are set in each delegated act. Based on the ESPR framework and the confirmed battery DPP requirements, most DPPs will include data across six main areas.

Product identification and manufacturer information:

• Unique product identifier (GS1 GTIN or equivalent standard)
• Manufacturer name and contact information
• Country of origin and production location
• Production date and product model information

Material composition and substances of concern:

• Primary materials and their percentage by weight
• Presence of substances of very high concern (SVHCs) listed under REACH
• Packaging materials and their recyclability classification

Environmental performance data:

• Product carbon footprint (lifecycle assessment basis)
• Recycled content percentage by material
• Resource consumption data where required by the delegated act

Circularity and end-of-life information:

• Repairability score and availability of spare parts
• Recyclability assessment and disassembly instructions
• End-of-life handling and sorting guidance

Supply chain traceability:

• Key supplier information and origin of critical components
• Relevant certifications and compliance declarations

Compliance declarations:

• Confirmation of conformity with applicable ESPR delegated act requirements
• CE marking reference where applicable

For battery DPPs specifically, Regulation (EU) 2023/1542 requires detailed data on state of health, remaining capacity, carbon footprint per kWh, and recycled material content for cobalt, lithium, nickel, and lead. These requirements set the benchmark for how detailed DPP data obligations can be across other product categories.

Companies that have already built PPWR data workflows, including recyclability grade assessments and packaging declarations of conformity, will find significant overlap with DPP material composition and packaging data fields.

Technical implementation: how DPPs work

A DPP is built on three technical components: a data carrier attached to the product, a unique product identifier, and a digital record linked to the carrier. Understanding each component is essential for implementation planning.

Data carriers and identifiers

A data carrier is a physical marking on the product or its packaging that links to the DPP digital record. Under ESPR, the data carrier must be machine-readable and physically attached to the product throughout its lifecycle.

The most common data carrier is a QR code, which links to a URL using the GS1 Digital Link standard. GS1 Digital Link encodes a unique product identifier, typically a Global Trade Item Number (GTIN), into a web-resolvable URL format that any modern smartphone can scan without a dedicated app.

Alternative carriers serve different use cases:

• RFID (Radio Frequency Identification) tags: high data capacity, suited for supply chain automation and logistics scanning
• NFC (Near Field Communication) chips: consumer-facing, enable smartphone interaction without a visible code, common in luxury goods
• Data Matrix codes: compact format offering equivalent data capacity to a QR code in a smaller footprint

GS1 published a Provisional Standard for DPP encoding in 2024, providing a framework for how product identifiers map to DPP data records. Companies that already use GS1 standards for product identification are well-positioned to extend their existing identifier infrastructure to support DPP data carriers.

Data architecture

DPP data can be stored in centralized or decentralized systems, but all approaches must meet interoperability requirements set under ESPR. The key requirement is that data be accessible to any authorized party, from market surveillance authorities to recyclers, through a standardized interface.

The CIRPASS project, an EU-funded initiative that concluded its first phase in March 2024 after consulting over 40 stakeholders across battery, electronics, and textile sectors, established that decentralized architectures are preferred. Manufacturers maintain their own data and link it to the product's data carrier. Interoperability is achieved through common data standards, not centralized storage.

The follow-on CIRPASS-2 project, running from May 2024 to April 2027, is conducting 13 large-scale pilot deployments across textiles (6 pilots), electronics (5 pilots), and tyres (2 pilots) with 50 consortium partners from across Europe. The pilots are testing real-life circular use cases including reuse, repair, and recycling, ahead of final delegated act requirements. Their findings will inform the technical specifications companies need to implement.

Who creates and maintains the DPP?

The primary responsibility for creating and maintaining a DPP rests with the manufacturer placing the product on the EU market. For products manufactured outside the EU, the importer takes on responsibility for ensuring the DPP meets applicable requirements before the product is placed on the market.

Distributors and retailers also carry obligations under ESPR to ensure the products they handle carry a valid, up-to-date DPP. For importers already managing supplier documentation under PPWR, the data collection structure for DPPs follows a similar pattern. See PPWR compliance for importers: a step-by-step guide for a worked example of how to structure supplier data requests and documentation workflows.

Supply chain data providers, component manufacturers, and material suppliers play a supporting role, as much of the data required for a complete DPP sits upstream of the final product manufacturer. This makes supply chain data collection one of the main practical challenges in DPP implementation.

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How DPP connects to your EU compliance stack

The Digital Product Passport does not exist in isolation. It connects directly to three other EU regulatory frameworks that require product-level sustainability data.

DPP and PPWR

The Packaging and Packaging Waste Regulation (PPWR) and the ESPR DPP overlap on packaging composition and recyclability data. PPWR requires companies to document packaging recyclability under a grading system (grades A through E under the harmonized recyclability methodology) and to track recycled content targets by material type and packaging function. This same structured packaging data, formatted to ESPR standards, feeds directly into DPP requirements for any product where packaging falls within scope.

Companies that have already built PPWR data workflows, collecting material composition declarations and recyclability assessments from packaging suppliers, are ahead on DPP data preparation. The PPWR Declaration of Conformity documentation captures much of the structured product data a DPP will require for packaging fields.

For companies where PPWR compliance is already underway, the recommended approach is to build DPP data requirements into the same supplier engagement process rather than creating separate data collection streams. For a full breakdown of PPWR roles and responsibilities, see PPWR roles explained: when importers become manufacturers under Article 21.

DPP and CSRD (ESRS E5: Resource use and circular economy)

ESRS E5, the Circular Economy standard under the Corporate Sustainability Reporting Directive (CSRD), requires companies to report on circular economy practices including product design for durability, recyclability, and reuse. DPP data, specifically the repairability scores, recyclability assessments, and recycled content percentages a DPP contains, directly supports ESRS E5 disclosures.

For companies subject to CSRD reporting, the DPP becomes a data backbone for circular economy metrics. Rather than collecting product lifecycle data separately for the DPP and again for ESRS E5 disclosures, the same underlying data can serve both obligations. The DPP's structured product-level data provides the quantitative evidence base that ESRS E5 disclosures on circular economy strategies and targets require.

For a full breakdown of ESRS E5 disclosure requirements, see how to interpret ESRS E5: Resource use and circular economy.

DPP and EU Taxonomy

The EU Taxonomy's circular economy objective (Environmental Objective 4) applies to economic activities that contribute substantially to the transition to a circular economy. For companies conducting EU Taxonomy assessments, DPP data on recycled content, recyclability, and repairability provides quantitative evidence for technical screening criteria under this objective.

Product-level lifecycle data that a DPP captures, including end-of-life recyclability rates and circular material use percentages, maps directly to the "do no significant harm" criteria under other environmental objectives and contributes to Taxonomy-eligible revenue calculations for companies with circular economy activities in their business model.

The connection is particularly relevant for manufacturing companies that report under both CSRD and the EU Taxonomy. A single product data infrastructure, built to meet DPP requirements, can supply the product-level evidence needed for ESRS E5 impact disclosures and EU Taxonomy activity assessments simultaneously.

How to prepare for DPP compliance

DPP compliance is a data-first challenge. Companies that start building their product data infrastructure now will be significantly better positioned when delegated acts take effect for their product categories.

Step 1: Determine if your products fall under DPP scope

The ESPR applies to virtually all physical products placed on the EU market, except food, feed, and medicines. If your company manufactures or imports batteries, textiles, electronics, furniture, or most other physical goods, DPP requirements will apply to at least some of your product portfolio. Check whether your product categories appear in the April 2025 ESPR Working Plan priorities. Battery manufacturers and importers have a confirmed deadline of 18 February 2027 and should already be in active preparation.

Step 2: Map your current product data availability

Conduct an internal audit of the product data your company currently holds. For each product category, assess what data exists on material composition, origin, carbon footprint, recyclability, and supplier certifications. Identify where data is stored: ERP systems, product lifecycle management tools, supplier portals, or unstructured documents. Many companies discover that the data exists but is fragmented across systems and business units.

Step 3: Identify data gaps against DPP requirements

Compare your current data holdings against the likely DPP requirements for your product category. For batteries, use Regulation (EU) 2023/1542 as the benchmark. For other categories, the ESPR framework and CIRPASS-2 pilot outputs provide a directional view. Common data gaps include product carbon footprint data (particularly lifecycle-based), supply chain traceability beyond direct suppliers, and standardized recyclability assessments that go beyond general claims.

Step 4: Engage your supply chain for missing data

The data required for a complete DPP largely sits upstream with component suppliers, material producers, and sub-suppliers. Establishing structured data collection processes with key suppliers is a prerequisite for DPP compliance. Companies that have already set up supplier data workflows for PPWR packaging compliance can adapt these processes for DPP data fields, as the supplier engagement model is similar.

Step 5: Evaluate technology solutions for DPP creation

Creating and hosting a DPP requires a data management system capable of storing structured product data, issuing unique product identifiers compliant with GS1 standards, generating QR codes or other data carriers, and managing data updates as products change across their lifecycle. The market for DPP technology platforms is developing rapidly alongside the ESPR regulatory framework.

Step 6: Monitor delegated acts for your product category

DPP requirements are set category by category through delegated acts. The April 2025 ESPR Working Plan identified priority categories, but the specific data fields and technical standards for each will only be confirmed when the relevant delegated act is published. Set up monitoring for European Commission publications in your product categories, and follow CIRPASS-2 pilot outputs, which will publish findings through April 2027 and will inform the technical specifications of future delegated acts.

FAQ

What is a Digital Product Passport?

A Digital Product Passport (DPP) is a structured digital record attached to a physical product via a data carrier (typically a QR code). It contains information about the product's composition, origin, environmental impact, repairability, and recyclability. The EU's Ecodesign for Sustainable Products Regulation (ESPR), adopted in 2024, mandates DPPs across EU product categories.

Is the EU Digital Product Passport mandatory?

Yes. DPPs are mandatory under ESPR for product categories covered by delegated acts. Batteries are first: EV, LMT, and industrial batteries above 2kWh require a DPP from 18 February 2027 under Regulation (EU) 2023/1542. Textiles, electronics, and furniture follow through delegated acts expected between 2027 and 2030. ESPR covers virtually all physical products on the EU market except food, feed, and medicines.

How do you create a Digital Product Passport?

Creating a DPP requires five steps: (1) collecting product data on composition, origin, and environmental impact; (2) structuring it according to the applicable delegated act; (3) assigning a unique product identifier using GS1 standards; (4) encoding it in a data carrier such as a QR code or RFID tag; and (5) linking the carrier to an interoperable digital record accessible to consumers, regulators, and recyclers.

How does a Digital Product Passport work?

A DPP works through a data carrier physically attached to the product. Scanning the carrier, typically a QR code using the GS1 Digital Link standard, links to a digital record containing standardized product information. This record is accessible to consumers, recyclers, regulators, and market surveillance authorities throughout the product's lifecycle, from manufacture to end-of-life processing.

What brands are using Digital Product Passports?

Early adopters include battery manufacturers preparing for the February 2027 deadline and luxury fashion brands including LVMH, Cartier, and Burberry, which have piloted DPPs for product authentication, repair programs, and resale. The EU-funded CIRPASS-2 project (2024–2027) is running 13 large-scale pilots across textile, electronics, and tyre value chains with 50 European consortium partners.

How does the DPP relate to PPWR and CSRD?

PPWR requires packaging composition and recyclability data that overlaps directly with DPP requirements. CSRD's ESRS E5 (Circular Economy) requires reporting on product lifecycle data that DPPs provide. For companies subject to all three, the DPP becomes a shared data source: PPWR conformity documentation, ESRS E5 circular economy disclosures, and EU Taxonomy circular economy assessments all draw from the same product-level data a DPP captures.