EU Digital Product Passport: Which Economic Operators Need to Act Now?

Updated: 4 October 2026

The EU Digital Product Passport (DPP) is moving from legislation into implementation.

The European Union's DPP Registry became operational on 20 July 2026, harmonised standards supporting the system are being published, and the first major compliance deadline is approaching: 18 February 2027 for certain batteries.

For manufacturers, importers, brands and other economic operators selling products in the European Union, the important question is therefore no longer simply "What is a Digital Product Passport?"

It is:

Does my product need a DPP, when will it become mandatory, and what should my company be doing now?

The answer depends heavily on the product category.

Some economic operators have a firm legal deadline in February 2027. Others, particularly companies dealing with iron and steel, textiles and apparel, aluminium and tyres, should prepare now even though their final product-specific requirements and compliance dates have not yet been established.

What is the EU Digital Product Passport?

The Digital Product Passport is a structured digital record associated with a product, component or material.

It is intended to make regulatory, sustainability and circularity information available digitally to the parties entitled to access it, which can include consumers, businesses, repairers, recyclers, market surveillance authorities and customs authorities.

The principal framework is established by the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR).

Under the ESPR, a DPP can contain information concerning areas such as:

• product identification;
• manufacturer and economic operator information;
• materials and composition;
• sustainability and environmental characteristics;
• repair and maintenance;
• recycled content;
• substances of concern;
• end-of-life and recycling information;
• compliance documentation;
• other product-specific information required by EU legislation.

The exact information will not be identical for every product.

This is an important point for businesses. There is no single universal EU DPP template that applies to every product. The required information, data carrier, level of identification (for example model, batch or individual item), access rights and retention period are determined by the legislation applicable to the relevant product category. (EUR-Lex)

Is a Digital Product Passport already mandatory for every product sold in the EU?

No.

The ESPR does not mean that every product sold in Europe must already carry a Digital Product Passport.

DPP requirements are being introduced progressively.

For products regulated under the ESPR, the European Commission adopts product-specific delegated acts. These acts establish the applicable ecodesign requirements and determine whether a DPP is required for that product group.

The Commission expressly states that inclusion of a product category in the ESPR Working Plan does not automatically make a DPP mandatory for that category.

Instead, the regulatory process determines:

1. which ecodesign requirements will apply;
2. whether a DPP will be required;
3. what information it must contain; and
4. when the legally binding requirements will start applying.

Following adoption of an ESPR delegated act, economic operators are expected to receive a transition period of at least 18 months. (European Commission)

DPP requirements can also arise under separate EU legislation rather than directly through an ESPR delegated act. Examples include the Batteries Regulation and Construction Products Regulation, while other EU legislation is also integrating the DPP architecture. (European Commission)

Who is an "economic operator" under the ESPR?

The term is broader than manufacturer.

Under Regulation (EU) 2024/1781, an economic operator can include a:

• manufacturer;
• authorised representative;
• importer;
• distributor;
• dealer; or
• fulfilment service provider.

The precise responsibility depends on the operator's position in the supply chain and the applicable product legislation. (EUR-Lex)

For DPP purposes, particular attention should be paid to the economic operator placing the covered product on the EU market or putting it into service.

The Commission states that the primary responsibility for creating the DPP and ensuring its accuracy rests with the economic operator placing the relevant product on the EU market. This applies to products manufactured within the EU as well as imported products. (European Commission)

This is particularly important for non-EU manufacturers and brands.

If goods manufactured outside the EU are imported into the Union, the importer and other responsible parties need to establish clearly who is responsible for the applicable DPP obligations rather than assuming that the overseas factory will handle them.

1. Batteries: the most urgent DPP deadline

The most immediate DPP obligation concerns certain batteries.

Under Regulation (EU) 2023/1542 concerning batteries and waste batteries, from 18 February 2027, a battery passport will be required for:

• each electric vehicle (EV) battery;
• each light means of transport (LMT) battery; and
• each industrial battery with a capacity greater than 2 kWh.

This is a firm statutory date rather than merely an indicative date in the ESPR Working Plan. (EUR-Lex)

The economic operator placing the battery on the market is responsible for ensuring that the information in the battery passport is accurate, complete and up to date. The operator may give written authorisation to another operator to act on its behalf. (EUR-Lex)

Who should act now?

Companies should treat DPP preparation as urgent if they manufacture, import or place on the EU market:

• EV batteries;
• e-bike batteries;
• e-scooter and other LMT batteries; or
• industrial batteries exceeding 2 kWh.

The European Commission has already published detailed implementation guidance covering the data points relevant to the battery passport. Its August 2026 guidance brings together 71 data points and explains their applicability across EV, LMT and industrial battery categories. (European Commission)

With the February 2027 deadline approaching, affected companies should already be preparing their battery data, identifiers, QR-code architecture, supply-chain information, internal responsibilities and DPP registration processes.

2. Iron and steel: the next ESPR priority

Iron and steel are among the first priority product groups under the ESPR Working Plan.

The Commission's current indicative timetable foresees adoption of the product-specific delegated act in Q4 2026. (European Commission)

This does not mean that every covered iron or steel product automatically requires a DPP in Q4 2026.

The delegated act will establish the detailed requirements. According to the Commission's general DPP implementation approach, economic operators will have a transition period of at least 18 months following adoption of an ESPR delegated act. (European Commission)

Nevertheless, manufacturers, producers and importers of relevant iron and steel products should begin preparing.

Depending on the final legislation, DPP information may include:

• product identification and classification;
• technical and material information;
• recycled content;
• sustainability-related information;
• compliance documentation; and
• traceability information.

The Commission stresses that the exact information will be determined by the final delegated act. (European Commission)

3. Textiles and apparel: businesses should start preparing now

Textiles and apparel are likely to be one of the most commercially significant applications of the DPP.

The Commission currently plans adoption of the relevant ESPR delegated act in Q4 2027. (European Commission)

Again, 2027 should not be presented as the date on which every garment suddenly requires a DPP.

It is the planned period for adoption of the product-specific rules. The final delegated act will establish the requirements and applicable compliance timeline.

However, textile businesses should not wait until the compliance date to start organising their data.

The Commission indicates that, depending on the final requirements, textile DPP information could include:

• product identification and characteristics;
• fibre composition;
• information on use, repair and maintenance;
• reuse and resale information;
• disassembly, refurbishment and recycling information;
• end-of-life information;
• origin information;
• identification of relevant economic operators;
• sustainability information; and
• documentation relevant to compliance and traceability.

The Commission also makes an important distinction between different actors.

Economic operators placing covered textile products on the EU market or putting them into service will primarily be responsible for making the required DPP available. Depending on the commercial arrangement, this may be the manufacturer, producer or importer.

Distributors and dealers will need to ensure that a DPP is available for products they distribute or sell where the requirement applies. Suppliers and service providers may also have obligations to provide information available to them. (European Commission)

Why apparel brands should start now

The difficult part of DPP compliance is unlikely to be generating a QR code.

The larger challenge is obtaining reliable, structured product data throughout the supply chain.

For a clothing brand, that can involve data held by:

• fibre and yarn suppliers;
• fabric mills;
• dyeing and finishing facilities;
• garment factories;
• component suppliers;
• testing laboratories;
• logistics providers; and
• the brand itself.

Companies that begin structuring this information now will be in a much better position when the final requirements become binding.

4. Aluminium and tyres: 2027 regulatory priority

The Commission's current DPP implementation timeline also identifies aluminium and tyres alongside textiles for sector-specific ESPR delegated acts in Q3-Q4 2027. (European Commission)

Manufacturers, importers and other operators in these sectors should therefore monitor the development of the delegated acts and begin reviewing where the required product and supply-chain information is currently stored.

As with textiles, the eventual legal compliance date will depend on the final legislation. The 2027 date should not be confused with an automatic DPP compliance deadline.

5. Furniture: 2028 priority

Furniture is scheduled for a product-specific ESPR delegated act in 2028 under the Commission's current indicative timetable. (European Commission)

Furniture companies therefore have more time, but manufacturers and brands with complex international supply chains may benefit from starting early.

Relevant data could potentially sit across multiple suppliers covering wood, textiles, foams, metals, coatings, adhesives, plastics and other components. Waiting until the final compliance period to reconstruct this information could create unnecessary difficulties.

6. Mattresses and ICT products: later priorities

The ESPR Working Plan currently places:

• mattresses in 2029; and
• ICT products in 2029.

The Commission's DPP timeline also identifies work concerning recycled-content requirements during this period. (European Commission)

These businesses do not face the same immediate deadline as affected battery operators, but larger manufacturers and importers should consider DPP requirements when designing new product-data systems, traceability processes and supplier documentation procedures.

7. Construction products: a separate DPP framework

Construction products deserve separate treatment.

The new Construction Products Regulation (EU) 2024/3110 establishes a construction digital product passport framework.

The Regulation provides for DPP information that can include:

• declarations of performance and conformity;
• general product information;
• instructions for use;
• safety information;
• technical documentation;
• labels;
• unique identifiers; and
• documentation required under other applicable EU legislation.

The Commission's current implementation timeline anticipates further DPP requirements for construction products during 2027. (EUR-Lex)

Companies in the construction-products sector should therefore follow the CPR implementation timetable separately rather than relying only on the ESPR Working Plan.

The EU DPP Registry is already operational

A major implementation milestone occurred on 20 July 2026, when the European Commission launched the EU Digital Product Passport Registry. (European Commission)

The Registry does not function as one enormous database containing every piece of information contained in every product passport.

Instead, it acts as an EU-level indexing system.

It stores unique identifiers, registration information and required high-level metadata. The more detailed product information remains decentralised and can be stored by the responsible economic operator or a DPP service provider. (European Commission)

Under the ESPR, the economic operator placing the covered product on the market or putting it into service must upload the required information to the Registry. The Registry then generates a unique registration identifier associated with the registered product identifiers. (EUR-Lex)

The operational rules for the Registry are now established by Commission Implementing Regulation (EU) 2026/1778. (EUR-Lex)

The Commission has also published a dedicated DPP Registry User Guide for Economic Operators, updated in September 2026. (European Commission)

This means DPP implementation is no longer theoretical. The EU infrastructure needed to support the system is now being put into practical use.

DPPs will also affect imports and customs

For importers, one of the most significant elements of the ESPR is the connection between the DPP Registry and EU customs controls.

For products covered by an applicable ESPR delegated act and entered for release for free circulation, the unique DPP registration identifier must be provided or made available to customs.

Customs authorities can verify whether the registration identifier and commodity code correspond to the information stored in the Registry. (EUR-Lex)

This makes DPP compliance much more than a consumer-information or sustainability exercise.

For covered imported products, it becomes part of the market-access and customs compliance process.

Online sellers and marketplaces are also affected

DPP obligations will not stop at the physical product.

The ESPR specifically anticipates accessibility before the customer is bound by a contract, including in distance selling.

Where customers cannot physically access the product, the economic operator placing it on the market must provide dealers and online marketplaces with the relevant digital data carrier or unique product identifier so it can be made accessible to potential customers.

The economic operator must also provide the relevant digital copy or webpage link free of charge upon request, within the period prescribed by the Regulation. (EUR-Lex)

This means DPP implementation needs to be considered not only in packaging and product labelling but also in:

• ecommerce product pages;
• marketplace listings;
• product information management systems;
• distributor data feeds; and
• online sales processes.

What will a compliant DPP technically require?

The ESPR establishes several core principles.

A DPP must be linked through a data carrier to a persistent unique product identifier.

Depending on the applicable legislation, the data carrier can be placed on:

• the product;
• its packaging; or
• accompanying documentation.

The applicable delegated act determines the precise placement and level of identification. (EUR-Lex)

The data must also be structured using open and interoperable standards and, where appropriate, be machine-readable, searchable and transferable without vendor lock-in.

Access is role-based. A consumer, customs authority, market surveillance authority, repairer and recycler do not necessarily receive access to exactly the same information.

The ESPR also requires the DPP to remain available for the period specified by the relevant delegated act, including where the economic operator responsible for the passport later becomes insolvent, is liquidated or ceases operating in the EU. (EUR-Lex)

The technical framework has progressed substantially in 2026. In July, the Commission adopted Implementing Decision (EU) 2026/1736 concerning harmonised standards for DPPs. The Commission reports that the standards cover areas including identifiers, interoperability, data carriers, APIs, data exchange protocols and data storage. (EUR-Lex)

A QR code alone is not a Digital Product Passport

This distinction is important.

Adding a QR code to a product does not by itself make the product DPP compliant.

A compliant DPP is a regulatory data architecture involving:

• the required product information;
• the correct unique identifiers;
• an appropriate data carrier;
• applicable EU technical standards;
• structured and interoperable data;
• defined access rights;
• lifecycle management;
• data accuracy and updating;
• DPP Registry registration;
• appropriate storage;
• backup arrangements; and
• the product-specific requirements established by applicable EU legislation.

The QR code or other data carrier is essentially the physical-digital connection to that system.

Businesses should therefore be cautious about commercial services that describe an ordinary QR-code product webpage as an "EU-compliant Digital Product Passport" without assessing the applicable legislation and technical requirements.

Which companies should act now?

As of October 2026, EaseCert recommends dividing businesses into three practical groups.

Immediate action required

Manufacturers, importers and other responsible economic operators for EV batteries, LMT batteries and industrial batteries above 2 kWh.

The legal deadline is 18 February 2027.

These companies should already be implementing their battery passport systems.

DPP readiness should start now

Businesses dealing with:

• iron and steel;
• textiles and apparel;
• aluminium;
• tyres; and
• relevant construction products.

These sectors are at the front of the EU's next implementation phases.

There may not yet be a final DPP compliance deadline for every product in these categories, but waiting for the final deadline before collecting supply-chain information creates unnecessary compliance risk.

Monitor and build DPP readiness into product systems

Businesses dealing with:

• furniture;
• mattresses;
• ICT products;
• other energy-related products; and
• product groups that may become subject to DPP requirements under separate EU legislation.

For these companies, immediate creation of a legally compliant DPP may be premature unless specific legislation already requires it. However, product-data systems and supplier-documentation processes should increasingly be designed with future DPP requirements in mind.

What should economic operators do now?

Businesses do not need to guess what their final DPP will contain. They should instead establish the infrastructure needed to comply once the product-specific requirements become applicable.

A sensible DPP readiness programme should include the following steps:

1. Determine the applicable product legislation.
   Establish whether the product falls under the ESPR, Batteries Regulation, Construction Products Regulation or another EU framework introducing DPP requirements.
2. Determine the company's economic operator role.
   Identify the manufacturer, importer, authorised representative, distributor and other relevant parties, and determine who actually places the product on the EU market.
3. Map products and product groups.
   Establish SKUs, models, variants, batches and other identifiers and determine how these relate to the likely DPP level.
4. Map the supply chain.
   Identify factories, material suppliers, component suppliers and other parties holding information that may eventually need to enter the DPP.
5. Perform a data-gap assessment.
   Compare existing technical documentation, material information, testing, traceability and sustainability data against known and anticipated DPP requirements.
6. Establish reliable identifiers.
   Product, operator and facility identification will be fundamental to DPP architecture.
7. Plan the physical data carrier.
   Consider how the QR code or other required carrier can be incorporated into the product, packaging or accompanying documentation without creating costly packaging changes later.
8. Prepare digital product information.
   Information should be structured and maintainable rather than stored only across PDFs, emails and supplier spreadsheets.
9. Prepare for Registry registration.
   The EU DPP Registry is already operational. Businesses in the first regulated categories should become familiar with its organisation enrolment and registration processes.
10. Establish ongoing responsibility.
    DPP compliance does not end when a QR code is printed. Information must remain accurate, complete, available and appropriately updated throughout the required lifecycle.

Do non-EU manufacturers need to prepare?

Yes.

The DPP framework is based primarily on products being placed on the EU market, not simply on where the manufacturer is established.

A manufacturer in the United States, United Kingdom, China, Australia or another non-EU country can therefore be affected when its covered products are sold into the European Union.

The EU importer and other economic operators will also need to understand their responsibilities.

For international brands, this makes early contractual allocation of DPP responsibilities important. The company should establish who collects the information, who verifies it, who creates the DPP, who registers it, who maintains it and who responds if a market surveillance or customs authority identifies a problem.

The DPP should be integrated with existing EU compliance documentation

Businesses should avoid treating the DPP as a completely separate compliance project.

A large amount of the information needed for future DPPs may already exist within:

• technical files;
• bills of materials;
• declarations of conformity;
• supplier declarations;
• test reports;
• REACH documentation;
• product labels;
• traceability records;
• instructions and safety information;
• sustainability documentation; and
• existing product databases.

The more effective approach is therefore to build DPP readiness into the company's existing EU product compliance system.

For companies already preparing technical documentation under EU product legislation, this can substantially reduce duplication.

How EaseCert can help

EaseCert supports manufacturers, brands, importers and online sellers preparing for the EU Digital Product Passport framework.

Our EU Digital Product Passport (DPP) Service is available for €500 and is designed to help businesses assess and prepare their product information for the emerging EU DPP requirements.

Depending on the product and applicable legislation, support can include:

• determining whether and when the product is expected to require a DPP;
• identifying the responsible economic operator;
• reviewing applicable EU legislation;
• assessing existing technical and supply-chain documentation;
• identifying missing product data;
• structuring relevant DPP information;
• supporting product and economic operator identification;
• preparing for QR/data-carrier implementation;
• supporting DPP Registry readiness; and
• aligning DPP preparation with existing EU product compliance documentation.

For product groups where the final delegated act has not yet been adopted, the service should be understood as DPP readiness and preparation. Final legal requirements can only be confirmed once the applicable EU legislation has been adopted.

EU Digital Product Passport (DPP) Service

Prepare your products and supply-chain documentation for the EU Digital Product Passport framework with EaseCert.

Learn more about EaseCert's EU Digital Product Passport Service

For a detailed introduction to the system, see our EU Digital Product Passport Guide.

Conclusion

The EU Digital Product Passport is no longer a distant policy concept.

The technical and regulatory infrastructure is now being deployed. The EU DPP Registry has been operational since July 2026, the first harmonised standards have been adopted, and the first major mandatory passport deadline arrives on 18 February 2027 for certain batteries. (European Commission)

For most other consumer products, however, businesses should avoid the opposite mistake of assuming that a DPP is already mandatory simply because their sector appears in the ESPR Working Plan.

The correct approach is product-specific.

Battery economic operators affected by the February 2027 deadline need to implement now. Iron and steel, textile and apparel, aluminium, tyre and construction-product businesses should closely follow the legislation and begin building DPP-ready product data. Furniture, mattress, ICT and other manufacturers should incorporate future DPP requirements into their longer-term compliance and data-management systems.

The companies best prepared for DPP compliance will not necessarily be those that create the first QR code. They will be those that know what they manufacture, where it comes from, which economic operator is responsible, what information supports compliance, and how that information can be maintained throughout the product lifecycle.

Official EU Sources

The following official European Union sources were used for this article:

• Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR), including Articles 9-15 concerning the Digital Product Passport, Registry and customs controls: EUR-Lex, Regulation (EU) 2024/1781
• European Commission, Digital Product Passport portal, including the current implementation timeline and sector roadmap: European Commission, Digital Product Passport
• European Commission, DPP guidance for economic operators, including economic operator responsibilities and the indicative product schedule: Digital Product Passport for Economic Operators
• European Commission, DPP Frequently Asked Questions, including clarification that inclusion in the ESPR Working Plan does not automatically create a DPP obligation: Digital Product Passport FAQs
• Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187 final: EUR-Lex, ESPR Working Plan 2025-2030
• Batteries Regulation (EU) 2023/1542, particularly Article 77 establishing the battery passport and the 18 February 2027 deadline: EUR-Lex, Regulation (EU) 2023/1542
• European Commission, Digital Batteries Passport guidance, including the August 2026 data-point guidance: Guidance to Support Preparations for the Digital Batteries Passport
• European Commission, DPP for Textile Apparel, including the current Q4 2027 delegated-act timetable and anticipated information categories: Digital Product Passport for Textile Apparel
• European Commission, DPP for Iron and Steel, including the current Q4 2026 delegated-act timetable: Digital Product Passport for Iron and Steel
• Commission Implementing Regulation (EU) 2026/1778, establishing implementation arrangements for the EU DPP Registry: EUR-Lex, Implementing Regulation (EU) 2026/1778
• Commission Implementing Decision (EU) 2026/1736, concerning harmonised standards for Digital Product Passports: EUR-Lex, Implementing Decision (EU) 2026/1736
• European Commission, DPP Registry, explaining registration, identifiers, decentralised storage and enforcement functions: EU Digital Product Passport Registry
• European Commission, DPP Registry launch, 20 July 2026: Digital Product Passport Registry is Now Live
• Construction Products Regulation (EU) 2024/3110, including the construction digital product passport provisions: EUR-Lex, Regulation (EU) 2024/3110

Regulatory note

This article reflects the EU regulatory position as of 4 October 2026. DPP implementation is developing through delegated and implementing acts. Businesses should assess the legislation applicable to their specific product before determining their compliance obligations.