The European Union is progressively introducing Digital Product Passports (DPPs) across a growing range of industries. For manufacturers, brand owners and importers, this raises three fundamental questions: Will my products need a Digital Product Passport? When will it become mandatory? And what should my company do today to prepare?
The answers are not always straightforward. Some industries already have legally adopted DPP requirements and confirmed application dates. Others have been identified as regulatory priorities, but their detailed obligations are still being developed. Further sectors are covered by separate European legislation that introduces product-specific digital information requirements.
At the time of the last review, the EU DPP framework rests on two main regulatory approaches:
- The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, which progressively introduces product-specific requirements through delegated acts.
- Sector-specific EU legislation, including the regulations on batteries, construction products, toys and detergents, which establish DPP obligations directly.
Related regulations, such as the Packaging and Packaging Waste Regulation (PPWR) and the Critical Raw Materials Act, introduce digital information requirements without necessarily requiring a complete Digital Product Passport. This article gives a consolidated overview of the regulatory landscape, the industries concerned, the expected milestones and the practical steps businesses can take now.
1. EU Digital Product Passport: regulatory status at a glance
The table summarises the main product categories and the expected developments at the time of the last regulatory review (9 October 2026).
| Industry | Regulatory status | Next major milestone | Mandatory DPP |
|---|---|---|---|
| Batteries | Regulation (EU) 2023/1542 adopted; passport requirements defined | Implementing act on access rights (Art. 77(9)), indicative adoption Q4 2026 | 18 February 2027 for LMT, industrial >2 kWh and EV batteries |
| Toys | Regulation (EU) 2025/2509 adopted, in force since 1 January 2026 | Penalties notified by Member States by 1 August 2028 | 1 August 2030 |
| Detergents and end-user surfactants | Regulation (EU) 2026/405 adopted, in force since 22 March 2026 | Implementing act on technical DPP requirements (no fixed date) | 23 September 2029 (general application) |
| Construction products | Regulation (EU) 2024/3110 applies from 8 January 2026, with exceptions | Delegated act on DPP requirements, indicatively Q2 2027 | 18 months after the relevant delegated act |
| Iron and steel | ESPR delegated act in preparation | Indicative adoption 2026 (working plan) | Set by the act; normally not earlier than 18 months after entry into force |
| Textiles and apparel | ESPR delegated act in preparation | Indicative adoption Q3-Q4 2027 | Not yet fixed |
| Aluminium | ESPR delegated act in preparation | Indicative adoption Q3-Q4 2027 | Not yet fixed |
| Tyres | ESPR delegated act in preparation | Indicative adoption Q3-Q4 2027 | Not yet fixed |
| Furniture | ESPR priority; no act yet | Indicative adoption 2028 | Not yet fixed |
| Mattresses | ESPR priority; no act yet | Indicative adoption 2029 | Not yet fixed |
| Electronics and energy-related products | Existing ecodesign rules; horizontal ESPR measures planned | Repairability 2027, recycled content and recyclability of EEE 2029 (indicative) | Depends on future product rules |
| Packaging | Regulation (EU) 2025/40 applies from 12 August 2026 | Harmonised labelling from 12 August 2028 at the earliest | No universal standalone packaging DPP |
| Permanent magnets in specified products | Regulation (EU) 2024/1252 adopted | Implementing act on the label format, due by 24 November 2026 | Label and data carrier duties, not a general full DPP |
Important: the years and quarters shown for future ESPR delegated acts are indicative adoption dates from the Commission's planning, not dates by which businesses must provide DPPs. Under ESPR Article 4(4), a delegated act normally cannot apply earlier than 18 months after it enters into force, except in duly justified cases. The binding compliance dates will be set in each act. Likewise, the existence of a product-specific regulation does not mean that every product in that broad industry is covered.
Let's examine each category, starting with the sectors that already have adopted DPP legislation.
2. Batteries: the first mandatory European Digital Product Passport
Legal basis: Regulation (EU) 2023/1542, Articles 13, 77 and 78, Annex XIII. Status: legally adopted; main passport date confirmed. GoodsTag page: Battery DPP.
Which batteries are concerned?
From 18 February 2027, a battery passport is required under Article 77 for:
- Electric vehicle (EV) batteries
- Light means of transport (LMT) batteries, such as e-bike and e-scooter batteries
- Industrial batteries with a capacity greater than 2 kWh
The 2 kWh threshold is not a universal exemption: LMT batteries are covered regardless of their capacity.
What about all other batteries?
Portable batteries, starting, lighting and ignition (SLI) batteries and industrial batteries of 2 kWh or less do not need an Article 77 battery passport. But every battery must carry a QR code from 18 February 2027 under Article 13(6).
For LMT, industrial batteries above 2 kWh and EV batteries, that QR code links to the battery passport (Article 77(1) and (3)). For all other batteries, it gives access to the label information, the EU declaration of conformity (Article 18) and the waste prevention and end-of-life information of Article 74(1)(a) to (f). For SLI batteries, it also covers the recovered cobalt, lead, lithium and nickel content (Article 13(6)(c)). We explain this in detail in No battery passport needed? The digital battery data behind the QR code. The distinction matters for manufacturers of starter, portable and smaller industrial batteries.
What information must the passport contain?
Annex XIII sets out the battery passport information. Where applicable, it includes:
- Product and manufacturer identification
- Manufacturing information
- Battery chemistry and technical characteristics
- Composition and material information
- Performance and durability characteristics
- Safety and dismantling information
- Carbon footprint information
- Recycled content information
- Conformity documentation
- Individual battery information and lifecycle data
Not every attribute is mandatory on the first day. On 21 August 2026 the Commission published updated, non-binding guidance (the document was last updated on 15 August 2026) that maps 71 data points. Each one is marked as mandatory, optional, applicable only in specific circumstances, or not to be completed or displayed as of February 2027.
What are the next milestones?
Access rights (pending). The implementing act under Article 77(9) on who has a "legitimate interest" in restricted passport data, for example repairers and recyclers, was legally due by 18 August 2026 and is still pending. The Commission expects to publish a draft for public feedback in October or November 2026, with indicative adoption in Q4 2026. The open points are covered in EU battery passport 2027: the open questions.
18 February 2027: mandatory battery passport. Covered batteries placed on the EU market or put into service must have a battery passport.
2027 onward: additional sustainability information. Carbon footprint, recycled content and due diligence requirements follow their own schedules, several of which depend on further legal acts.
What should battery manufacturers do now?
Companies in scope should already be implementing their battery passport architecture: product identification, collection of mandatory data, supplier information, data validation, QR codes, access rights and Registry integration. Manufacturers of batteries outside the passport scope still need to prepare the QR code information.
Recommendation: do not postpone implementation because some technical details are still evolving. Start with the confirmed requirements and choose an architecture that can absorb future attributes and access rules.
3. Toys: Digital Product Passports mandatory from August 2030
Legal basis: Regulation (EU) 2025/2509 on the safety of toys. Status: adopted; entered into force on 1 January 2026. Application: 1 August 2030 (Article 59).
The new Toy Safety Regulation is one of the clearest examples of a sector-specific DPP obligation outside the ESPR delegated-act programme.
Which products are concerned?
The Regulation covers products designed or intended, whether exclusively or not, for use in play by children under 14 years of age (Article 2(1)). Examples include dolls and action figures, construction toys, toy vehicles, educational and activity toys, electronic toys and certain creative-play products. The exact scope follows the Regulation's definition of a toy, and the Regulation itself excludes or lists certain products that are not treated as toys. Not every product marketed to children is automatically a toy.
What will the DPP contain?
Article 19 requires manufacturers to draw up a Digital Product Passport for each toy model, containing the information set out in Annex VI and demonstrating compliance with the applicable requirements. The passport must remain available for 10 years (Article 19(2)(g)). It supports:
- Product identification
- Manufacturer and economic operator information
- Evidence of compliance with the safety requirements
- Conformity information
- Traceability and market surveillance
What are the next milestones?
2026-2028: preparation. The Regulation is in force while manufacturers and authorities prepare for its application. Member States must lay down and notify their penalties by 1 August 2028 (Article 55).
2028-2029: operational readiness. Manufacturers should finalise data collection, model identification, documentation processes and DPP systems before the application date. This is a recommended preparation window, not a statutory milestone.
1 August 2030: mandatory DPP. The Regulation applies, including its Digital Product Passport provisions.
What should toy brands do now?
Toy manufacturers should start structuring their safety and conformity documentation around a consistent digital product identity, connecting technical files and conformity assessment information to product master data. Unlike sectors still waiting for an ESPR delegated act, toy manufacturers already know that a DPP will be mandatory and when.
4. Detergents and surfactants: an adopted DPP framework for 2029
Legal basis: Regulation (EU) 2026/405 on detergents and surfactants. Status: adopted on 11 February 2026, published in the Official Journal on 2 March 2026, in force since 22 March 2026. Application: 23 September 2029 (Article 37, with exceptions). GoodsTag page: Detergents DPP.
This is a major development for the home care and cleaning products sector.
Which products are concerned?
Article 21 introduces a Digital Product Passport for detergents and for surfactants made available to end-users. That can include household cleaning products, laundry and dishwashing detergents and relevant professional or industrial cleaning products. Companies supplying surfactants only as industrial ingredients should check whether their products fall within this DPP scope.
What is different about detergent DPPs?
The passport is established per model (Article 21(2)(a)), and per batch or item only where other Union law requires it (Article 21(7)). The information covers, among other things, the trade name and unique product identifier, manufacturer and importer details, and information demonstrating regulatory conformity.
The passport must remain available for 10 years after the product is placed on the market (Article 21(2)(g)). For products sold through refill stations, the data carrier must also be present on the refill station (Article 21(4)(d)).
What about digital labels?
The Regulation also provides for digital labelling, but a digital label and the Digital Product Passport are not the same legal concept. Some information must remain on the physical label, while other information may be provided digitally under specified conditions.
What are the next milestones?
2026: entry into force. The legal framework is established.
Implementing act on technical requirements. The Commission will lay down the technical DPP requirements by implementing act (Article 21(10)). There is no fixed adoption deadline, and its requirements cannot apply earlier than 18 months after its entry into force, save in duly justified cases.
23 September 2029: general application, subject to the exceptions and transitional rules in the Regulation.
What should detergent manufacturers do now?
Identify formulations, product models, manufacturers, importers and conformity documentation. Brands active in several European markets should also prepare multilingual digital information and manage packaging and label variants.
Recommendation: begin with model-level product identification and structured conformity information, then add the final technical requirements once adopted.
5. Construction products: a dedicated DPP framework with sector-specific complexity
Legal basis: Regulation (EU) 2024/3110, Articles 75 to 80. Status: applies from 8 January 2026, with exceptions (Article 96); the delegated act on DPP requirements is pending.
Which products are concerned?
The revised Construction Products Regulation (CPR) covers construction products within its defined scope, for example cement and other binders, structural metal products, insulation materials, windows and doors, and construction kits and systems. The actual DPP obligations depend on the implementing rules and the harmonised technical specifications.
What makes construction DPPs different?
Construction products already come with extensive documentation: declarations of performance and conformity, technical characteristics, safety information and environmental performance information. The DPP system must also be interoperable with Building Information Modelling (BIM) (Article 75(2)(a)). The passport is linked to the product type and its identification code, so it should not be assumed that every physical component needs an individual serial-level passport.
Are there exemptions?
Article 76(4) links the DPP obligation to the exemption under Article 14: products covered by that exemption are also exempt from the passport. The precise scope must be assessed together with the evolving harmonised technical specifications.
What are the next milestones?
8 January 2026: CPR applies, with the exceptions set out in Article 96.
Q2 2027: delegated act (indicative). The Commission's indicative timeline lists a CPR delegated act on DPP requirements for construction products for Q2 2027. This is a planning target, not a guaranteed date.
18 months after the delegated act: DPP obligation. Under Article 22(7) and Article 80(1), the manufacturer's passport obligation applies 18 months after the relevant delegated act. The rollout must also be read against the applicable technical specifications and transitional provisions.
What should construction manufacturers do now?
Start organising product type identifiers, declarations of performance and conformity, technical specifications, supporting documents and environmental data. Much of this information already exists, but is spread across PDFs, ERP systems, product catalogues and compliance repositories.
Recommendation: focus first on structuring existing product and environmental documentation rather than generating large numbers of individual passports before the final rules are known.
6. Iron and steel: the next major DPP sector
Legal basis: ESPR, Regulation (EU) 2024/1781. Status: product-specific delegated act in preparation. Indicative adoption: 2026 in the ESPR working plan (COM(2025) 187). GoodsTag page: Iron and steel DPP.
Which products could be concerned?
Iron and steel are among the first intermediate products selected in the ESPR working plan. The scope will be defined by the delegated act and could cover selected primary and intermediate steel products. It should not be assumed that every finished product containing steel will need its own steel DPP.
What information is likely to matter?
Likely areas include material and product grade, product identification, manufacturing information, material composition, recycled content, environmental impact information and conformity and technical documentation. These are areas of probable relevance, not a confirmed data checklist.
What are the next milestones?
Adoption of the delegated act will clarify scope, required information and the timetable. Companies will then need to map the final requirements to their production and material data.
Generally at least 18 months later: earliest ordinary application. If the act is adopted in late 2026 and follows the normal rule of Article 4(4), obligations would typically not start before around mid-2028. The binding date will be the one set in the adopted act.
What should companies do now?
Steel producers should identify the relevant material, production, traceability and sustainability information across their systems. Downstream manufacturers should determine which steel-related information they can obtain from suppliers.
7. Textiles and apparel: one of the most anticipated DPP regulations
Legal basis: ESPR, Regulation (EU) 2024/1781. Status: delegated act in preparation. Indicative adoption: 2027 in the working plan; the Commission's DPP page now shows Q3-Q4 2027. GoodsTag page: Fashion DPP.
Which products are likely to be covered?
Textile apparel is a priority group in the ESPR working plan. The initiative is especially relevant to apparel manufacturers, fashion brands, garment importers, companies sourcing finished garments from third parties, and suppliers of fabric, fibre and production information. Footwear is also an ESPR concern, but its treatment in individual acts should not be assumed before the scope is finalised. A garment DPP is not an automatically adopted DPP for every textile product, carpet, home textile or shoe.
What information might be required?
Possible information areas include fibre composition, product identification, manufacturer and economic operator information, manufacturing and origin information, environmental performance, durability and repairability, care and maintenance, reuse, resale and recycling, and conformity and traceability information. The precise attributes and granularity remain to be defined.
Is there already a related obligation?
Yes. The ESPR ban on destroying unsold consumer products listed in Annex VII, which covers apparel, clothing accessories and footwear, applies from 19 July 2026 (Article 25), subject to derogations. It does not apply to micro and small enterprises, and applies to medium-sized enterprises from 19 July 2030. This is not a DPP obligation, but it shows that some textile-related ESPR provisions already apply even though the textile delegated act has not been adopted.
What are the next milestones?
2026-2027: technical studies and regulatory preparation.
Q3-Q4 2027: indicative adoption of the delegated act, which will clarify scope, data and obligations.
Potentially from 2029: first application window. Assuming adoption in late 2027 and the usual minimum transition of 18 months, application could start around mid-2029 or later. This is not a legally fixed date.
What should fashion brands do now?
Start collecting supply-chain data now. Product information in fashion is spread across suppliers, manufacturers, buying teams and enterprise systems. A useful starting point:
- Product references and identifiers
- Fibre and material composition
- Fabric suppliers and production partners
- Manufacturing locations
- Available sustainability declarations
- Care instructions
- Certifications and supporting evidence
- Repairability and recycling information
Collecting reliable supplier data can take considerably longer than building the passport interface itself.
8. Aluminium: material-level traceability and environmental information
Legal basis: ESPR, Regulation (EU) 2024/1781. Status: delegated act in preparation. Indicative adoption: 2027 in the working plan; Q3-Q4 2027 on the Commission's DPP page.
Which products may be covered?
Aluminium is an intermediate-product priority. The final scope could cover selected aluminium product forms placed on the EU market. It does not automatically mean a separate aluminium passport for every consumer product containing aluminium.
What information may be relevant?
Material grade and composition, origin and production information, recycled content, manufacturing characteristics, environmental performance, and product identification and traceability. Because aluminium production is energy-intensive, energy and recycling information is likely to be especially relevant.
What are the next milestones?
2026-2027: technical and impact assessment work. Q3-Q4 2027: indicative adoption of the delegated act. Generally 2029 onward: possible application window, depending on the final act.
What should aluminium companies do now?
Consolidate composition, product identifiers, production processes and sustainability data. Buyers of aluminium should find out what their suppliers can provide in a structured format.
9. Tyres: durability, performance and circularity
Legal basis: ESPR, Regulation (EU) 2024/1781. Status: delegated act in preparation. Indicative adoption: 2027 in the working plan; Q3-Q4 2027 on the Commission's DPP page.
Which products are concerned?
Tyres are an explicit ESPR priority. The exact product categories will be defined by the delegated act. A future DPP may complement existing obligations under the Tyre Labelling Regulation, Regulation (EU) 2020/740.
Which information could be relevant?
Product model and manufacturer, tyre characteristics, performance and durability, material information, environmental indicators, retreading and recycling information, and existing label information. The final content has not been established.
What are the next milestones?
2026-2027: preparation of the product rules. Q3-Q4 2027: indicative adoption. Generally 2029 onward: possible compliance window, subject to the adopted act.
What should tyre manufacturers do now?
Consolidate technical, manufacturing and performance information. Do not assume that existing labelling or registration systems automatically satisfy a future DPP requirement, although they can be a useful data foundation.
10. Furniture: another major product category
Legal basis: ESPR, Regulation (EU) 2024/1781. Status: priority product group; no delegated act yet. Indicative adoption: 2028. GoodsTag page: Furniture DPP.
Which products could be concerned?
Furniture is a priority final product group. Relevant categories could include chairs and seating, tables and desks, cabinets and storage furniture, and domestic and office furniture within the final scope. Requirements will not necessarily be identical for every product.
What information might be relevant?
Materials and components, material origin, dimensions and characteristics, durability, repairability, disassembly, spare parts, recycled materials, and reuse and end-of-life treatment. The exact requirements are still under development.
What are the next milestones?
2026-2027: preparatory studies and impact assessment. 2028: indicative adoption of the delegated act. Generally from 2030: possible application, subject to the final act and transition period.
What should furniture brands do now?
Start structuring bills of materials and supplier information, especially for products combining wood, metal, plastics, foam, textiles and adhesives. For many furniture manufacturers, the hardest part will be obtaining consistent material and component data from suppliers.
11. Mattresses: a separate product priority
Legal basis: ESPR, Regulation (EU) 2024/1781. Status: priority group; no delegated act yet. Indicative adoption: 2029.
Although often grouped commercially with furniture, mattresses appear separately in the ESPR working plan. The scope will be set by the future act and may cover mattress categories for consumer or professional use. Potential information areas include product composition, foam, textile, spring and other component materials, durability, repair and refurbishment, disassembly, and recycling and end-of-life information.
Milestones: preparatory work in 2026-2028, indicative adoption in 2029, and generally application from 2031 at the earliest, depending on the final act. Manufacturers can already start collecting material and component information, with attention to supplier technical data and recyclability.
12. Electronics, ICT products and energy-related equipment
Legal basis: ESPR and existing ecodesign and energy labelling legislation. Status: product-specific work ongoing.
Which products may be affected?
This broad category may involve selected consumer electronics, ICT equipment, small household appliances and other energy-related products already subject to ecodesign requirements. The working plan continues work on several product groups from the existing ecodesign programme and adds horizontal measures: repairability (indicatively 2027) and recycled content and recyclability of electrical and electronic equipment (indicatively 2029).
Existing labels are not automatically DPPs
A refrigerator or washing machine may already be subject to energy labelling or ecodesign requirements. That does not mean it currently needs a Digital Product Passport under the ESPR. Likewise, EPREL registration and the future DPP system are different obligations.
What are the next milestones?
2026-2029: product-specific ecodesign work for selected equipment categories. 2027 (indicative): horizontal repairability requirements, possibly including scoring approaches, with scope still to be refined. 2029 (indicative): horizontal recycled content and recyclability measures for selected electrical and electronic equipment. DPP obligations and their dates will depend on the final legal acts.
What should electronics brands do now?
Improve the quality and accessibility of technical specifications, bills of materials and component data, repair and spare-part information, compliance documentation, material and recycled content information, and energy and environmental performance data.
Recommendation: build an extensible product information architecture rather than assuming that one universal electronics DPP template already exists in law.
13. Packaging and PPWR: digital information without a universal packaging DPP
Legal basis: Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation. Status: applies from 12 August 2026 (Article 71). GoodsTag page: PPWR packaging compliance.
Packaging affects companies in almost every industry. However, the PPWR does not require a full ESPR-style Digital Product Passport for every package. It introduces labelling, information and digital data requirements that vary with packaging format, material and function, and apply to sales, grouped and transport packaging placed on the EU market.
What digital information is required?
Article 12 sets out harmonised packaging labelling. For reusable packaging, it provides for access to information through a QR code or other standardised digital data carrier.
What are the next milestones?
12 August 2026: the PPWR applies.
12 August 2028, or 24 months after the implementing acts under Article 12(6) and (7) enter into force, whichever is later: harmonised labelling under Article 12(1).
12 February 2029, or 30 months after the Article 12(6) implementing act enters into force, whichever is later: QR code or digital data carrier on reusable packaging under Article 12(2).
Can companies combine DPP and PPWR information?
Yes, and in some cases they must. Article 12(5) addresses situations where Union law requires information about the packaged product to be provided through a data carrier. In that case, "a single data carrier shall be used for providing the information required for the packaged product and for the packaging, and both shall be easily distinguishable" (fourth subparagraph). Mandatory packaging information provided electronically must also not be displayed together with sales or marketing information (third subparagraph, point (b)).
What should brands do now?
Organise packaging information alongside product data:
- Packaging materials and components
- Packaging composition and weights
- Reusability characteristics
- Recycling and sorting information
- Packaging suppliers
- Product-to-packaging relationships
Recommendation: avoid building a disconnected digital infrastructure for packaging. A shared information architecture can serve several obligations, provided the legal distinctions are respected.
14. Permanent magnets and critical raw materials
Legal basis: Regulation (EU) 2024/1252, the Critical Raw Materials Act (CRMA). Status: adopted; implementation depends on further acts.
Which products are affected?
Article 28(1) lists the products concerned: magnetic resonance imaging devices, wind energy generators, industrial robots, motor vehicles, light means of transport, cooling generators, heat pumps, electric motors (including those integrated in other products), automatic washing machines, tumble driers, microwaves, vacuum cleaners and dishwashers. Applicability depends on the product and the magnets it contains.
Does this mean a full DPP is mandatory?
Not automatically. The CRMA requires a label and a data carrier for products incorporating permanent magnets. The data carrier links to a unique product identifier (Article 28(4)), and where another Union act requires a product passport, the information goes into that existing passport (Article 28(6)). The magnet rules should not be presented as a requirement to issue a complete ESPR passport for every listed product.
What are the next milestones?
By 24 November 2026: implementing act on the label format (Article 28(2)). The label and data carrier duties apply two years after that act enters into force. For MRI devices, motor vehicles and L-category light means of transport, they apply from 24 May 2029 (Article 28(10)).
Recycled content disclosure (Article 29). Article 29 is first a disclosure duty: manufacturers must publish the share of recovered neodymium, dysprosium, praseodymium, terbium, boron, samarium, nickel and cobalt in permanent magnets weighing more than 0.2 kg. It applies from 24 May 2027 or two years after the delegated act on the calculation method, whichever is later. Minimum recycled shares are to follow later through delegated acts, by 31 December 2031.
What should companies do now?
Identify products containing relevant permanent magnets and collect information on magnet types, materials, weights and recycled content. This also supports future DPP initiatives for the finished products.
15. Which industries are outside the ESPR framework?
The ESPR has a broad scope, but it is not universal. Article 1(2) excludes:
- (a) food;
- (b) feed;
- (c) medicinal products;
- (d) veterinary medicinal products;
- (e) living plants, animals and micro-organisms;
- (f) products of human origin;
- (g) products of plants and animals relating directly to their future reproduction;
- (h) vehicles under Regulations (EU) No 167/2013, No 168/2013 and (EU) 2018/858, for the product aspects covered by sector-specific Union law.
These exclusions concern the ESPR only. They are not exemptions from every other EU information or traceability obligation: a food company still has packaging obligations under the PPWR, and an electric vehicle's battery needs a battery passport even though the vehicle itself is covered by separate legislation.
What about cosmetics, paints, lubricants and chemicals?
These sectors do not all have adopted mandatory DPP rules. Although the ESPR's framework and prioritisation criteria include certain chemical and consumer product categories, not all were retained for product-specific measures in the 2025-2030 working plan. Companies in these industries should monitor future work programmes and sector developments, and should not assume that a mandatory DPP date already exists.
16. Does every product need its own individual passport?
Not necessarily. Depending on the product category, a passport may correspond to a product model, a production batch or an individual item. The Batteries Regulation requires a passport per individual battery for covered batteries. The detergents and toy regulations define passports at model level, and under the ESPR each delegated act specifies the granularity.
This has major consequences for implementation cost, identifiers, QR code management and data architecture. Manufacturers should not invest in item-level serialisation across the board before confirming the requirements for their product category.
17. Who is responsible for creating the DPP?
The responsible actor depends on the sector legislation and on the economic operator's legal role. In many cases, the operator placing the product on the EU market carries the central obligations: the manufacturer, brand owner or another economic operator.
A company producing goods for another brand is not automatically responsible for the passport just because it physically makes the product. A technology provider hosting the DPP does not become responsible for the accuracy of the manufacturer's declarations either. Brands working with OEM or private-label manufacturers should clarify roles and data-sharing responsibilities early. We go into the details in Who is responsible for the Digital Product Passport?
18. Do not wait for the delegated act to begin preparing
For industries without a final delegated act, waiting for the exact requirements may seem reasonable. Why collect information before knowing what will be mandatory? The problem is that implementing a Digital Product Passport is not primarily a software project.
For many companies, the longest and most complex task is identifying, collecting, checking and maintaining product information across suppliers and internal systems. A brand sourcing from many manufacturers may need months to obtain reliable data on something as basic as material composition and manufacturing locations.
Preparation should remain proportionate, though. Collect broadly reusable information first and avoid imposing expensive, highly specific reporting requirements that have not yet been defined.
19. Start by building a DPP-ready product data foundation
Across the adopted regulations and the ESPR's published principles, several recurring information categories are already visible:
| Data category | Examples of information worth preparing |
|---|---|
| Product identification | Product model, SKU, GTIN or other identifiers |
| Economic operators | Manufacturer, brand owner, importer and supplier identities |
| Manufacturing | Manufacturing locations, production partners and production information |
| Materials | Material and component composition, with source and evidence |
| Technical characteristics | Dimensions, performance, specifications and product-specific attributes |
| Sustainability | Available carbon, recycled content and environmental data |
| Compliance | Declarations, test reports, certificates and regulatory documents |
| Circularity | Durability, repair, maintenance, disassembly and recycling information |
| Supporting documents | Manuals, instructions, technical files and related digital resources |
| Data governance | Source, owner, validation status, version and access permissions |
This is a recommended preparation framework, not a legally mandatory attribute list. The exact requirements will differ between batteries, garments, furniture, detergents, toys and other products.
Collect evidence, not just values
Recording that a product contains 40% recycled material is useful. But companies should also know who supplied the figure, which material or component it describes, how it was calculated, whether supporting documentation exists, when it was last verified, and whether it applies to a model, a batch or an individual product. A spreadsheet of unverified supplier claims is not a reliable compliance foundation.
20. Map data ownership across your supply chain
Next, determine which organisation or system can provide each data element:
| Data | Likely source |
|---|---|
| Product model and commercial references | ERP or PIM |
| Material composition | Supplier, manufacturer or PLM |
| Manufacturing site | OEM, factory or production system |
| Technical performance | Engineering or quality department |
| Certifications and test reports | Compliance or quality team |
| Carbon footprint information | Sustainability team, suppliers or LCA tools |
| Instructions and repair information | Technical documentation team |
| Packaging data | Packaging development and suppliers |
This mapping shows both available and missing information. A useful readiness indicator is the share of required or anticipated attributes for which the company has a reliable source. For sectors without final rules, it can be measured against an internal provisional dataset and updated as legislation develops.
21. Establish supplier data collection processes early
For brand owners, supplier collaboration often determines DPP readiness, especially in international and fragmented supply chains such as textiles, furniture, consumer products and electronics. Practical steps include:
- Creating a common supplier questionnaire
- Defining consistent data formats
- Identifying evidence requirements
- Establishing responsibilities for data accuracy
- Agreeing how updates are communicated
- Defining access to commercially sensitive information
Suppliers should not be asked for every possible future environmental indicator at once. Prioritise information that is likely to stay relevant and feasible to obtain. The goal is a repeatable process, not a one-off data collection exercise.
22. Choose a flexible, standards-based DPP architecture
The European DPP framework emphasises interoperability, standardised identifiers, structured information and long-term availability, and its common infrastructure is now taking shape.
The EU DPP Registry. Commission Implementing Regulation (EU) 2026/1778 was adopted on 16 July 2026, published on 17 July 2026 and entered into force on 6 August 2026. The Registry went live on 20 July 2026, together with a testing environment. What it checks is covered in The EU DPP Registry: what it validates.
Harmonised standards. Implementing Decision (EU) 2026/1736, adopted on 14 July and published on 15 July 2026, cites six harmonised standards: EN 18216 (data exchange protocols), EN 18219 (unique identifiers), EN 18220 (data carriers), EN 18221 (storage, archiving and persistence), EN 18222 (APIs) and EN 18223 (system interoperability). The remaining standards, for example on access rights and security, are still in progress.
This shared architecture lets companies prepare even before their product-specific obligations are final.
What should the platform support?
A future-ready solution should be able to:
- Manage multiple product categories
- Support model, batch and item-level identification
- Create structured, machine-readable product records
- Integrate with existing ERP, PIM and PLM systems
- Collect data from suppliers
- Validate data
- Manage different access permissions
- Track changes and version history
- Connect product identifiers to digital information through data carriers
- Register with the EU DPP Registry where required
- Preserve and export data in interoperable formats
A modular architecture is particularly valuable for companies active in several industries. A business may need a battery passport for an industrial battery, a future DPP for a connected appliance and PPWR information for its packaging. That should not mean three independent product information platforms.
23. What should companies avoid doing too early?
Preparation matters, but premature implementation creates unnecessary costs. In sectors awaiting delegated acts, avoid:
Assuming the final attribute list is already known. Requirements may change after impact assessments and consultations.
Serialising every product without a regulatory or business need. The required granularity may be model-level rather than item-level.
Building rigid custom data structures. A system designed around an early draft or pilot schema can be expensive to adapt.
Treating an attractive web page as a complete DPP solution. Compliance may require structured data, interoperability, controlled access, registration and long-term availability.
Making unsupported environmental claims. Incomplete or unverified carbon and recycled content data creates compliance and reputational risks.
Waiting until the deadline to involve suppliers. Supplier data quality will not improve on its own when a delegated act is published.
A phased implementation is generally more effective.
24. A practical DPP preparation roadmap for brands
Companies without an immediate legal deadline can start with a structured readiness programme.
Phase 1: understand your regulatory exposure
Identify all relevant product categories and determine whether they fall under adopted DPP legislation, an ESPR priority or related digital information requirements. For each, document the regulation, its status, the next expected milestone and the responsible internal team.
Phase 2: assess existing product data
Take a representative sample of products, identify the data available in ERP, PIM, PLM, technical documentation and supplier systems, and assess its quality, completeness and gaps.
Phase 3: launch supplier data collection
Develop a standard process for collecting priority attributes and supporting evidence, starting with a pilot group of suppliers before expanding.
Phase 4: build a pilot Digital Product Passport
Create a provisional DPP for one or more representative products with the information available today. This does not establish conformity with future rules; its purpose is to validate identification, data preparation, integration and publication.
Phase 5: test interoperability and scalability
Check that the solution can handle more products, attributes, suppliers and regulatory categories, and evaluate export, permissions, versioning and integration.
Phase 6: update when the delegated act is adopted
Once the sector rules are final, run a gap analysis between the pilot and the binding requirements, add the required attributes, adjust granularity and complete technical and regulatory validation.
Phase 7: go to production before the compliance date
Use the transition period for supplier onboarding, data verification, training and deployment. The goal is to reach the deadline with an operational data process, not just a newly installed software platform.
25. What should businesses expect between 2026 and 2031?
The first Digital Product Passports are the start of a broader transformation. Several developments are likely to shape the European product information ecosystem:
More product categories. The ESPR working plan adds sectors step by step, each subject to adopted product rules.
More structured sustainability information. Carbon footprint, recycled content, circularity and lifecycle data will matter in more product categories.
Greater supplier participation. Manufacturers and brands will need more reliable information from upstream partners.
More interoperability. Common standards and the EU Registry make data exchange between systems increasingly important.
More operational use of product data. Digital identities can support repair, resale, second life and recycling, beyond regulatory reporting.
Requirements for DPP service providers. ESPR Article 11 (final subparagraph) empowers the Commission to adopt a delegated act on requirements for DPP service providers "and, where appropriate, a certification scheme". The Commission's indicative timeline points to 2027; at the time of the last review, it had not been adopted. See also DPP certified backup provider.
Businesses should expect information requirements to change periodically as legislation, methods and standards evolve. Adaptability is therefore a central requirement for any long-term DPP investment.
26. Final recommendation: prepare the data now, activate compliance when the rules are ready
For brand owners, the key distinction is between regulatory certainty and operational readiness. For batteries, toys and detergents, the core obligation and main compliance date are already set. For textiles, furniture, aluminium, steel and tyres, companies still need to wait for the product-specific rules before treating detailed DPP requirements as binding.
That uncertainty should not prevent meaningful preparation. A company that already understands its product identifiers, material composition, suppliers, manufacturing processes and technical documentation will implement future requirements faster. Invest first in reusable capabilities:
- Reliable product data
- Supplier data collection
- Structured documentation
- Standardised identifiers
- Data governance
- Interoperable digital infrastructure
Do not wait for every delegated act to start preparing. But do not confuse early preparation with confirmed legal obligations. The Digital Product Passport is best approached as a long-term product information capability, not merely a regulatory deadline.
27. How GoodsTag supports Digital Product Passports across industries
GoodsTag provides a Digital Product Passport platform for different industries, product categories and evolving regulatory requirements. It combines product identification, structured data management, system integration and digital information delivery. Instead of one rigid passport format, companies structure product information around their products, data sources and regulatory use cases.
This supports organisations implementing requirements that are already defined, such as the EU battery passport, as well as brands preparing for future ESPR obligations in sectors such as textiles, iron and steel, furniture, detergents and packaging. For sectors whose delegated acts are not yet adopted, the platform can serve as the foundation for collecting, organising and validating product data before the final requirements apply.
Whether you manufacture batteries, textiles, furniture, industrial materials or consumer goods, we can help you assess your requirements and prepare your product data strategy. Contact GoodsTag to discuss your Digital Product Passport project.
Official sources
- European Commission: Digital Product Passport overview and regulatory roadmap
- European Commission: Digital Product Passport FAQ
- Regulation (EU) 2024/1781 (ESPR)
- ESPR and Energy Labelling Working Plan 2025-2030, COM(2025) 187
- Regulation (EU) 2023/1542 on batteries and waste batteries
- European Commission: battery passport guidance
- Regulation (EU) 2024/3110 on construction products
- Regulation (EU) 2025/2509 on the safety of toys
- Regulation (EU) 2026/405 on detergents and surfactants
- Regulation (EU) 2025/40 on packaging and packaging waste (PPWR)
- Regulation (EU) 2024/1252, Critical Raw Materials Act
- Commission Implementing Regulation (EU) 2026/1778 on the DPP Registry
- Commission Implementing Decision (EU) 2026/1736 on harmonised DPP standards
- European Commission: harmonised standards for the Digital Product Passport
Last regulatory review: 9 October 2026. Indicative milestones are based on the Commission's current working plans and may change. This article does not replace a sector-specific regulatory or legal assessment.
