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
Reviewed by Team GreenSutra · Updated 18 June 2026
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.
As a digital product passport consultant serving exporters across India, GreenSutra turns the European Digital Product Passport into an export-ready record. The Digital Product Passport is a structured electronic record introduced by the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, in force since 18 July 2024. 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. 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. A short DPP discovery questionnaire is the quickest way to scope a product group, the route to the European market and the data already on hand before a readiness review.
The first Working Plan, COM(2025) 187 final adopted on 16 April 2025, names six priority groups, from textiles to iron and steel, with indicative adoption years across 2026 to 2029 that are planning dates rather than law; 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. Because the framework reaches products placed on the European market wherever made, Indian exporters fall within scope once a delegated act covers their goods, and the European Commission must set up the central DPP registry by 19 July 2026. India has no domestic Digital Product Passport law, so the task is export readiness. How the passport is reached, the GS1 Digital Link carrier route, who holds the duty for imported goods, the deadlines and the cost drivers are set out in full in the Digital Product Passport guide.
Who sees what: the three access tiers
A passport is not a single open file. Under ESPR Article 11 the record gives the listed actors free and easy access, but only to the information their access rights allow, and ESPR Article 14 adds a publicly accessible web portal to search and compare passport data within those rights. The battery passport tiers access the same way under Article 77 of the Battery Regulation (EU) 2023/1542. The three tiers separate what the public, the authorities and the value-chain operators each see.
| Access tier | Who | What the passport shows them |
|---|---|---|
| Public | Customers and the general public, through the publicly accessible web portal under ESPR Article 14. | The public subset of the record, the information opened to everyone under each product's access rights; for the battery passport, the information set as public under Annex XIII. |
| Authorities | Market surveillance and customs authorities under ESPR Articles 11 and 15; for the battery passport, notified bodies, market surveillance authorities and the Commission. | Access for enforcement and, at release for free circulation, the registration identifier and commodity code verified against the central EU registry once it is operational. |
| Economic operators | Repairers and recyclers under ESPR Article 11; for the battery passport, persons with a legitimate interest such as repairers, remanufacturers, second-life operators and recyclers. | The information their access rights allow for repair, remanufacture, second-life use and end of life, available even after the operator ceases activity. |
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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; 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.
Furniture
Furniture as a finished product group named in the first Working Plan.
Tyres
Tyres as a finished product group placed on the European market.
Mattresses
Mattresses as a finished product group, the latest indicative planning year of the six.
Iron and steel
Iron and steel as an intermediate product group, the earliest indicative planning year of the six.
Aluminium
Aluminium as an intermediate product group placed on the European market.
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.
01
Map the product and the data
The product confirmed against the ESPR priority groups and the battery passport rule, the supply chain mapped, and the product level data a passport will need identified.
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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.
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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.
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Register and ready for customs
The identifiers readied for the central EU registry the Commission must set up by 19 July 2026, and the registration identifier prepared for customs at release for free circulation.
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Maintain the passport across the chain
Data governance set so the passport stays accurate, complete and up to date, accessible to each actor by their access rights, even after the operator ceases 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 holding its unique product identifier.
02Scan and resolve
Scanning the data carrier resolves the identifier to the digital product passport, the structured electronic record held for that product.
03Record build
Product level data assembles into the passport record: material composition, recycled content, durability, repair and end of life information.
04DPP registry
The unique identifiers are registered in the central EU registry the Commission must set up by 19 July 2026.
05Value chain access
Each actor, the manufacturer, the importer and the recycler, reads the passport for the information relevant to them, by their access rights.
06Market surveillance
Market surveillance and customs verify 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.
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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.
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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.
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Trusted supplier status
Verified, traceable product data positions the exporter as a preferred supplier to European buyers who must source passport-ready goods.
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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 a digital product passport consultant in India is trusted by exporters to the European market.
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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.
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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.
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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.
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End to end delivery
Mapping, data assembly, identifiers, data carrier and registry readiness handled as one accountable engagement, or any stage standalone.
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Mumbai based, serving worldwide
DPP readiness delivered to exporters in India and worldwide from a Mumbai base.
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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 maps the product against the priority groups, assembles the product level data a passport needs across the supply chain, secures the unique identifiers, prepares a machine readable data carrier such as a QR code, and sets the data governance that keeps the record accurate, complete and up to date for the European market.
Q·02When is the DPP mandatory?
The Ecodesign for Sustainable Products Regulation has been in force since 18 July 2024, but the framework 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 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·03When 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. It does not cover every battery; portable and consumer batteries below those thresholds are outside the Article 77 passport. Access is tiered, 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·04Does 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 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·05How much does a digital product passport cost to implement?
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 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 that must supply material, 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 before any work is sized.
Q·06Digital product passport vs battery passport: what is the difference?
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, 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 above 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.
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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.
01Schedule a call
Pick the service and a slot; a practitioner takes the call.
02Write to us
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Maintained by GreenSutra · Last reviewed June 2026
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