The Digital Product Passport

Last reviewed: August 2026 · Legal status verified against EUR-Lex.

The Digital Product Passport (DPP) is a structured, electronic record of product information, made accessible through a data carrier — typically a QR code — affixed to the product, its packaging, or its accompanying documentation. Its legal foundation is the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR), in force since July 2024, though the first passport to become mandatory arrives through a different act: the battery passport under the Battery Regulation, from 18 February 2027. Over the coming decade the DPP is set to become as routine a part of placing a product on the EU market as the Declaration of Conformity is today — and in one sector, toys, it is already replacing it.

This page explains the model established by the ESPR, the concrete cases that are already fixed in law, and — importantly — what remains undecided. DPP requirements arrive product group by product group through delegated acts, and for most sectors those acts have not yet been adopted. Statements about "the" DPP should always be read against that pipeline.

What a Digital Product Passport is

Under the ESPR, a DPP is a set of data specific to an individual product, batch, or product model (the granularity is set per product group), registered and retrievable electronically through a data carrier. The design principles fixed in the regulation are:

• A data carrier on the product. A machine-readable carrier — QR code or equivalent — physically present on the product, its packaging, or documentation, linked to a unique product identifier.
• Interoperability and open standards. Data formats and exchange protocols must be open and interoperable, so that no single commercial platform controls access.
• Decentralised storage. The passport data is created and held by the responsible economic operator (or a service provider acting for it), not in a central EU database. The Commission maintains a registry storing the unique identifiers — so that authorities and customs can verify that a passport exists — and a public web portal through which passports can be searched. The data itself stays with the operator.
• Tiered access. Different data fields are visible to different audiences: consumers and the public see one layer; market surveillance authorities, customs, repairers, and recyclers see more.
• Persistence. The passport must remain available for a defined period after the last unit of a model is placed on the market, and must survive the insolvency or exit of the operator through backup arrangements.

What it will contain

The ESPR lists the categories of information a delegated act may require in a passport; the actual content is fixed per product group. Recurring elements across the framework and the known sectoral cases include:

• the unique product identifier and the identity of the manufacturer and responsible operators (compare the traceability duties in manufacturer obligations);
• compliance information — references to the applicable legislation, the Declaration of Conformity or performance, and identification of any Notified Body involved;
• substance and material information, including substances of concern;
• performance data against the applicable ecodesign requirements: durability, reparability scores, recycled content, carbon footprint, depending on the product group;
• user information: instructions, spare-part availability, repair and disassembly information, end-of-life handling.

What a passport for any given product must contain, at what granularity (item, batch, or model), and from what date, is decided only in the delegated act for that product group. Until that act is adopted, no ESPR-based DPP obligation exists for the group.

The concrete cases fixed in law

Battery passport — 18 February 2027

Article 77 of the Battery Regulation (EU) 2023/1542 requires an electronic battery passport for each LMT (light means of transport) battery, electric vehicle battery, and industrial battery with capacity above 2 kWh placed on the market from 18 February 2027. Each battery carries a QR code linking to a passport holding identification, composition (including critical raw materials), carbon footprint, due diligence information, and data relevant to second life and recycling, with state-of-health data updated over the battery's life. The battery passport predates any ESPR delegated act and is the operational prototype for the whole DPP programme.

Toy passport — under the Toy Safety Regulation (EU) 2025/2509

The Toy Safety Regulation (EU) 2025/2509, in force since 1 January 2026, introduces a Digital Product Passport for toys that takes over the role of the paper EU Declaration of Conformity in that sector: instead of drawing up and holding a paper DoC, the manufacturer creates a toy DPP before placing the toy on the market, and the data carrier accompanies the toy. The passport supports border enforcement — customs can check for the existence of a valid passport at import. The obligation becomes effective as the regulation's application dates and transition periods run their course; toys compliant with Directive 2009/48/EC may still be placed on the market during the transition. Manufacturers selling toys should track the regulation's transitional provisions directly on EUR-Lex, as the operative dates are staggered.

ESPR product groups — following the April 2025 working plan

The first ESPR working plan, adopted in April 2025, named the priority product groups for delegated acts; textiles (apparel) and iron and steel are among the priorities. Each delegated act will set both the ecodesign requirements and the corresponding DPP content for its group, with application dates expected to allow at least 18 months' lead time from adoption. As of this review, no ESPR delegated act imposing a DPP has yet become applicable — obligations for the priority groups are expected to land in the second half of the decade, but the dates are not fixed until each act is adopted.

Who creates and maintains the passport

The obligation sits with the economic operator placing the product on the market — the manufacturer in the standard case, following the same allocation of roles as CE marking. Non-EU manufacturers act through their importer or authorised representative chain in the usual way. The operator may commission a DPP service provider to host the data, but responsibility for its accuracy and availability remains with the operator. Passports must be kept up to date where the underlying information changes, and — in the battery case — updated with in-life data by the operators best placed to provide it.

For distributors and marketplaces, the practical duty will be verification that the data carrier is present, parallel to today's duty to check that CE marking and documentation are in place.

Relationship to CE marking and technical documentation

The DPP is not a conformity mark and does not replace CE marking. The division of function is:

• CE marking remains the visible claim of conformity with the applicable harmonisation legislation, affixed under the rules in affixing the CE mark.
• Technical documentation remains the manufacturer's internal evidence file, held for ten years and produced to authorities on request. The DPP does not publish the technical file; it publishes selected data fields drawn from it.
• The DPP is the distribution channel for product data — compliance references, substance data, performance and circularity information — to consumers, authorities, and the repair and recycling chain.

The toy sector shows the direction of travel: there, the DPP absorbs the Declaration of Conformity's accompanying-document role. Whether other sectors follow — whether the DoC generally migrates into the passport — is a policy direction that has been signalled but not enacted; for every CE act other than the Toy Safety Regulation, the DoC obligations stand unchanged today. ESPR ecodesign requirements themselves, where they apply to a CE-marked product, become part of the compliance basis just as RoHS or the Ecodesign Regulation framework already are for electrical equipment.

Open questions

• Content per product group — unknown until each delegated act is adopted; the working plan names groups, not data fields.
• Granularity — item-level versus model-level passports will be decided per group; the battery passport is item-level, which is not necessarily the template for low-value goods.
• Technical standards — European standardisation work on DPP data exchange, identifiers, and access control is under way but not complete; operators building systems now are working against draft specifications.
• SME arrangements — the ESPR provides for SME support measures, but their concrete shape per product group depends on the delegated acts.

Sources

• Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products — EUR-Lex.
• Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries, Article 77 (battery passport) — EUR-Lex.
• Regulation (EU) 2025/2509 of the European Parliament and of the Council on the safety of toys — EUR-Lex.
• European Commission — Ecodesign for Sustainable Products Regulation portal, including the 2025–2030 working plan.