It depends on who is asking. A Digital Product Passport (DPP) is not one open file: some data is public, some is kept for professionals such as repairers and recyclers, and some only for authorities. The Ecodesign Regulation leaves the split to the rules for each product group. The EU battery passport, due from 18 February 2027, already shows how it can look.
Who is entitled to access?
The Ecodesign Regulation names the people a passport must serve, free of charge and as far as their access rights go:
- businesses in the supply chain, such as manufacturers, importers, distributors and dealers
- customers
- repairers, refurbishers, remanufacturers, recyclers and independent operators
- market surveillance authorities and customs
- civil society organisations, trade unions and other relevant parties
What does a tiered passport look like?
| Tier | Who can read it | What it holds |
|---|---|---|
| Public | Anyone scanning the QR code, including consumers | General information about the battery |
| Legitimate interest | Repairers, remanufacturers, second-life operators and recyclers | Data needed to repair, reuse or recycle the battery |
| Authorities | Notified bodies, market surveillance authorities and the Commission | Data for checking compliance |
The Commission’s act confirming who has a legitimate interest is still to come. Products under the Ecodesign Regulation will get their own version once their rules are adopted.
Can a business edit its own passport data?
Not as of right. The Ecodesign Regulation gives businesses no general power to change their own fields. The rules for each product group decide who may add or change which data.
Is confidential business data safe?
That is the point of the tiers. Access is limited by type of reader, so trade secrets and other confidential business data can be kept away from the public.
Where this comes from: Ecodesign Regulation (EU) 2024/1781, Articles 9(2) and 11; Battery Regulation (EU) 2023/1542, Article 77(2) and Annex XIII.