Digital Product Passport Guide

The passport is linked to the product through a unique product identifier, held in a QR code or other data carrier on the product, its packaging or its documents. Customers, repairers, recyclers and authorities all scan the same code, but each sees only what their role allows.

There is no single start date. Under the ESPR, a passport becomes mandatory only when the Commission adopts the rules for a specific product group. Those rules then set what the passport holds, which carrier it uses, who can see what, and how long it must stay available.

The Commission's first working plan, of 16 April 2025, sets the order:

• Final products: textiles with a focus on apparel, furniture, tyres and mattresses.
• Intermediate products: iron and steel, and aluminium.
• Cross-cutting measures: repairability, and the recyclability and recycled content of electrical and electronic equipment.

The planned years run from 2026 to 2029. They are plans, not law. Once a group's rules take effect, its passport duty applies no earlier than 18 months later, unless an earlier date is justified.

Example: the steel rules are planned for the end of 2026. If they took effect in March 2027, steel passports could apply from September 2028 at the earliest.

Six other laws set passports of their own:

• Euro 7 Regulation: an Environmental Vehicle Passport for new car and van types from 29 November 2026, the earliest passport date in EU law.
• Battery Regulation: the battery passport, from 18 February 2027.
• Construction Products Regulation: a passport once the Commission sets up its passport system and a product family moves under the 2024 rules.
• Detergents Regulation, Toy Safety Regulation and End-of-Life Vehicles Regulation: each with its own start date, listed under key dates below.

All except the two vehicle laws use one EU registry for passport identifiers.

These laws apply to products sold on the EU market wherever they are made. Manufacturers and exporters outside the EU, including in India, come into scope as soon as their product group does. India has no passport law of its own, so for Indian businesses this is a question of export readiness.

Where this comes from: Ecodesign Regulation Articles 4(4) and 9 to 15; Battery Regulation Article 77; Working Plan COM(2025) 187 final; Implementing Regulation (EU) 2026/1778.

Every passport date, with its source and the day it was last checked, is kept on the Digital Product Passport timeline. The passport finder narrows it to one product and one role.

GS1 Digital Link, GTIN and the DPP data carrier standard

Many products already carry a GTIN, the number behind a retail barcode. GS1 Digital Link turns that number into a web address that a QR code or Data Matrix can hold. One code can then both identify the product and open its passport. The ESPR does not require GS1 Digital Link, but it does list the GTIN among the details a product group's rules can ask for.

Where a business starts depends on its products:

• Already barcoded: products with GTINs and GS1 barcodes have part of the identifier groundwork in place.
• Not yet identified: for other products, setting up unique product, operator and facility identifiers comes first.

Identifiers and carriers prepared to ISO/IEC 15459, EN 18219 and EN 18220 fit what the product group rules are expected to set.

Who is responsible for the passport on imported goods?

Two businesses, once a product group's rules apply:

• Non-EU manufacturer: a manufacturer outside the EU, including one in India, must make sure the passport and its back-up copy are available. It cannot hand that duty to an authorised representative.
• EU importer: before selling the product, the importer must also make sure the passport and back-up are in place.
• Back-up copy: the back-up sits with an independent DPP service provider, so the passport survives if the business stops trading.
• An exporter's own EU company: if it brings the goods in, it is the importer, with the importer's duty. If it sells them under its own name or brand, it is treated as the manufacturer.
• Supplying EU brands and importers: those buyers carry their own duties and will ask their suppliers for the product data, identifiers and carrier.

Where this comes from: Ecodesign Regulation Articles 2(42) and 2(44), 10(4), 27(1), 28(1), 29(2) and 34(a).

What is a DPP readiness assessment and gap analysis?

A check of where a product stands against the passport rules, and what is missing before they apply. It usually has four parts:

• Scope check: which passport laws reach the product, and when.
• Data inventory: what product data is already held, in-house and with suppliers, against what a passport will need.
• Identifier and carrier check: whether unique identifiers and a carrier are in place.
• Gap register: each missing item and the work needed to close it.

The result is a readiness plan timed against the planned dates for each product group and the battery date.

Why textile and apparel exporters watch this first

Textiles and apparel are among the first finished products in line, with rules planned for 2027. The year is a plan, and the duty starts only when the rules apply, but the data takes time to collect. Fibre composition, recycled content and durability information often sits with spinners, weavers and processors several steps back in the supply chain.