Digital Product Passport (DPP): ESPR rules and registry

Hugues Orgitelloupdated 7 Oct 202615 min read

The Digital Product Passport (DPP) is the product data record created by Chapter III (Articles 9 to 15) of the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (the ESPR). As of 7 October 2026, no ESPR delegated act has yet made a passport mandatory for any product group, but the infrastructure is in place: the registry rules of Implementing Regulation (EU) 2026/1778 have been in force since 6 August 2026, and Implementing Decision (EU) 2026/1736 cited six harmonised standards, EN 18216 and EN 18219 to EN 18223:2026, on 15 July 2026. The first dated passport is the battery passport of Regulation (EU) 2023/1542, from 18 February 2027. This guide reads those texts article by article, from the data carrier to the registry and customs checks, and lists the claims about the DPP that the texts contradict, including some an earlier version of this page made. It is the detailed companion to the broader ESPR guide.

What the DPP is, in the words of the text

Article 10(1) sets the essential requirements. A DPP is connected through a data carrier to a persistent unique product identifier. The carrier is physically present on the product, its packaging or the documentation accompanying it, as the delegated act specifies. The data refer to the product model, batch or item, again as the delegated act specifies, and must be based on open standards, in an interoperable format and, as appropriate, machine-readable, structured, searchable and transferable without vendor lock-in. Customer personal data may not be stored in the passport without explicit consent (Article 10(1)(e)).

The ESPR recitals describe the passport as a decentralised data system set up and managed by economic operators. The Commission does not host the passports: it runs a registry of identifiers (Article 13) and a public web portal to search and compare passport data within each user's access rights (Article 14).

Article by article

Article	What it does
9(1)	A delegated act can make the passport a condition for placing the product on the market; the data must be accurate, complete and up to date
9(2)	Lists what each delegated act must decide (see the next table)
9(3)	Purpose: easy access for value chain actors, verification by national authorities, traceability along the value chain
9(4)	The Commission may exempt a product group when no technical specifications exist, or when other Union law already includes a system for the digital provision of the information
10(3)	The operator gives dealers and online marketplaces a digital copy of the carrier or identifier, free of charge, within five working days of a request
10(4)	When placing the product on the market, the operator makes a back-up copy available through a DPP service provider
11	Interoperability, free access by listed actors, storage by the operator or a service provider, linking of a new passport to the original, availability after insolvency or cessation of activity, data integrity and security
12	Operator and facility identifiers; delegated acts may set rules for issuing agencies
13	Commission registry, at least the unique identifiers, plus the commodity code for imports and battery identifiers
14	Public web portal to search and compare passport data
15	Customs: the unique registration identifier must be given to customs before release for free circulation

What each delegated act decides (Article 9(2))

Point	Decision
(a)	Which data from Annex III are included
(b), (c)	Which data carrier, its layout and its position
(d)	Model, batch or item level, and the definition of those levels
(e)	How customers reach the passport before they are bound by a contract, including distance selling
(f)	Which actors have access to which data
(g), (h)	Who creates or updates the passport, which data they may introduce, and how
(i)	How long the passport stays available: at least the expected lifetime of the product

What goes in the passport: Annex III

The data are not fixed by ESPR. Annex III is a menu, and each delegated act states what is to be or can be included:

Annex III point	Data element
(a)	Information required under Article 7(2)(b) and Article 7(5), or by other Union law for the product group
(b)	Unique product identifier, at the level set by the delegated act
(c)	GTIN under ISO/IEC 15459-6, or equivalent, of products or their parts
(d)	Commodity codes, such as a TARIC code
(e)	Compliance documentation: declaration of conformity, technical documentation or conformity certificates
(f)	User manuals, instructions, warnings or safety information required by other Union law
(g)	Manufacturer information, including its unique operator identifier
(h)	Unique operator identifiers other than the manufacturer
(i)	Unique facility identifiers
(j)	Importer information, including its EORI number
(k)	The EU economic operator responsible under Article 4 of Regulation (EU) 2019/1020 or Article 15 of Regulation (EU) 2023/988
(l)	Reference of the DPP service provider hosting the back-up copy

Point (a) is where the sustainability content enters. Article 7(2)(b) covers, as appropriate, performance information on Annex I parameters (including a repairability score, a durability score, a carbon footprint or an environmental footprint), instructions to install, use, maintain and repair, information for treatment facilities on disassembly, reuse, recycling or disposal, and other information influencing sustainable choices. Article 7(5) requires tracking of substances of concern: name (IUPAC, EC or CAS number where available), location in the product, concentration or concentration range, safe use instructions and end-of-life information. Under Article 7(6)(b), a REACH substance of very high concern above 0.1 % weight by weight cannot be exempted from that tracking. For electronics makers this is the same substance knowledge already needed for RoHS and REACH, in a structured form.

Annex III also states that the data carrier, the unique product identifier and the operator and facility identifiers must comply with ISO/IEC 15459-1 to 15459-6 where relevant. Article 10(1)(c) and Article 12(1) apply that rule until harmonised standards are published, which happened on 15 July 2026 (next section).

Identifiers and data carrier

The text uses three kinds of identifiers. The unique product identifier designates the product at model, batch or item level. The unique operator identifier designates an actor in the chain: the manufacturer, other operators, and the economic operator responsible in the EU (Annex III points (g), (h) and (k)). The unique facility identifier designates a location or building. When a supplier or a facility has no identifier yet, the operator creating the passport must first ask whether one exists and, if not, request one on its behalf (Article 12(2) and (3)).

ESPR does not name a carrier technology. A QR code is not imposed by ESPR itself: the delegated act chooses one or more data carriers and their position (Article 9(2)(b) and (c)), and the carrier must meet ISO/IEC 15459 or now EN 18220:2026. The battery passport is the exception where the law names the carrier: Article 77(3) of the Battery Regulation requires access through the QR code of Article 13(6).

The 2026 infrastructure: standards, registry, customs

Harmonised standards (Implementing Decision (EU) 2026/1736)

Adopted on 14 July 2026 and published in the Official Journal on 15 July 2026, the decision cites six standards drafted by CEN, CENELEC and ETSI under standardisation request C(2024) 5423, as amended by C(2025) 8024. Under Article 41(2) ESPR, a passport that conforms to them is presumed to conform to the requirements of Articles 10 and 11 that they cover.

Standard	Title in the decision
EN 18216:2026	Digital product passport: data exchange protocols
EN 18219:2026	Digital product passport: unique identifiers
EN 18220:2026	Digital product passport: data carriers
EN 18221:2026	Digital product passport: data storage, archiving, and persistence
EN 18222:2026	Digital product passport: application programming interfaces (APIs) for product passport lifecycle management and searchability
EN 18223:2026	Digital product passport: system interoperability

The decision lists the six references without restrictions. The Commission DPP timeline announced an implementing decision on two remaining DPP standards for September 2026; as of 7 October 2026, the Commission page on DPP harmonised standards lists only Decision 2026/1736.

Registry (Implementing Regulation (EU) 2026/1778)

Article 13(1) ESPR required the registry by 19 July 2026, and the Commission DPP page gives 20 July 2026 as the date it became operational. Implementing Regulation (EU) 2026/1778, adopted on 16 July 2026 and published on 17 July 2026, entered into force on 6 August 2026 (Article 24). Its main rules:

Article of 2026/1778	Rule
1(1)	Scope: products under ESPR delegated acts, batteries under Article 77 of Regulation (EU) 2023/1542, construction products under Article 76 of Regulation (EU) 2024/3110, toys under Article 19 of Regulation (EU) 2025/2509, detergents and surfactants under Article 21 of Regulation (EU) 2026/405, and any other product whose Union law requires registration
2	For this Regulation, "digital product passport" includes the battery passport
3	Registry components: website, API, verification platform, scheme for unique registration identifiers, identifier and commodity code storage, list of verified DPP service providers, semantic repository, log system
4	Economic operators are verified with a qualified electronic seal (legal persons) or qualified electronic signature or "high" eID (natural persons), or an electronic attestation of attributes; verified status lasts at most three years
5	Value chain actors such as repairers and recyclers are verified the same way
7	Member States appoint a designated national administrator by 18 February 2027
8	Registration at the level set by the applicable law; if several laws require different levels, the most granular one applies; an item-level passport is linked to its batch and model identifiers where they exist; the registry automatically checks semantic conformity, granularity, commodity code and the back-up link, then issues a unique registration identifier
9	Proof of registration with a qualified electronic seal and time stamp, downloadable for 90 days after it is generated
10(3)	Where Union law sets no availability period, registration data are deleted 10 years after registration
12	Free public semantic repository of data models and vocabularies

Customs (Article 15 ESPR)

Anyone placing a product covered by an ESPR delegated act under release for free circulation must give customs the unique registration identifier, from the moment the registry is operational. Customs verify it, with the commodity code, against the registry, automatically once the registry is interconnected with EU CSW-CERTEX. That interconnection must be operational within four years of the entry into force of the registry implementing act, so by 6 August 2030 at the latest. Neither release for free circulation nor the registration identifier is proof of compliance (Articles 13(5) and 15(2)).

The battery passport (Regulation (EU) 2023/1542)

Article 77(1): from 18 February 2027, each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric-vehicle battery placed on the market or put into service must have a battery passport. Other batteries need none. Article 78 ESPR added Article 77(10), which requires the operator to upload the battery unique identifier to the ESPR registry.

Annex XIII part	Content (examples)	Who can access
1	Label information, material composition and chemistry, hazardous substances, critical raw materials, carbon footprint, due diligence information, recycled and renewable content, capacity, voltage, expected lifetime in cycles, declaration of conformity, waste information	General public
2	Detailed composition, part numbers and spare-part sources, dismantling information, safety measures	Persons with a legitimate interest and the Commission
3	Test reports proving compliance	Notified bodies, market surveillance authorities and the Commission
4	Individual battery data: performance and durability values, state of health, status (original, repurposed, re-used, remanufactured, waste)	Persons with a legitimate interest

Article 77(9) required the Commission to adopt, by 18 August 2026, implementing acts defining who counts as a person with a legitimate interest; the Commission DPP timeline lists that act for the fourth quarter of 2026. A repurposed or remanufactured battery gets a new passport linked to the original, and the passport ceases to exist once the battery is recycled (Article 77(7) and (8)). From the same 18 February 2027, Article 13(6) requires a QR code on all batteries: for batteries without a passport, it gives access to the label information, the declaration of conformity, the due diligence report where applicable and waste information. For the full battery picture, see the EU Battery Regulation guide.

How the DPP sits next to CE documentation

Aspect	Technical documentation	Digital Product Passport
Purpose	Prove conformity with product law	Give value chain actors and authorities access to product information (Article 9(3))
Who sees it	Authorities on request	Actors defined by the delegated act, with free access (Article 11(b))
Content	Set by each applicable act	Annex III menu, chosen by the delegated act; point (e) can include the declaration, technical documentation or certificates
Trigger	Any applicable directive or regulation	An ESPR delegated act, Article 77 of the Battery Regulation, or another Union act requiring a passport

The passport does not replace the technical file, and CE conformity does not create a passport. Where an ESPR act applies, the manufacturer keeps the technical documentation and declaration for 10 years unless the act sets another period (Article 27(3)). See the technical documentation file guide for its contents and the ESPR guide for conformity assessment under ESPR.

Which products come first

Track	Legal basis	Status at 7 October 2026
Batteries (LMT, industrial above 2 kWh, EV)	Article 77, Regulation (EU) 2023/1542	Applies from 18 February 2027
ESPR product groups	Delegated acts under Article 4, Regulation (EU) 2024/1781	None adopted; working plan gives indicative adoption years
Construction products, toys, detergents	Regulations (EU) 2024/3110, 2025/2509, 2026/405	Passport and registration required by those acts, at dates they set (covered by 2026/1778 Article 1(1))

The ESPR working plan, COM(2025) 187 of 16 April 2025, gives indicative adoption years: iron and steel (2026), textiles and apparel (2027), tyres (2027), aluminium (2027), repairability including scoring as a horizontal measure (2027), furniture (2028), mattresses (2029), and recycled content and recyclability of electrical and electronic equipment as a horizontal measure (2029). The Commission DPP timeline lists the iron and steel delegated act for the fourth quarter of 2026. These are adoption dates, not application dates: under Article 4(4), a delegated act applies no earlier than 18 months after its entry into force, except in duly justified cases. ICT products are not a group of their own in the plan, which covers them through the two horizontal measures and some energy-related products. Detergents, paints, lubricants, chemicals and footwear are left out of this first plan.

Two links to adjacent rules: the working plan keeps the energy label as the default for relevant energy-related products and states that EPREL can stand in for a passport where it provides equivalent information, which Article 9(4)(b) allows (see the ecodesign and energy-efficiency guide). Waste electronics remain under the WEEE Directive.

What a manufacturer can prepare now

1. Structure substance and material data. Article 7(5) asks for substance name, location, concentration and end-of-life information. Reuse the work done for RoHS, REACH and conflict-minerals due diligence, and keep it in a form that can be exported.
2. Keep compliance documents ready to link. Annex III point (e) lets a delegated act include the declaration of conformity, technical documentation or certificates.
3. Choose identifiers that fit ISO/IEC 15459 and EN 18219. Annex III mentions the GTIN under ISO/IEC 15459-6. Leave room for model, batch or item level, since the delegated act decides.
4. Plan the carrier position. The delegated act decides between product, packaging and documentation; EN 18220 covers data carriers. Marking is also a mechanical and industrialisation question.
5. Plan hosting with a back-up. Article 10(4) requires a back-up copy at a DPP service provider, and Article 11(e) requires availability after insolvency or cessation of activity.
6. Prepare registry access. Registering a passport requires a verified economic operator status under Article 4 of 2026/1778, renewed at least every three years.
7. Batteries first. If you place LMT, industrial above 2 kWh or EV batteries on the market, the battery passport applies from 18 February 2027. If your product only contains a small battery, check the QR code of Article 13(6) and the removability rules of Article 11 instead.

A worked example

Case: a mains-powered connected sensor with a small rechargeable backup battery.

The cell is not an LMT, industrial or electric-vehicle battery, so it needs no battery passport under Article 77. Two battery obligations still apply from 18 February 2027. Article 13(6) requires a QR code giving access to the label information, the declaration of conformity and waste information; Article 13(7) puts it on the battery or, where that is not possible, on the packaging and accompanying documents. If the cell is a portable battery, Article 11(1) requires it to be readily removable and replaceable by the end user, unless a derogation applies; Article 11(3) excludes cases where continuity of power supply is necessary and a permanent connection is required for user and appliance safety or, for products that collect and supply data as their main function, for data integrity reasons.

The sensor itself has no ESPR passport obligation until a delegated act covers it. The two horizontal measures of the working plan (repairability, indicative 2027; recycled content and recyclability of electrical and electronic equipment, indicative 2029) are the items most likely to reach it, and their content is not yet known. A sensible plan: settle the Article 11 and Article 13(6) position now, structure substance and material data, and choose an identifier scheme that could serve a later passport.

Claims the texts contradict

Common claim (including on an earlier version of this page)	What the text says
The DPP carrier is a QR code, a data-matrix or an RFID tag	ESPR names no technology. The delegated act chooses the carrier (Article 9(2)(b)); it must meet ISO/IEC 15459 or EN 18220:2026. Only the battery passport names a QR code (Article 77(3) of 2023/1542)
Every passport has a public tier and a restricted tier	ESPR has no tiers. Each delegated act sets which actors access which data (Article 9(2)(f)); the three-way split is specific to the battery passport (Annex XIII of 2023/1542)
The DPP carries durability, recycled content and repairability data by default	Annex III is a menu. Sustainability data enter only through the information requirements a delegated act sets (Annex III point (a), Article 7(2)(b))
The data carrier must be on the product	Article 10(1)(b): on the product, its packaging or accompanying documentation, as the delegated act specifies
A passport is per item	Article 9(2)(d): model, batch or item level, chosen by the delegated act; 2026/1778 Article 8(3) applies the most granular level when several laws apply
The Commission stores the passports in a central EU database	The registry stores identifiers, commodity codes and registration data (Article 13 ESPR, Article 3 of 2026/1778). The passport is stored by the operator or a DPP service provider (Article 11(c)), with a back-up copy at a service provider (Article 10(4))
A registration identifier proves the product complies	Article 13(5): the registry communication is not proof of compliance; release for free circulation is not either (Article 15(2))
Small batteries in electronic products need a battery passport from 2027	Article 77(1) covers only LMT, industrial above 2 kWh and EV batteries; other batteries get a QR code under Article 13(6)
There are no DPP standards yet, only ISO/IEC 15459	Six harmonised standards were cited on 15 July 2026 (Decision (EU) 2026/1736), giving a presumption of conformity with Articles 10 and 11
Electronics will need an ESPR passport from a known date	No ESPR delegated act for electronics exists. The working plan gives indicative adoption years only, and Article 4(4) adds at least 18 months before application

See also

• ESPR (EU) 2024/1781: Sustainable Products Regulation
• EU Battery Regulation 2023/1542
• Environmental compliance: what it asks of a product
• PPWR: the EU Packaging and Packaging Waste rules
• Technical documentation file: required contents

Working on preparing a product's data model and data carrier for the Digital Product Passport for a real product? AESTECHNO can audit your design and certification plan. Get in touch

Sources & references

1. Regulation (EU) 2024/1781 (ESPR), Chapter III and Annex III on the digital product passport, EUR-Lex eur-lex.europa.eu/eli/reg/2024/1781/oj
2. Implementing Regulation (EU) 2026/1778, implementation arrangements for the digital product passport registry, EUR-Lex eur-lex.europa.eu/eli/reg_impl/2026/1778/oj
3. Implementing Decision (EU) 2026/1736 on harmonised standards for digital product passports (EN 18216, EN 18219 to EN 18223:2026), EUR-Lex eur-lex.europa.eu/eli/dec_impl/2026/1736/oj
4. Regulation (EU) 2023/1542 (Batteries Regulation), Articles 11, 13, 77 and Annex XIII, EUR-Lex eur-lex.europa.eu/eli/reg/2023/1542/oj
5. COM(2025) 187, Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 (16 April 2025), European Commission (EUR-Lex) eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187
6. Digital Product Passport, Commission information page and timeline, European Commission single-market-economy.ec.europa.eu/single-market/digital-product-passport_en
7. Harmonised standards for the Digital Product Passport, Commission page, European Commission single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/digital-product-passport-dpp_en
8. Ecodesign for Sustainable Products Regulation, overview, European Commission environment.ec.europa.eu/strategy/circular-economy/ecodesign-sustainable-products-regulation_en