Digital Product Passport Guide

The ESPR has been in force since 18 July 2024. It replaced the Ecodesign Directive 2009/125/EC, with transitional exceptions.

The record is linked to a unique product identifier and reached by scanning a machine readable data carrier on the product. It carries, across the value chain:

• Product data: material composition, recycled content, substances of concern, durability, repair and end of life information, kept accurate, complete and up to date.
• Readers: actors along the value chain, including consumers, repairers, recyclers, market surveillance and customs, each according to their access rights.

The framework itself sets no general deadline. Under Articles 9 to 15 the passport becomes mandatory product group by product group through delegated acts of the European Commission, which fix the data, the data carriers, the access rights and the availability period for each group. The first Working Plan, COM(2025) 187 final adopted on 16 April 2025, names six priority groups:

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

Its adoption years run from 2026 to 2029, with a mid-term review in 2028. These are planning dates, not law, and no product-specific act had been adopted by September 2026. As a rule, ESPR Article 4(4) sets at least 18 months between an act's entry into force and the date it applies. Example: if the steel act, planned for the fourth quarter of 2026, entered into force in March 2027, steel passports could apply from September 2028 at the earliest.

The first DPP to become mandatory is the EU battery passport. Article 77 of the Battery Regulation (EU) 2023/1542 applies it from 18 February 2027. It covers light means of transport batteries, industrial batteries above 2 kWh and electric vehicle batteries. Because the ESPR applies to products placed on the European market wherever made, Indian manufacturers and exporters fall within scope once a delegated act covers their goods. India has no domestic Digital Product Passport law, so the task is export readiness. Six EU laws now provide for a passport. Besides the ESPR and the Battery Regulation, they are the Construction Products Regulation, the Toy Safety Regulation, the Detergents Regulation and the End-of-Life Vehicles Regulation. Implementing Regulation (EU) 2026/1778 links the first five to one EU registry. Construction products need a passport 18 months after the Construction Products Regulation's delegated act on the passport system enters into force. Key dates, below, gives the other laws' start dates. The Digital Product Passport solutions page explains how a GreenSutra readiness review applies these rules to a business's own products.

The passport is read by actors along the value chain, including consumers, repairers, recyclers, market surveillance and customs, each according to their access rights. Under Article 11 of the Ecodesign for Sustainable Products Regulation the passport must be fully interoperable and give listed actors free and easy access per their access rights, with data authentication and integrity assured.

The battery passport under Article 77 of the Battery Regulation (EU) 2023/1542 makes the tiers concrete:

• Public: information open to anyone, including consumers scanning the data carrier.
• Authorities: information restricted to notified bodies, market surveillance and the European Commission.
• Legitimate interest: information reserved to persons with a legitimate interest such as repairers and recyclers.

The product level data behind these tiers also underpins a life cycle assessment and the carbon footprint of the product.

The framework itself sets no general passport deadline. The EU registry has been live since 20 July 2026, and the battery passport applies from 18 February 2027. ESPR product acts carry indicative adoption years only, and none had been adopted by September 2026. As a rule, each applies at least 18 months after it enters into force.

Sequencing readiness against these dates, with the battery passport date fixed and the ESPR groups indicative, is the work of a DPP discovery brief and the readiness review that follows.

The passport is reached by scanning a machine readable data carrier, such as a QR code, a data matrix or an RFID tag, that is linked to a unique product identifier and, where possible, placed on the product itself so the data stay accessible across its life. Each delegated act picks the carrier for its product group. The technical standards now exist. On 15 July 2026, Implementing Decision (EU) 2026/1736 cited EN 18219 for unique identifiers and EN 18220 for data carriers. Meeting them gives a presumption of conformity with the matching ESPR requirements.

GS1 Digital Link, GTIN and the DPP data carrier standard

GS1 Digital Link is a GS1 standard that turns a product's GTIN into a web address, which a QR code or data matrix can carry. The ESPR does not require it. Annex III lists the GTIN, under ISO/IEC 15459-6, among the data a delegated act can call for.

How the route fits together:

• GS1 Digital Link: turns the carrier on a product into a web address, so a single QR code or data matrix both identifies the product and resolves to its digital product passport.
• GTIN: the Global Trade Item Number that already identifies products in barcodes and trade, extended into the web link a passport needs.
• Already barcoded: where products already carry GTINs and GS1 barcodes, the identifier groundwork for a future passport is partly in place.
• Not yet identified: where they do not, securing unique product, operator and facility identifiers is part of the readiness work.

A readiness review prepares the identifiers and a machine readable carrier in line with ISO/IEC 15459 and the harmonised standards EN 18219 and EN 18220. That leaves the product ready for whatever each delegated act sets.

Who holds the passport duty for imported goods

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.

How the duty falls:

• Non-EU manufacturer: a manufacturer outside the EU, including in India, keeps the duty to make the passport and its back-up copy available. ESPR Article 28 bars it from handing that duty to an authorised representative. The EU importer must check that both exist before placing the product on the market.
• Back-up copy: the operator placing the product on the market must keep a back-up copy of the passport available through an independent third-party service provider, so the record survives the operator ceasing activity.
• EU entity of the exporter: where an EU entity of the business places the goods, that entity holds the duty.
• Supplying EU brands and importers: 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.

The DPP readiness assessment and gap analysis

The first deliverable of a digital product passport consultant is a named DPP readiness assessment and gap analysis. It establishes where a product sits against the European framework and exactly what is missing before each obligation applies.

The assessment runs four moves:

• Scope check: places each product against the ESPR priority groups and the dated battery passport rule.
• Data inventory: maps what product level data already exists across the supply tiers against what a passport will need, from material composition and recycled content to substances of concern, durability, repair and end of life information.
• Identifier and carrier check: confirms whether unique product, operator and facility identifiers and a machine readable carrier are in place.
• Gap register: lists each missing item with the work to close it.

The output is a prioritised readiness plan, sequenced against the indicative Working Plan years and the 18 February 2027 battery passport date. A structured first step is a DPP discovery brief, and where deeper product data is needed the same inventory feeds a life cycle assessment and the carbon footprint of the product.

Why textile and apparel exporters watch this first

The first ESPR and Energy Labelling Working Plan, adopted on 16 April 2025 and covering 2025 to 2030, names textiles with a focus on apparel among its priority product groups, alongside furniture, tyres, mattresses, iron and steel and aluminium. Apparel is a leading India to EU trade flow, which puts textile and apparel exporters among the groups most likely to face an early ESPR delegated act. The Working Plan year for textiles is indicative planning rather than a legal deadline, and the binding obligation starts only once the textile delegated act is adopted and applies. Assembling fibre and material composition, recycled content and durability data ahead of that act is what keeps apparel ready for the European market. The same product level data also underpins a life cycle assessment and the carbon footprint behind a product, so the work compounds across export requirements.