Textiles
Textiles with a focus on apparel, a leading India to EU trade flow, named a priority group in the first ESPR Working Plan.
Digital Product Passport Solutions for
Export readiness for the EU Digital Product Passport under the Ecodesign for Sustainable Products Regulation, and for the EU battery passport that applies from 18 February 2027. Product level data, unique identifiers and a machine readable data carrier prepared, and the passport record built and maintained so Indian goods stay ready for the European market.
Map · Build · RegisterESPR and battery passportIndia and worldwide delivery
On recordFrameworkESPR · Regulation (EU) 2024/1781First dated passportBattery passport · February 2027Data carrierMachine readableRegistryEU centralScopePriority product groupsBaseMumbai
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From an EU framework to an export-ready passport
For Indian manufacturers and exporters of batteries, textiles, metals and electronics placed on the European market.
DPP Solutions by GreenSutra turn the European Digital Product Passport into an export-ready record. One accountable engagement maps a product against the priority groups and the battery rule, assembles the data a passport needs, secures the identifiers and data carrier, and maintains the record for the European market.
WHAT THE REGULATION REQUIRES
The Digital Product Passport is a structured electronic record introduced by the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, the EU framework in force since 18 July 2024 that replaced the former Ecodesign Directive. The framework 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 PASSPORT APPLIES, AND WHEN
The first Working Plan, COM(2025) 187 final adopted on 16 April 2025, names six priority groups, from textiles to iron and steel. Its adoption years across 2026 to 2029 are indicative planning, not law, and as of June 2026 no product-specific delegated act has been adopted. The one passport fixed in dated law is the EU battery passport under Article 77 of Regulation (EU) 2023/1542, applying from 18 February 2027.
WHAT IT MEANS FOR INDIAN EXPORTERS
The framework applies to products placed on the European market wherever made, so Indian 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. The European Commission must set up the central DPP registry by 19 July 2026, after which the identifier passes to customs at release for free circulation.
WHAT THE ENGAGEMENT DELIVERS
- Scope and obligation map placing the product against the ESPR priority groups and the battery passport rule
- Structured passport record assembling material composition, recycled content, substances of concern, durability and end of life data across supply tiers
- Identifiers and data carrier secured to the Annex III standards, with a machine readable carrier such as a QR code
- Registry and maintenance readiness so the identifier is ready for the registry and customs and the record stays accurate and up to date
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Product groups covered by the Digital Product Passport
The first priority groups under the ESPR Working Plan, indicative on timing, alongside the one passport already fixed in dated law.
The Digital Product Passport becomes mandatory product group by product group through delegated acts under the ESPR. The first Working Plan, COM(2025) 187 final, names the priority groups below with indicative adoption years across 2026 to 2029, which are planning dates rather than law, and as of June 2026 no product-specific delegated act has been adopted. The one passport fixed in dated law is the EU battery passport, which applies from 18 February 2027. The groups below act as the guide rather than every covered product.
Furniture
Furniture as a finished product group, named in the first Working Plan for a future ESPR delegated act.
Tyres
Tyres as a finished product group placed on the European market, named a priority group in the Working Plan.
Mattresses
Mattresses as a finished product group, named in the Working Plan with the latest indicative planning year of the six.
Iron and steel
Iron and steel as an intermediate product group, named in the Working Plan with the earliest indicative planning year of the six.
Aluminium
Aluminium as an intermediate product group placed on the European market, named a priority group in the Working Plan.
Batteries
Light means of transport, industrial batteries above 2 kWh and electric vehicle batteries, the one passport fixed in dated law under Article 77 of the Battery Regulation.
A precise check of which product groups a business places on the EU market, and whether the dated battery track applies, is the first step of every DPP readiness review.
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How a DPP engagement runs
From product scoping and data mapping to a built passport record, secured identifiers, a registered passport and a maintained record.
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Map the product and the data
The product confirmed against the ESPR priority groups and the battery passport rule, the supply chain mapped across its tiers, and the product level data a passport will need identified, from material composition to repair and end of life information.
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Assemble the record across supply tiers
Material composition, recycled content, substances of concern, durability, repair and end of life data gathered across every supply tier into one structured passport record, so the information a passport needs sits in a single accurate place before identifiers are secured.
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Secure identifiers and the data carrier
Unique product, operator and facility identifiers secured to the standards referenced in Annex III, and a machine readable data carrier such as a QR code prepared so the record is reached by scanning the product.
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Register and ready for customs
The identifiers readied for the central EU registry that the European Commission must set up by 19 July 2026, and the unique registration identifier prepared for customs at release for free circulation once the registry is operational.
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Maintain the passport across the chain
Data governance set so the passport stays accurate, complete and up to date across the value chain, accessible to each actor by their access rights, and maintained even after the operator insolvency or cessation of activity.
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How a digital product passport works
The passport follows a product from value-chain data through a data carrier to the central EU registry and its readers.
01Product and carrier
A physical product, such as a battery or a textile, carries a machine readable data carrier such as a QR code that holds its unique product identifier.
02Scan and resolve
Scanning the data carrier resolves the unique product identifier to the digital product passport, the structured electronic record held for that product.
03Record build
Product level data assembles into the passport record across the value chain: material composition, recycled content, durability, repair and end of life information.
04DPP registry
The unique identifiers are registered in the central EU registry that the European Commission must set up by 19 July 2026, where at least the identifiers and the commodity code are held.
05Value chain access
Each actor along the chain, the manufacturer, the importer and the recycler, reads the passport for the information relevant to them, with free and easy access set by their access rights.
06Market surveillance
Market surveillance and customs authorities verify the passport at the point of control, confirming the registered identifier and commodity code against the product once the registry is operational.
Product level data is gathered across the value chain and carried by a machine readable data carrier such as a QR code, the unique identifiers are registered in the central EU registry, and the passport is read by each actor along the chain and verified by customs and market surveillance once the registry is operational. The battery passport applies from 18 February 2027.
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DPP exposure self-check
Two answers map a business onto the EU Digital Product Passport.
Two questions place a business against the EU Digital Product Passport: the product groups it places on the European market and the route by which they reach it. The result separates the indicative ESPR groups from the dated battery passport and states what to prepare next.
Two questions decide DPP exposure: which product groups the business places on the European market, from textiles, furniture, tyres, mattresses, iron and steel and aluminium to batteries, and the route by which they reach it. A DPP readiness review works through both with the product on the table.
Request a DPP readiness review →- Battery passportFrom 18 February 2027
- Central EU DPP registryCommission to set up by 19 July 2026
- ESPR product groupsPer delegated act, timing indicative
The business sits outside the Digital Product Passport today
None of the priority product groups or the dated battery track are placed on the European market, so the Digital Product Passport sets no obligation on the business today. The framework attaches product group by product group through delegated acts under the ESPR, so the product mix is the point to watch, since placing any covered group on the market brings the obligation into force once its delegated act applies.
No covered product reaches the EU market today
Covered product groups are made, but nothing reaches the European market, so the EU Digital Product Passport sets no obligation on the business today. The framework bites only where a product is placed on the EU market under a delegated act, and the EU battery passport applies only to batteries placed on the EU market. Any future European sale is the point to watch, since it brings the obligation into scope.
The dated battery passport applies
Batteries are placed on the European market, so the one passport already fixed in dated law applies. Under Article 77 of the Battery Regulation (EU) 2023/1542 the battery passport applies from 18 February 2027 to light means of transport batteries, industrial batteries above 2 kWh and electric vehicle batteries, with tiered public, restricted and legitimate-interest access. Product level data, unique identifiers and a machine readable data carrier prepared ahead of that date keep covered batteries moving into the European market.
A priority product group, with timing indicative
Priority product groups under the first ESPR Working Plan are placed on the European market, so the Digital Product Passport will attach once a product-specific delegated act is adopted and applies. The Working Plan gives indicative adoption years across 2026 to 2029, which are planning dates rather than law, and as of June 2026 no product-specific delegated act has been adopted. Assembling product level data, securing identifiers and preparing a machine readable data carrier ahead of each delegated act keeps the goods ready.
The position is worth a short review
The product groups placed on the European market, or the route by which they reach it, are still being mapped, so the exact passport position cannot be fixed from the answers alone. The ESPR attaches the passport product group by product group through delegated acts, while the EU battery passport is fixed in dated law from 18 February 2027. Confirming which groups the business places on the EU market, and by what route, is the first step of a DPP readiness review.
Where the business places goods on the EU market through its own European entity, that entity holds the passport duties directly, so the identifiers and data carrier stay within the business.
Where the business supplies EU brands and importers, those EU operators carry the passport duties and will demand the product level data, identifiers and carrier from the supplier.
Identifying who places the goods on the EU market, and so who carries the passport, is part of the DPP readiness review.
Answers stay in this browser. Nothing is sent until a contact channel is opened.
The passport follows each product from the data gathered across its value chain to the data carrier and the registry, and a readiness review turns that path into a built, maintained passport record.
WhatsAppRequest a DPP readiness review →06
Benefits of DPP solutions
What passport readiness earns an exporter before each delegated act applies.
B·01
Market access protected
A compliant, registry-matched passport keeps covered goods moving into the European market, since a product without one can be refused release for free circulation once the registry is operational.
B·02
Ahead of the deadline
Product level data assembled before each delegated act applies, and before the battery passport date of 18 February 2027, so the obligation is met without a last-minute scramble.
B·03
Trusted supplier status
Verified, traceable product data positions the exporter as a preferred supplier to European buyers who must source passport-ready goods.
B·04
Circular advantage
The traceability data behind a passport, from recycled content to repair and end of life information, also supports durability and circularity claims that grow in value over time.
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Why GreenSutra leads DPP readiness
The reasons behind the reputation.
R·01
EU regulatory fluency
Working knowledge of the Ecodesign for Sustainable Products Regulation, its delegated-act mechanism and the EU battery passport, so guidance separates indicative planning from binding obligation.
R·02
Supply chain data depth
Product level data assembled across multiple Indian supply tiers, from material composition and recycled content to substances of concern and end of life.
R·03
Export readiness focus
A clear export-readiness brief that prepares Indian goods for the European market without assuming any domestic Indian passport law, since none exists.
R·04
End to end delivery
Mapping, data assembly, identifiers, data carrier and registry readiness handled as one accountable engagement, or any stage standalone.
R·05
Mumbai based, serving worldwide
DPP readiness delivered to exporters in India and worldwide from a Mumbai base.
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Built for every priority product group
The same traceability discipline, tuned to the product and the European market it serves.
01
Battery and EV exporters
Producers of LMT, industrial and electric vehicle batteries prepared for the Article 77 battery passport that applies from 18 February 2027, with tiered public, restricted and legitimate-interest access.
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Textile and apparel exporters
A major India to EU trade flow, with fibre and material composition, recycled content and durability data assembled ahead of the indicative textile delegated act.
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Steel and aluminium exporters
Intermediate metals producers building product level data for the indicative iron and steel and aluminium delegated acts named in the Working Plan.
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Electronics manufacturers
Makers of electrical and electronic equipment readied for the horizontal measures on repairability and recyclability and any product-specific passport that follows.
Every priority product group carries the same traceability discipline, tuned to the exporter and the European market it supplies.
WhatsAppRequest a DPP readiness review →09
DPP questions, answered
Q·01What are DPP solutions?
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.
Q·02What is a Digital Product Passport?
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.
Q·03When is the DPP mandatory?
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.
Q·04Which products will need a passport first?
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.
Q·05When does the EU battery passport apply and to which batteries?
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.
Q·06Does the DPP apply to Indian manufacturers exporting to the EU?
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.
Q·07What is the EU DPP registry and when must it exist?
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.
Q·08Which data carrier and standard does the DPP require?
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.
Q·09Can companies still destroy unsold clothing in the EU?
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.
Q·10What are the penalties for a non-compliant product?
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.
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Request a DPP readiness review
A short conversation about the product, the European market it serves and the data already on hand turns into a tailored Digital Product Passport plan. Schedule a call directly or send a written brief.
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Field notes and stories
Reading on the European Union, product traceability and the circular economy from the GreenSutra journal.
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