What is a Digital Product Passport?

A Digital Product Passport (DPP) is a structured, machine-readable set of data about a physical product, made accessible through a data carrier such as a QR code, a data-matrix or an RFID tag printed on or attached to the item. Scanning the carrier resolves a unique product identifier to an online record holding sustainability and compliance information: material composition, recycled content, repairability, substances of concern, end-of-life instructions and links to compliance documents. The DPP is introduced as a horizontal tool by the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 and is rolled out product group by product group through delegated acts.

Is the Digital Product Passport mandatory yet?

Not as a single switch. The ESPR creates the legal framework, but the obligation becomes concrete only when a delegated act for a given product group sets the required data fields and the start date. The first binding instance is the battery passport under the EU Battery Regulation (EU) 2023/1542, which applies to certain batteries placed on the market from February 2027. Other groups, such as electronics, textiles or iron and steel, follow a phased schedule defined by the ESPR working plans and their own delegated acts.

What data does a DPP contain?

The exact fields are fixed per product group by the relevant delegated act, but the recurring categories are: unique product identifier and unique operator identifier, material and substance composition (including substances of concern), recycled content share, durability and reliability indicators, repairability and spare-part availability, disassembly and recycling instructions, the compliance documentation (declaration of conformity, test reports references) and the responsible economic operator. Data is split into access tiers so not every field is public.

Who can read the data in a Digital Product Passport?

Access is tiered. A public tier is open to anyone who scans the carrier, typically consumers checking durability, repairability or recycling guidance. A restricted tier is reserved for defined actors: market surveillance authorities, customs, repairers, remanufacturers and recyclers, who may see fields such as dismantling sequences or hazardous-substance locations that are not exposed to the general public. The delegated act for each product group defines which field sits in which tier.

How does the DPP relate to the CE marking and the technical file?

They overlap but are not the same. The CE marking and the technical documentation prove conformity with the applicable product directives and regulations; the DPP is an information and circularity instrument that points to some of that same evidence (for example a declaration of conformity reference) while adding sustainability data the technical file never carried. A DPP does not replace the technical file, and CE conformity does not by itself satisfy a DPP obligation. The two run in parallel.

Which product groups get a Digital Product Passport first?

Batteries lead, through the dedicated battery passport in the EU Battery Regulation (EU) 2023/1542. Under the ESPR itself, the first ESPR working plan flags priority groups including electronics (and ICT), textiles and apparel, furniture, tyres, iron and steel, aluminium and certain chemicals. The precise sequence and the per-group start dates are set by delegated acts, so they should be treated as phased rather than as a single fixed date.

What should a manufacturer start doing now to prepare?

Map your bill of materials and substance data so it can be exported in a structured form, secure a unique product identifier scheme (for example a GTIN plus a serial or batch identifier), confirm how you will physically apply a data carrier without harming the product, and identify which downstream actors (recyclers, repairers) will need restricted data. Aligning early with the battery passport requirements is the most concrete starting point, because it is the first one with a firm date.

Digital Product Passport (DPP) under the ESPR

Author Hugues Orgitello Last updated 28 May 2026 ~11 min read

Guide · Circular economy data infrastructure

The Digital Product Passport (DPP) is the data backbone of the European Union's push toward a circular economy. Instead of leaving a product's sustainability and compliance information scattered across datasheets, labels and internal files, the DPP gathers a defined set of that data into a structured, machine-readable record and makes it reachable from the physical item through a scannable data carrier. It is introduced as a horizontal instrument by the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (the ESPR), and it is being rolled out product group by product group rather than all at once. This guide explains what the DPP is, what it carries, how it is accessed, which products come first, how it sits alongside the existing CE technical file, and what a manufacturer should start preparing now. It is a deep-dive companion to the broader ESPR guide.

What the DPP actually is

A Digital Product Passport is not a document and not a website page. It is a structured dataset, expressed in a defined, interoperable format, that describes one product (or one model, batch or item, depending on the rule) and is bound to that physical object by a data carrier. Scanning the carrier resolves a unique product identifier to the corresponding record, which is hosted in a decentralised way by the responsible economic operator or its service provider rather than in one central EU database.

Three things make the concept work:

A data carrier physically present on the product, its packaging or its documentation. The carrier is a 2D barcode (typically a QR code or a data-matrix) or an RFID tag.
A unique identifier that the carrier encodes, so that scanning always reaches the right record. The framework distinguishes the product identifier from the operator identifier.
A registry and a data store. The European Commission maintains a registry of identifiers, while the actual passport data lives with the economic operator under defined availability and persistence rules.

The result is that anyone, from a consumer in a shop to a recycler at end of life, can point a phone or a reader at the item and obtain the part of the data they are entitled to see.

Why the DPP exists

The DPP is a means, not an end. Its purpose is to make the rest of the ecodesign agenda enforceable and useful. The Regulation (EU) 2024/1781 sets ecodesign requirements (durability, reparability, recycled-content minimums, restrictions on substances of concern) and the DPP is the mechanism that exposes whether a given product meets them and lets actors down the value chain act on it.

Concretely, the passport is meant to:

Empower consumers and professional buyers to compare products on durability, repairability and environmental footprint before purchase, not just on price and features.
Support repair and reuse by giving repairers access to spare-part information, disassembly guidance and diagnostic data that today is often locked away.
Make recycling more efficient by telling recyclers what materials and hazardous substances are inside an item and how to separate them.
Help market surveillance authorities verify compliance quickly, by pointing them to declarations of conformity and underlying data.
Reduce information asymmetry along the value chain, so that recycled-content claims, substance declarations and durability figures can be checked rather than merely asserted.

This circular-economy framing is why the DPP is owned, on the policy side, by the environmental strand of EU product law and connects naturally to instruments such as the WEEE Directive for waste electronics and the broader ecodesign and energy-efficiency regime.

The data carrier and the unique identifier

The link between the physical object and its digital record is the heart of the system, so the framework is specific about it.

The carrier

The carrier must be a machine-readable data carrier, physically present on the product, its packaging, or accompanying documentation. In practice this means one of:

Carrier	Typical use	Notes
QR code	Most consumer products	Cheap to print, scans with any phone camera
Data-matrix	Small items, electronics PCBs	Higher data density in a small footprint
RFID / NFC tag	Logistics, high-value or harsh-environment goods	Readable without line of sight, costs more

The carrier itself does not store the full passport. It encodes a pointer (the identifier and a resolver link) so that the data can be updated over the product's life without re-marking the item. That distinction matters: a durability or repair record can change after sale, and the carrier must keep resolving to the current data.

The identifiers

The framework separates several identifier roles. The two that matter most for a manufacturer are:

The unique product identifier, which designates the product (often at model or item level). Existing schemes such as a GTIN combined with a serial or batch number can usually feed this.
The unique operator identifier, which designates the responsible economic operator placing the product on the market.

A registry operated by the European Commission stores these identifiers so authorities and customs can find a passport even if a company changes its web infrastructure. The passport data must remain available for a defined period, including after the operator that created it ceases trading, which is one reason the data store cannot simply be an ordinary product webpage.

What goes inside the passport

The exact list of fields is not fixed by the ESPR itself. The regulation sets the framework and then a delegated act per product group defines which data elements are required, in what format, and in which access tier. That is a deliberate design choice: a battery, a t-shirt and a steel beam need very different data.

That said, the recurring data categories across the framework and the early delegated acts are:

Category	Examples of fields
Identification	Unique product identifier, operator identifier, model, batch or serial
Material composition	Materials and their share, critical raw materials present
Substances of concern	Presence, location and concentration of hazardous substances
Recycled content	Share of recycled material, by material where relevant
Durability and reliability	Expected lifetime, durability test results, warranty terms
Repairability	Reparability indicators, spare-part availability and lead time
Disassembly and recycling	Dismantling sequence, separation instructions, end-of-life routing
Compliance	Declaration of conformity reference, relevant test or compliance documents
Carbon and environmental footprint	Where the product group rule requires it

Two of these deserve emphasis for electronics makers. Substances of concern ties the DPP into the chemicals regime: the passport is expected to surface the same hazardous-substance information that obligations like the RoHS restriction and REACH already require companies to know, but in a structured, queryable form. And the compliance category is where the DPP touches CE conformity, by referencing (not replacing) the declaration of conformity.

Access tiers: public versus restricted

Not every field is meant for the general public. A core design principle of the DPP is tiered access, so that the data carrier returns different views depending on who is asking.

Public tier. Information any consumer or buyer should be able to see by scanning: durability, repairability indicators, recycled-content share, basic recycling guidance, and the existence of a declaration of conformity.
Restricted tier. Information limited to defined actors. Repairers and remanufacturers may need detailed disassembly steps and diagnostic access; recyclers may need the exact location and concentration of hazardous substances; market surveillance authorities and customs may need the full compliance picture. Some commercially sensitive data is shielded from competitors while remaining available to authorities.

The per-group delegated act assigns each field to a tier and defines which categories of actor may read the restricted fields. For a manufacturer this means the data model has to be built with access control in mind from the start, not bolted on later. A practical consequence: you cannot satisfy the restricted tier by simply publishing everything on an open page, nor satisfy the public tier by locking everything behind a login.

How the DPP interacts with CE documentation and the technical file

This is the question that matters most to anyone already running a CE compliance programme, and it is easy to get wrong. The short answer: the DPP and the technical file are complementary, not interchangeable.

Aspect	Technical documentation file	Digital Product Passport
Primary purpose	Prove conformity to product law	Make sustainability and circularity data accessible
Audience	Authorities on request	Public and restricted actors, by tier
Format	Held by the manufacturer, any documented form	Structured, machine-readable, interoperable
Content	Design, risk analysis, test reports, the declaration of conformity	A defined subset plus sustainability data the file never held
Trigger	Required when a directive or regulation applies	Required when a product-group delegated act applies

Key points to hold onto:

The DPP does not replace the technical file. You still build and keep the technical documentation that the applicable directives demand. See the dedicated guide to the technical documentation file within the ESPR programme for how ecodesign data slots into it.
CE conformity does not by itself create a DPP. A product can be perfectly CE-marked and still lack a required passport once its delegated act applies. The two obligations are layered.
They share evidence. The passport references the declaration of conformity rather than reproducing it, and pulls substance and material data that the compliance work already generated. Well-organised compliance data feeds the DPP cheaply; disorganised data makes the DPP expensive.

The practical takeaway is that the DPP rewards manufacturers who treat compliance data as structured, reusable information rather than as a pile of PDFs assembled per audit.

Which products come first: a phased rollout

The DPP does not arrive everywhere at once. Two tracks run in parallel.

Batteries lead, through their own regulation

The first concrete, dated DPP is the battery passport, created not by the ESPR but by the dedicated Regulation (EU) 2023/1542 (the EU Batteries Regulation). It requires a passport for certain batteries (notably LMT, industrial and electric-vehicle batteries above a capacity threshold) placed on the market from February 2027. Because it is the first one with a firm date and a defined data set, the battery passport is the de facto template the rest of the ecosystem is learning from. The full picture for batteries, including carbon-footprint and recycled-content rules, is covered in the EU Battery Regulation guide.

Other groups follow under the ESPR working plans

Under the ESPR itself, priority product groups are identified in the regulation and refined in the ESPR working plan. The early priorities flagged include:

Electronics and ICT equipment
Textiles and apparel (notably finished garments)
Furniture
Tyres
Iron and steel
Aluminium
Certain chemicals

For each of these, a delegated act will set the required ecodesign parameters, the DPP data fields, the access tiers and the application date. Until that delegated act is adopted, there is no fixed DPP date for the group. This is why the timeline must be described as phased: the framework exists, batteries have a 2027 anchor, and the remaining groups are sequenced through delegated acts over the following years rather than on a single published deadline.

Track	Legal basis	Status
Battery passport	Regulation (EU) 2023/1542	Dated: from February 2027 for in-scope batteries
Electronics, textiles, others	Regulation (EU) 2024/1781 plus per-group delegated acts	Phased: dates set group by group

A note on accuracy worth repeating: beyond the battery passport, treat any specific calendar date you see for electronics or textiles with caution unless it cites the adopted delegated act for that group. The working plan signals priority and sequence; the delegated act sets the binding date.

What a manufacturer should start preparing

Even without a delegated act for your product group yet, several preparations have a positive return regardless of the eventual date, because they are the same data hygiene that good compliance already needs.

Data foundations

Structure your bill of materials and substance data. The single biggest determinant of DPP cost is whether material composition, recycled-content figures and substances-of-concern data already exist in a structured, exportable form, or whether they are buried in supplier emails and PDFs. Start collecting it in machine-readable form now.
Pin down recycled-content evidence. Recycled-content claims will have to be substantiated, not asserted. Establish how each supplier documents recycled input and keep that chain of evidence.
Map your substances of concern. Reuse the work already done for RoHS, REACH and your conflict-minerals due diligence; the DPP largely asks for the same facts in a queryable shape.

Identifiers and carriers

Choose an identifier scheme. A GTIN plus a serial or batch identifier is the common starting point. Decide early whether you passport at model, batch or item level, because it changes how you mark and track units.
Plan the physical carrier. Decide where a QR, data-matrix or RFID carrier can live on the product without harming function, aesthetics or durability, and how it survives the product's expected life. Marking is a mechanical and industrialisation problem, not only a software one.
Design for a resolver, not a static page. Because the carrier must keep resolving to current data for years, plan a hosting and resolver approach that outlives a single web redesign, and account for the persistence-after-cessation requirement.

Access and downstream actors

Build access control into the data model. Separate public fields from restricted ones from day one, and decide which downstream actors (repairers, recyclers, authorities) get which view.
Talk to your recyclers and repairers. They are the customers of the restricted tier. Knowing what disassembly and substance data they actually need keeps you from over- or under-disclosing.

Sequencing your effort

Anchor on batteries if relevant. If any product you place on the market contains an in-scope battery, the battery passport gives you a dated, concrete first target and a working template. Even if it does not, studying the battery passport data model is the best available preview of what your own group's delegated act is likely to demand.

A realistic posture for an electronics manufacturer in 2026 is: assume a DPP will apply to your category within the ESPR programme, get your material and substance data into structured form now, solve the battery passport where it bites first, and avoid committing to a specific non-battery date until the relevant delegated act is published.

A worked example

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

This product sits at the intersection of two DPP tracks. Its rechargeable cell may fall under the battery passport regime of Regulation (EU) 2023/1542 depending on chemistry and capacity, giving a dated obligation around February 2027 for the battery aspect. The electronics enclosure and the device as a whole fall under the ESPR electronics priority, whose DPP requirements will be set by a later delegated act and so are phased, not yet dated.

A sensible plan for the maker:

Treat the battery passport as the firm near-term deliverable, using its data set as the template.
Begin structuring the device's full material composition, recycled-content and substances-of-concern data now, so the electronics DPP becomes a matter of exporting existing structured data rather than a fresh data-collection project.
Choose a single identifier and carrier strategy that can serve both the battery and the whole-device passport, to avoid marking the same unit twice.

This is the typical shape of DPP readiness for electronics: one dated obligation to satisfy first, and a structured-data foundation that makes the phased obligations cheap when they arrive.