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, assemble, ready for the registryESPR and battery passportIndia and worldwide delivery
Reviewed by Team GreenSutra · Updated 28 September 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 Commission's first ESPR Working Plan, COM(2025) 187 final of 16 April 2025, names six priority product groups, from textiles to iron and steel. Its years, 2026 to 2029, are when the Commission plans to adopt each act, and none had been adopted by September 2026. Under ESPR Article 4(4), a passport duty applies no earlier than 18 months after its act enters into force. 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. The Digital Product Passport guide sets out how a passport is reached, the GS1 Digital Link carrier route, who holds the duty for imported goods, and the deadlines.
Who sees what: the three access tiers
A passport is not a single open file. Under ESPR Article 11, each listed actor gets free and easy access, but only to the information its access rights allow. ESPR Article 14 adds a public web portal to search and compare passport data. The Commission's DPP FAQ says the portal is planned for launch in the coming years. 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, by scanning the data carrier on the product. The public web portal under ESPR Article 14 has no launch date yet. | 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. Once an ESPR delegated act covers a product, customs check its registration identifier and commodity code against the EU registry before release for free circulation. |
| 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 ESPR Working Plan's first priority groups, with indicative timing, and the battery passport, the first passport with a fixed date.
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 and the years, 2026 to 2029, in which the Commission plans to adopt each act. None had been adopted by September 2026, and under ESPR Article 4(4) each act applies at least 18 months after it enters into force. For example, a steel act adopted in December 2026 would enter into force around March 2027 and apply from around September 2028 at the earliest. Five other EU laws set a passport with dates of their own. Batteries come first on 18 February 2027, then detergents on 23 September 2029, toys on 1 August 2030 and cars and vans on 1 September 2032. Construction products follow 18 months after their delegated act.
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 first passport with a fixed date, 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, registry readiness 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
Product, operator and facility identifiers and a QR code or other machine readable data carrier, prepared to EN 18219 and EN 18220, the harmonised standards published on 15 July 2026.
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Registry and customs readiness
Identifiers made ready for the economic operator's upload to the EU registry, which went live on 20 July 2026. The operator then receives the registration identifier that customs ask for 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 links a product's value-chain data to its readers through a data carrier, while the EU registry holds the product's identifiers.
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 authorities use the registry. For a product under an ESPR delegated act, customs match the registration identifier and commodity code before release, with an automatic link due by 6 August 2030.
A data carrier such as a QR code links each product to passport data gathered across its value chain. The unique identifiers go to the central EU registry, and each actor reads the passport by its access rights. Customs checks apply to a product once its ESPR delegated act does. 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 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. It is the first EU passport with a fixed date. 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's years, 2026 to 2029, are when the Commission plans to adopt each act, and none had been adopted by September 2026. Each passport then applies at least 18 months after its act enters into force. 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 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.
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
Once a product's ESPR delegated act applies, customs release it only after matching its registration identifier against the EU registry. A passport ready by then keeps covered goods moving into the European market.
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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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Ready for the importer's check
Before placing a covered product on the EU market, an importer must check that its passport and back-up copy exist, under ESPR Article 29(2). Passport-ready data lets an exporter meet that check.
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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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How GreenSutra works on DPP readiness
GreenSutra has worked from Mumbai since 2016 for more than 200 clients, and handles the passport alongside CBAM, EUDR and EU PPWR work.
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EU regulatory fluency
Working knowledge of the ESPR and the five other EU laws that set a passport, with each date marked as binding or planned, as in the 25-slide DPP deck.
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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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One engagement or any single stage
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?
Not yet for any product. The first binding date is 18 February 2027, when the Battery Regulation requires a passport for electric vehicle, light means of transport and industrial batteries over 2 kWh. Under the ESPR, Regulation (EU) 2024/1781, the passport becomes mandatory one product group at a time, through a delegated act. None had been adopted by September 2026. The Working Plan's years, 2026 to 2029, are targets for adopting each act, and each act applies at least 18 months after it enters into force. Detergents follow on 23 September 2029, toys on 1 August 2030 and cars and vans on 1 September 2032, under their own laws. Construction products follow 18 months after their own delegated act.
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, once a product falls in a covered group, because EU passport rules apply to products placed on the EU market wherever they are made. Under the ESPR, the manufacturer makes the passport and its back-up copy available. An EU importer must check that both exist before placing the product on the market, under Article 29(2). Textile, steel and aluminium products need a passport once their delegated acts apply. Electric vehicle, light means of transport and industrial batteries over 2 kWh need one from 18 February 2027. India has no passport law of its own, so for an Indian exporter the work is export readiness.
Q·05Digital product passport vs battery passport: what is the difference?
The battery passport is one of six EU product passports, and the first with a binding date. Article 77 of the Battery Regulation (EU) 2023/1542 requires it from 18 February 2027 for electric vehicle, light means of transport and industrial batteries over 2 kWh. The ESPR passport, under Regulation (EU) 2024/1781, reaches other products one group at a time, through delegated acts that apply at least 18 months after they enter into force. None had been adopted by September 2026. For both, the operator placing the product on the market uploads its identifiers to the same EU registry, live since 20 July 2026.
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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 ↗
Solution deck · 25 slides · PDF by email
Digital Product Passport Solutions
A 25 slide deck on the Digital Product Passport under the Ecodesign for Sustainable Products Regulation and five other EU laws, and what it takes to be ready.
- Six EU laws that call for a passport, batteries first on 18 February 2027
- 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 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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Related services
Maintained by GreenSutra · Last reviewed September 2026
DPP mapped, built 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, and GreenSutra returns a tailored Scope of Work.