Digital Product Passport: What’s in store for your online shop and how to implement it in Shopware

Imagine you run a shop selling e-bikes, cycling clothing and tyres. Shopware 6, 15 staff, one warehouse, steady growth. Then you receive an email from your largest battery supplier: from February 2027, every battery will carry a QR code, which links to its battery passport, and, as a retailer, you’d be best advised to display this to your customers directly on the product page. Do you already have a field for this in your shop?

You don’t. Nobody does. Your product data model includes price, weight, colour and a description from the manufacturer’s catalogue. There’s no mention of serial numbers per battery, repairability information or recycled content.

This is the moment when the digital product passport stops being just a Brussels term for you. And the battery is only the beginning: In two or three years’ time, you’ll receive the same email from your clothing and tyre suppliers – but this time, it will be backed by a genuine legal obligation.

What the digital product passport actually is

Technically speaking, the product passport is a URL. The product, its packaging or the accompanying documents feature a data carrier – in practice, a QR code – which contains a permanent, unique product identifier. Behind this lies machine-readable, structured data based on open standards. The data remains with the manufacturer or a service provider; the EU merely maintains a register in which identifiers and basic data are stored.

“The product passport is not a document that you file away. It is a URL that accompanies your product throughout its lifetime.”

The legal basis is the EU Ecodesign Regulation for sustainable products, or ESPR (Regulation (EU) 2024/1781), which has been in force since 18 July 2024 and applies to almost all physical products in the single market. Article 9 of the ESPR stipulates: Once a passport is mandatory for a product group, the product may only be placed on the market if accompanied by a passport, and the data must be ‘accurate, complete and up to date’.

The Commission sets out, in delegated acts for each product group, what data is required, at what level the passport is maintained and how it is made available to customers. The basic technical rules are set out in Article 10.

The information contained in the passport varies by product group but follows a standard format: identification of the manufacturer and model, material composition and substances of concern, recycled content, reparability and spare parts, care and disposal. Whether the passport is maintained per model, per batch or per individual item is determined by the relevant legal act. In the case of batteries, it is the individual item, with its serial number.

When the product pass will become mandatory for which products

‘When?’ has two answers: a fixed deadline that has already been set, and a series of timeframes announced by the Commission in its work plan.

The fixed deadline stems from the EU Battery Regulation, which is already in force. According to Article 77 of Regulation (EU) 2023/1542, from 18 February 2027, every LV battery placed on the market (i.e. batteries for light vehicles such as e-bikes and e-scooters), every industrial battery exceeding 2 kWh and every electric vehicle battery must have a battery passport, accessible via a QR code on the battery. This is the email from the opening scene.

For all other product groups, the first ESPR Work Plan, which the Commission adopted on 16 April 2025. It sets out indicative years for the delegated acts; the actual obligation generally takes effect no earlier than 18 months later, in accordance with Article 4 of the ESPR.

As at October 2026. With the exception of the battery passport, all dates are indicative plans of the Commission; the delegated acts for textiles, tyres and furniture have not yet been adopted.

One thing has already happened, however, and it directly affects retailers: Since 20 July 2026, the central EU Product Passport Register has been online, including a test environment. The legal basis is Implementing Regulation (EU) 2026/1778, which has been in force since 6 August 2026. Manufacturers and importers must register their passports there before a product is placed on the market.

For fashion retailers, there is an additional development that has nothing to do with the passport but stems from the same regulation: since 19 July 2026, Article 25 of the ESPR has prohibited large enterprises from destroying unsold clothing, footwear and accessories; medium-sized enterprises will follow on 19 July 2030, whilst micro and small enterprises are exempt. Large enterprises that have previously disposed of returns in the bin once a quarter now require a documented exemption to do so.

What your online shop must do in practice

You do not need to create the passport. Responsibility lies with the economic operator placing the product on the market, i.e. the manufacturer or, in the case of imported goods, the importer. They collect the data, create the passport, register the identifier in the register and, under Article 10(4) of the ESPR, must even store a backup copy with an independent third-party service provider.

You do, however, have to show it. Article 9 of the ESPR requires that the passport be made available to customers “even in the case of distance selling” before they are bound by a sales contract; the specific legal act determines exactly how this is to be done. Retailers must, in accordance with Article 31 of the ESPR, ensure that customers and potential customers have access to all relevant product information, explicitly including in the case of distance selling.

To ensure this works, Article 10(3) obliges manufacturers, retailers and online marketplaces to provide, upon request and free of charge, a digital copy of the data medium or the unique product identifier within five working days.

Specifically: an ESPR passport must be accessible on your product detail page, either as a QR code or a link, visible before clicking ‘Add to basket’.

“You don’t have to write the pass. But you must display it before the customer makes a purchase.”

When it comes to the battery passport, the situation is less stressful for you as a retailer. That’s precisely why it serves as a dress rehearsal. The Battery Regulation places the obligation on the distributor; before you offer a battery for sale, you must check that the labelling and QR code are present. There is no obligation to link to the battery passport on the product page. Anyone who does so anyway will, from February 2027, be practising with real data exactly the procedure that will become mandatory for textiles and tyres.

This results in four tasks for your shop:

1. Maintain the identifier for each item. No passport without a unique product identifier. For model or batch passports, the GTIN per variant is sufficient. For item certificates, such as for batteries, you’ll also need the serial number, right down to the order line item, because the customer needs to be able to identify their exact battery.
2. Save and display the certificate link. One URL per product, batch or individual item, which appears on the product page, in the order confirmation and in the customer’s account.
3. Import the data from the supplier. Pass URLs and identifiers are obtained via catalogue data, delivery notes or APIs from the manufacturer and form part of the import process.
4. Clarify responsibilities. Imagine the day when the first textile passports become mandatory: 400 jackets in stock, three manufacturers have sent passport links, and the fourth hasn’t replied for two weeks. Take them offline or sell them without a passport? This decision shouldn’t be left to the shop admin at 5 pm. That’s a matter for procurement, not IT.

If, as a D2C brand, you are the manufacturer yourself, the whole first half comes into play: data collection, passport hosting, registration with the authorities, backups. Then the shop becomes the shop window for a much larger system.

Implementing a digital product passport in Shopware

Shopware does not have a product passport module in its core. Nor could it really: the data requirements for each product group have not even been finalised yet. What Shopware does have are the building blocks for a solution that starts with the battery passport and simply needs to be configured for textiles and tyres.

Data model and identifiers. For your battery shop, this means, first of all: a ‘Product Passport’ custom field set on the product with dpp_url (text), dpp_level (selection: model, batch, item) and dpp_scheme (Battery Pass, ESPR Textile and so on). The GTIN belongs in the standard field ean for each variant. Custom fields can be populated in bulk via the Admin API and Sync API and are directly accessible in the storefront’s Twig template. “Product passport: see manufacturer’s website” in the description text does not fulfil any of these requirements.

As for the identifiers themselves, the EU standards for unique identifiers and data carriers have been listed in the Official Journal since July 2026; in practice, this amounts to GS1 Digital Link, a URL containing the GTIN and, optionally, a serial number, such as https://id.deinemarke.de/01/04012345678901/21/SN12345. If, as a manufacturer, you intend to host your own product passports, build your resolver in this format now, even if it only points to a simple product page until 2027.

Serial numbers down to the order line item. For product passports, a single field on the product is not sufficient, as the serial number only comes into play during picking. A practical approach is for the warehouse or ERP to write them to the customFields of the order line via the Admin API after dispatch; no set can be configured for this in the admin panel; for larger quantities, a separate extension entity is a cleaner solution. This generates the link in the customer account: “Your battery, serial number …, open product passport.”

The storefront is the part your supplier wants to see. This refers to a block above the description tabs, directly next to “Add to basket”, which renders the QR code and link as soon as dpp_url is populated. The condition must be included in the template to ensure there are no empty tiles in categories without product passports; if you’re working with Experience Worlds and a commercial Shopware plan, the visibility of the CMS block can also be controlled via Dynamic Access using a rule. A server-side QR code generator takes an afternoon’s work, as does the printable version for the delivery note.

Material, recycled content, repairability and care instructions are product master data and belong in a PIM or at least in a well-maintained ERP system from which Shopware is populated. Anyone stocking more than a few hundred items from multiple manufacturers will find it almost impossible to do without a product passport in product data management system, as otherwise every supplier will send their passport URLs in a different format and someone will have to enter them manually.

The Shopware Store now offers the first extensions, such as a product passport generator with GS1-compatible QR codes for Shopware 6.6 and 6.7. Such plugins are of interest to D2C brands that wish to host their own passports. For retailers who simply link to manufacturers’ passports, Custom Fields plus a template block are a more streamlined option and remain under your control following the next Shopware update.

Why you shouldn’t wait until the legislation comes into force

“Build the product passport once as a data model, not three times as separate projects: first batteries, then textiles, then tyres.”

The counter-argument is obvious: for textiles, it hasn’t even been decided yet what data needs to be included. That’s true. But the bulk of the work hinges on things that are already clear today, and the data fields are the smallest part of that.

First, there are the identifiers: a GTIN for each variant, a serial number for each individual item, and an economic operator identifier for each supplier. If you’re creating variants without their own EAN, or if the serial number is handwritten on the packing slip and isn’t in any database, you’ve got a data problem that no plugin can solve. It grows with every passing month, because every new variant without an EAN and every serial number on paper will have to be entered manually later on.

These identifiers lead straight to the next question: who do you actually make enquiries to? The five-working-day rule in Article 10 only protects you if you know who to ask, and if your supply contracts address this issue. A single clause in the framework agreement (“The supplier shall provide product passport identifiers and links in machine-readable form”) is easy to negotiate today but will be costly in 2028.

And once the identifiers and suppliers are in place, the obligation becomes a selling point. Two batteries, same price, same capacity. On one, it states directly above the ‘Add to basket’ button that the cells are replaceable, spare parts will be available until 2035 and the proportion of recycled material is specified. On the other, there is no such information. Which one would someone spending 700 euros buy? Repairability, spare parts and the origin of materials are precisely the questions that are answered in-store but remain unanswered online.

Anyone who presents the ESPR Pass section on the product page as a guide gives the customer a reason to buy from this very site.

From a legal perspective, it is worth taking a look at what already applies today. Missing or incorrect mandatory information prior to purchase is a classic reason for a warning letter, and the ESPR Pass is likely to fall into the same category as the base price and cancellation policy, even if no court has yet ruled on this. We have summarised separately how you can avoid typical legal mistakes in online shops, we’ve summarised this separately.

Your roadmap to the battery pass

Back to your E-bike shop. The email from the battery supplier is a golden opportunity, as it gives you a chance to carry out a trial run using real data and without the risk of a fine. Here’s what a plan looks like that will be ready by 18 February 2027 and simply continues thereafter:

1. Phase 1, immediately: Data foundation. All variants with their own GTIN, serial numbers on the order line, ‘Product Pass’ custom field set on the product. List of suppliers with contact persons for passport data; a clause to this effect in the next framework agreement.
2. Phase 2, before the deadline: Storefront. Passport section on the product details page, QR code, link in order confirmation and customer account. Trial run with the first battery models whose manufacturers already supply passports.
3. Phase 3, from the deadline: Monitoring. A ‘Pass available’ field (checkbox) on the product, plus a dynamic product group ‘Batteries without a pass’ in the admin panel, shows the purchasing team on a daily basis which items are still outstanding. This ensures that nothing goes online without a pass once it becomes mandatory.
4. Next: Scaling. The same model for textiles and tyres as soon as the legislation is in place. A new product group then means: a new selection in the dpp_scheme field, new discussions with suppliers, and that’s it.

If you’re looking for someone to handle this process who can manage Shopware, the data model and supplier interfaces all under one roof, get in touch with us about your Shopware project. The digital product passport is one of the few obligations that can be turned into a genuine selling point if you start early enough.

Frequently asked questions about the digital product passport

Is the digital product passport already mandatory? For batteries in light vehicles, industrial batteries over 2 kWh and electric vehicle batteries from 18 February 2027 (battery passport). For textiles, tyres, furniture and other product groups, this will only apply once the relevant delegated act under the ESPR has been adopted, expected to be phased in from 2028. Our overview of digital obligations.

As a retailer, do I have to create product passports myself? No. The passport is created by the manufacturer or importer. In the case of ESPR passports, you must make it available to your customers before purchase, including online, and may request a digital copy of the data carrier from the manufacturer within five working days. For the battery passport, you must check that the QR code is present on the battery.

Does the product passport also apply in a B2B shop? Yes, as soon as your business customer purchases the product for their own use, such as a company fleet of e-bikes. The ESPR defines ‘customer’ in Article 2 as any person who buys, rents or receives a product for their own use, without distinguishing between consumers and businesses. Pure resellers are retailers, not customers.

Do I need a plugin for Shopware? Not necessarily. For retailers, custom fields, a storefront block and a clean import are sufficient. Plugins are particularly worthwhile for brands that need to host their own passports and generate QR codes.