Textiles
With a focus on apparel, planned for 2027.
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 data governance set that keeps the passport record current, so Indian goods stay ready for the European market.
Map, assemble, ready for the registryESPR and battery passportIndia and worldwide delivery
Reviewed by Team GreenSutra · Updated 22 October 2026
On recordFrameworkESPR · Regulation (EU) 2024/1781Battery passportFrom 18 February 2027Data carrierMachine readableRegistryEU centralScopePriority product groupsBaseMumbai
01
The EU battery passport applies from 18 February 2027.
For manufacturers and exporters placing batteries, textiles, metals and other goods on the European market.
A Digital Product Passport (DPP) is an electronic record for each product, opened by scanning a QR code or other data carrier on it. The EU brought it in through the Ecodesign for Sustainable Products Regulation (ESPR), in force since 18 July 2024, and six other EU laws set passports of their own.
GreenSutra prepares exporters in India and elsewhere for these passports: the product data, the identifiers and the data carrier. The work starts with a short discovery questionnaire on the product, the route to the European market and the data already on hand. The answers set the scope of the readiness review.
When does a passport become mandatory?
Under the Ecodesign Regulation, one product group at a time, as the Commission adopts the rules for each. As of October 2026, none had been adopted. Other laws set dates of their own:
- New car and van types under Euro 7: 29 November 2026
- Batteries: 18 February 2027, under the EU Battery Regulation
- Detergents: 23 September 2029
- Toys: 1 August 2030
- Cars and vans: 1 September 2032
- Construction products: 18 months after their own passport act
These rules apply to products sold in the EU wherever they are made, so Indian goods come into scope as soon as their product group does. The Digital Product Passport guide covers the rules in more depth, and the passport timeline logs every change to these dates.
Where this comes from: Ecodesign Regulation (EU) 2024/1781, Articles 4(4) and 9 to 15; Working Plan COM(2025) 187 final; Battery Regulation (EU) 2023/1542, Article 77.
Who sees what: access by actor
A passport is not one open file. Each reader sees what their role allows, and the battery passport sets out three levels.
| Access group | Who | What the passport shows them |
|---|---|---|
| Public | Customers and anyone else who scans the code on the product. | The public part of the record. |
| Authorities | Market surveillance and customs authorities. For batteries, also notified bodies and the Commission. | What they need for enforcement. At the border, customs check the registration identifier and commodity code against the EU registry. |
| Value-chain operators | Repairers and recyclers. For batteries, people with a legitimate interest such as repairers, remanufacturers, second-life operators and recyclers. | What they need to repair, remanufacture, reuse or recycle the product, available even after the business behind it has closed. |
Where this comes from: Ecodesign Regulation Articles 11, 14 and 15; Battery Regulation Article 77 and Annex XIII.
02
Product groups covered by the Digital Product Passport
The Commission's first working plan, of 16 April 2025, names six priority product groups, with rules planned between 2026 and 2029. Each passport duty applies no earlier than 18 months after its rules take effect, unless an earlier date is justified.
Example: steel rules adopted in December 2026 would take effect around March 2027, and the steel passport would apply from around September 2028.
Furniture
A finished product, planned for 2028.
Tyres
A finished product, planned for 2027.
Mattresses
A finished product, the last of the six, planned for 2029.
Iron and steel
An intermediate product group, with the earliest planned year of the six: 2026.
Aluminium
An intermediate product group, like iron and steel, planned for 2027.
Batteries
Electric vehicle, light means of transport and industrial batteries above 2 kWh, from 18 February 2027.
A readiness review starts by checking which of these groups a business sells into the EU, and whether the battery passport applies.
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How a DPP engagement runs
The work starts with the product on the table and the data already on hand. GreenSutra runs the five stages below as one engagement or one stage at a time. The upload to the EU registry stays with the economic operator, the business placing the product on the market.
01
Map the product and the data
Each product is matched to the passport laws that reach it. The supply chain is mapped, and the data a passport will need is listed.
02
Assemble the record across supply tiers
Data comes in from each supply tier and is brought together into one passport record. It covers material composition, recycled content, substances of concern, durability, repair and end of life.
03
Obtain identifiers and prepare the data carrier
GreenSutra prepares the product, operator and facility identifiers and the QR code or other carrier to the European standards EN 18219 and EN 18220, cited on 15 July 2026. For batteries, the Battery Regulation names the ISO/IEC 15459 series.
04
Registry and customs readiness
GreenSutra gets the identifiers ready for the economic operator to upload to the EU registry. The operator receives a registration identifier in return, which customs ask for once a product's rules apply.
05
Maintain the passport across the chain
The last stage sets up who keeps the data accurate, complete and up to date, so the passport stays reliable for as long as it must be available.
04
How a digital product passport works
A code on the product holds its unique identifier, and scanning it opens the passport. The identifiers sit in the EU registry, live since 20 July 2026 though not yet taking registrations. Customs will check them automatically once the registry is linked to their systems, by 6 August 2030.
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DPP exposure self-check
Two questions show where a business stands under the EU Digital Product Passport.
They ask which product groups the business places on the European market, and by which route. The result separates the planned Ecodesign groups from the dated battery passport.
- Battery passportFrom 18 February 2027
- Central EU DPP registryLive since 20 July 2026, registration not yet open
- 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 ESPR adds product groups one delegated act at a time, so the product mix is the point to watch. Detergents, toys, construction products and cars and vans also have passport laws of their own, each with its own start date.
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 EU battery passport applies. Apart from the Euro 7 vehicle passport, it is the first EU passport with a fixed date. The Battery Regulation applies it from 18 February 2027 to electric vehicle, light means of transport and industrial batteries above 2 kWh, with a public part, a part for people with a legitimate interest and a part for authorities. Product data, unique identifiers and a data carrier prepared before 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's years, 2026 to 2029, are when the Commission plans to adopt each act, and none had been adopted by mid-October 2026. Each passport then applies no earlier than 18 months after its act enters into force, unless an earlier date is justified. Assembling product level data, obtaining 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 brings in the passport one product group at a time, while the EU battery passport applies 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.
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Benefits of DPP solutions
B·01
Market access protected
Once the registry is linked to customs systems, customs release a covered product only after matching its registration identifier against the EU registry.
B·02
Ahead of the deadline
Data collected early is in place before each product group's rules apply, and before the battery passport date.
B·03
Ready for the EU importer
The EU importer must also make sure the passport and its back-up copy are in place before selling a covered product. Passport-ready data from the exporter lets the importer meet that duty.
B·04
Circular advantage
The same data on recycled content, repair and end of life also backs up durability and circularity information.
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How GreenSutra works on DPP readiness
GreenSutra has worked from Mumbai since 2016 for more than 200 clients. The same team handles CBAM, EUDR and EU PPWR work.
R·01
Working knowledge of the EU passport laws
Every EU passport law, with each date marked as binding or planned.
R·02
Data from several supply tiers
Product data gathered from suppliers several tiers back.
R·03
Export readiness focus
Work aimed at the European market, under EU rules that apply wherever a product is made.
R·04
One engagement or any single stage
Mapping, data assembly, identifiers and carrier, and registry readiness, together or one at a time.
R·05
Mumbai based, serving worldwide
For exporters in India and worldwide, run from Mumbai.
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DPP questions, answered
Q·01What are DPP solutions?
The work and tools that get a product ready for a passport. That means mapping products to the rules, collecting the data, setting up identifiers and a carrier, and keeping the record accurate.
Q·02When is the DPP mandatory?
Product group by product group. No product needs an ESPR passport yet. The battery passport applies from 18 February 2027, and only the Euro 7 vehicle passport starts earlier.
Q·03When does the EU battery passport apply and to which batteries?
From 18 February 2027, to electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh. Portable batteries are outside it.
Q·04Does the DPP apply to Indian manufacturers exporting to the EU?
Yes, once their product group is covered. EU passport rules apply to products sold in the EU wherever they are made.
Q·05Digital product passport vs battery passport: what is the difference?
The battery passport is set directly by the EU Battery Regulation and has a fixed date. Other passports under the ESPR come group by group. Both use the same EU registry.
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Primary sources
Regulation (EU) 2024/1781 · ESPROpen ↗Regulation (EU) 2023/1542 · EU Battery RegulationOpen ↗COM(2025) 187 final · ESPR Working Plan 2025-2030Open ↗European Commission · Implementing the ESPROpen ↗European Commission · Unsold consumer products rules Implementing Regulation (EU) 2026/1778 on the DPP registryOpen ↗
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Asked at the Expert's Corner
Digital Product Passport questions answered by the GreenSutra team from the official EU texts.
Q · 01DPP19 views
How is a Digital Product Passport created, step by step?
A Digital Product Passport (DPP) is built in roughly six steps. Collect the product data the rules ask for, give the product a unique…
Answered by the GreenSutra teamQ · 02DPP19 viewsWho can update a Digital Product Passport after the product is sold?
The answer depends on the product. The EU has not given any business a general right to edit a Digital Product Passport (DPP). Each…
Answered by the GreenSutra teamQ · 03DPP17 viewsHow long must a Digital Product Passport stay available?
At least as long as the product is expected to last. That is the minimum the EU's Ecodesign Regulation sets for a Digital Product…
Answered by the GreenSutra teamQ · 04DPP20 viewsCan customers see a Digital Product Passport before they buy, including online?
Yes. Once a product needs a Digital Product Passport (DPP), customers must be able to look at it before they buy, including when shopping…
Answered by the GreenSutra teamQ · 05DPP21 viewsWhat must dealers and online marketplaces do about Digital Product Passports?
Shops, e-commerce sites and other sellers do not create the Digital Product Passport (DPP), but they do have to pass it on. They check…
Answered by the GreenSutra teamQ · 06DPP21 viewsWhat are an EU importer's duties for a Digital Product Passport?
An EU importer must make sure every covered product it brings in has its Digital Product Passport (DPP), with a back-up copy, before it…
Answered by the GreenSutra teamQ · 07DPP21 viewsWhich organisations have a role in a Digital Product Passport, and what does each do?
Almost everyone around a product has some part in its Digital Product Passport (DPP), but two businesses carry the main duty. They are the…
Answered by the GreenSutra teamQ · 08DPP21 viewsWhat can repairers, refurbishers and recyclers do with a Digital Product Passport?
The passport data their role allows, free of charge. The EU's Ecodesign Regulation gives professional repairers, refurbishers, remanufacturers and recyclers free and easy access…
Answered by the GreenSutra teamQ · 09DPP20 viewsHow does a Digital Product Passport protect confidential business data?
Mostly through access rights. A Digital Product Passport (DPP) does not show everything to everyone. Each product group's rules decide who may see which…
Answered by the GreenSutra teamQ · 10DPP20 viewsWhat is the EU Digital Product Passport web portal?
The EU Digital Product Passport (DPP) web portal is a public website, still to be built, where anyone will be able to search and…
Answered by the GreenSutra teamQ · 11DPP21 viewsDoes a non-EU manufacturer need an EU representative for a Digital Product Passport?
No, except for construction products. Under the EU's Ecodesign Regulation, a manufacturer outside the EU does not have to appoint an authorised representative for…
Answered by the GreenSutra teamQ · 12DPP29 viewsDoes packaging need its own Digital Product Passport?
No EU law gives packaging a Digital Product Passport of its own. The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has no…
Answered by the GreenSutra teamSolution deck · 25 slides · PDF by email
Digital Product Passport Solutions
A 25-slide deck on the Digital Product Passport under the Ecodesign Regulation and the other EU passport laws, and what it takes to be ready.
- The EU laws that call for a passport, and their dates
- Who carries the duty across the chain
- What a passport carries and how the EU registry works
- A five-stage engagement
Get the deck by emailThe PDF is attached to a confirmation email. There is no public download link.
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Request a DPP readiness review
A DPP readiness review starts with a short conversation about the product, the European market it serves and the data already on hand. From that, GreenSutra drafts a passport plan for the product. A call can be booked directly, or a written brief sent instead.
01Schedule a call
Pick the service and a slot; a practitioner takes the call.
02Write to us
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Related services
Maintained by GreenSutra · Last reviewed October 2026
DPP mapped, prepared and ready for registration WhatsAppRequest a DPP readiness review →
Scope DPP readiness
A short questionnaire on the products and the data on hand shows which passport laws apply. GreenSutra then returns a Scope of Work.