Digital Product Passport Guide

DPP solutions prepare a business for the European Union Digital Product Passport introduced by the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, and for the EU battery passport under the Battery Regulation (EU) 2023/1542. The work covers mapping the product against the priority groups, assembling the product level data a passport needs across the supply chain, securing the unique identifiers, preparing a machine readable data carrier such as a QR code, and setting the data governance that keeps the record accurate, complete and up to date for the European market.

A Digital Product Passport is a structured electronic record holding information about a product across its life, such as material composition, recycled content, substances of concern, durability, repair and end of life information. Under the Ecodesign for Sustainable Products Regulation the passport is linked to a unique product identifier, reached by scanning a machine readable data carrier on the product, and kept accurate, complete and up to date. It is read by actors along the value chain, including consumers, repairers, recyclers, market surveillance and customs, each according to their access rights.

The Ecodesign for Sustainable Products Regulation has been in force since 18 July 2024, but the framework itself sets no general passport deadline. The Digital Product Passport becomes mandatory product group by product group, only when a product-specific delegated act under Article 4 is adopted and applies. The first Working Plan, adopted on 16 April 2025, gives indicative adoption years for the priority groups across 2026 to 2029, but these are planning dates rather than law, and as of June 2026 no product-specific delegated act has been adopted. The one passport already fixed in dated law is the EU battery passport, which applies from 18 February 2027.

The first Ecodesign Working Plan, COM(2025) 187 final adopted on 16 April 2025, names the priority product groups for delegated acts: textiles with a focus on apparel, furniture, tyres, mattresses, iron and steel, and aluminium, alongside horizontal measures on repairability and on the recyclability and recycled content of electrical and electronic equipment. The Working Plan gives indicative adoption years from around 2026 for iron and steel to around 2029 for mattresses, with a mid-term review in 2028. The binding obligation for any group starts only when its delegated act is adopted and applies.

Under Article 77 of the Battery Regulation (EU) 2023/1542, the battery passport applies from 18 February 2027 to each light means of transport battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the European market or put into service. It does not cover every battery; portable and consumer batteries below those thresholds are outside the Article 77 passport. Access is tiered, with some information public, some restricted to notified bodies, market surveillance and the Commission, and some reserved to persons with a legitimate interest such as repairers and recyclers.

Yes. The Ecodesign for Sustainable Products Regulation applies to products placed on the European market or put into service regardless of where they are manufactured. An Indian exporter of a covered product, such as a battery, a textile or a steel or aluminium product, must provide a compliant passport once a delegated act covers that product group. India has no domestic Digital Product Passport law, so the obligation is the European Union and the work is export readiness, preparing the product data and identifiers ahead of each European deadline.

The Ecodesign for Sustainable Products Regulation requires the European Commission, by 19 July 2026, to set up and manage a secure central registry that stores at least the unique identifiers of covered products and the commodity code for goods released for free circulation, including the identifiers for batteries. A publicly accessible web portal is also required so stakeholders can search and compare passport data within their access rights. Once the registry is operational, the unique registration identifier must be supplied to customs at release for free circulation, and customs may release the product only after the identifier and commodity code match the registry.

The Ecodesign for Sustainable Products Regulation requires the passport to be reached through a machine readable data carrier on the product, such as a QR code, linked to a unique product identifier. The specific data carrier and the technical specifications are left to the delegated and implementing acts for each product group, so no single carrier or technical standard is fixed in the framework itself. A readiness review prepares a machine readable carrier and the unique identifiers in line with the standards referenced in Annex III, ready for the requirements that each delegated act will set.

No single figure fits, because the cost is driven by the work each business actually faces rather than a fixed fee. The main drivers are data readiness, how complete and traceable the product level data already is across the supply chain; the number of distinct product lines and models that each need their own passport record; the product group involved and the requirements its delegated act sets, with the dated battery passport carrying the most defined demands; the depth of the supply chain and the number of tiers that must supply material composition, recycled content and substances of concern data; and whether identifiers, a data carrier and ongoing data governance are built once or maintained across many products. A readiness review scopes these drivers against the specific product and the European market it serves before any work is sized.

The Ecodesign for Sustainable Products Regulation prohibits, from 19 July 2026, the destruction of unsold apparel, clothing accessories and footwear listed in Annex VII. The prohibition does not apply to micro and small enterprises and extends to medium-sized enterprises only from 19 July 2030. Operators that discard unsold consumer products must also disclose annually the number, weight and reasons for the discarded goods and the treatment routes. This obligation sits alongside the Digital Product Passport within the same regulation and matters most to exporters that hold unsold stock in the European market.

The Ecodesign for Sustainable Products Regulation does not fix a single European Union fine. Article 74 requires each Member State to set penalties that are effective, proportionate and dissuasive, so the exact amounts differ by country. For an exporter the harder consequence is market access: a covered product without a compliant, registry-matched passport can be refused release for free circulation by European customs once the registry is operational, and a non-compliant battery cannot lawfully be placed on the European market from 18 February 2027. The commercial risk of blocked shipments is usually the larger exposure.

The two rest on different regulations. The Digital Product Passport is the broad framework introduced by the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, which is rolled out product group by product group through delegated acts, with the priority groups named in the first Working Plan but no product-specific delegated act adopted as of June 2026. The battery passport is the one passport already fixed in dated law: under Article 77 of the Battery Regulation (EU) 2023/1542 it is mandatory from 18 February 2027 for light means of transport batteries, electric vehicle batteries and industrial batteries with a capacity greater than 2 kWh. In short, the battery passport is a specific, dated obligation, while the Digital Product Passport is the wider ESPR framework whose timing follows each delegated act.

For goods imported into the European Union the importer is the economic operator responsible for ensuring a compliant Digital Product Passport is available for the products placed on the EU market, and that the required documentation is available to authorities. Where the manufacturer is established outside the European Union, including in India, the obligations attaching to placing the product on the market fall on the importer, or on an authorised representative where one is designated. The operator placing the product on the market must also keep a back-up copy of the passport available through an independent third-party service provider. For an Indian exporter this means the duty sits with the EU entity that places the goods, and where the goods are supplied to EU brands and importers, those operators carry the duty and will demand the product level data, identifiers and carrier from the supplier.