Digital product passport (DPP)

Its legal basis is the EU Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781). The DPP is not a single document but a permanent digital identity linked to the product by a unique product identifier.

Why the digital product passport exists

With the product passport, the EU is pursuing three goals that are explicitly named in Article 9(3) ESPR. First, actors along the value chain, from the recycler to the repair shop, should be able to obtain the product information they need for their work without detours. Second, market surveillance should be able to check product conformity more easily, including at customs. Third, the traceability of products should be improved so that a circular economy can work at all: anyone who does not know what is in a product can neither repair it sensibly nor recycle it by material type.

For consumers and business customers, there is a fourth effect. Information on durability, availability of spare parts or repairability used to be scattered across data sheets, if it existed at all. The product passport bundles it in one place that can be reached before the purchase, including in online retail.

Legal basis: the ESPR and its delegated acts

The Ecodesign for Sustainable Products Regulation entered into force on 18 July 2024. It replaces the former Ecodesign Directive, which was limited to energy-related products, and applies in principle to almost all physical goods in the EU single market. The regulation itself does not yet prescribe a passport for any particular product. It creates the framework and empowers the EU Commission to adopt a delegated act for each product group that sets out the specific requirements.

Under Article 9 ESPR, such an act must determine, among other things, which data belongs in the passport, which data carrier is to be used and where it is to be placed, whether the passport is kept per model, per batch or per individual item, how customers obtain access, including in distance selling, before they are bound by a contract, who may view which data and who may update it, and how long the passport must remain available as a minimum. As soon as an act applies, products in this group may only be placed on the market with a passport, and the data must be correct, complete and up to date.

Basic requirements under Article 10 ESPR

Regardless of the product group, Article 10 sets out how a product passport must be designed technically. It is linked to a unique persistent product identifier via a data carrier. The data carrier is placed on the product, its packaging or the accompanying documents. All data is based on open standards, is machine-readable, structured and searchable and can be transferred via an interoperable data exchange network without vendor lock-in. Personal data of customers may only be stored with explicit consent. The economic operator placing the product on the market must also deposit a back-up copy of the passport with an independent third-party service provider and, on request, provide retailers and online marketplaces with a digital copy of the data carrier or the product identifier free of charge within five working days.

Which data belongs in the digital product passport

The exact data catalogue is defined for each product group but is based on Annex III of the ESPR. Typical content can be arranged in five groups:

• Identification: unique product identifier, identifier of the economic operator and of the production site, model, batch or serial number, commodity code for customs.
• Composition: materials, recycled content, substances of concern, fibre composition for textiles, cell chemistry for batteries.
• Circularity: repairability, availability of spare parts, disassembly instructions, take-back and recycling options.
• Use and care: durability and performance information, care instructions, software updates for connected products.
• Conformity: declarations of conformity, test reports, certificates and environmental information such as the carbon footprint.

Not all information is visible to everyone. The acts define tiered access rights: public data can be seen by anyone who scans the QR code; certain information is reserved for market surveillance authorities, customs or actors with a legitimate interest, such as recyclers.

When the digital product passport becomes mandatory

There is one fixed date and several indicative time windows. The fixed date does not come from the ESPR but from the EU Battery Regulation (Regulation (EU) 2023/1542): from 18 February 2027, batteries for light means of transport such as e-bikes, industrial batteries over 2 kWh and electric vehicle batteries must have a battery passport. The battery passport is therefore the first mandatory digital product passport in the EU.

For all other product groups, the first ESPR working plan, adopted by the Commission on 16 April 2025, applies. It names indicative years for the delegated acts; under Article 4 ESPR, the obligation generally applies at the earliest 18 months after the respective act enters into force.

Two building blocks are already active independently of this. Since 20 July 2026, the Commission has operated the central product passport registry under Article 13 ESPR, in which manufacturers and importers register the identifiers of their passports before placing products on the market; the associated Implementing Regulation (EU) 2026/1778 has applied since 6 August 2026. And since July 2026, the first harmonised standards of the EN 18216 to EN 18223 series have been listed in the Official Journal; they govern unique identifiers, data carriers, data exchange and interoperability of the passport.

Technology: QR code, GS1 Digital Link and registry

In practice, a product passport is a URL. The QR code on the product encodes a web address that carries a unique identifier and leads to a page or interface where the passport data is stored. GS1 Digital Link has established itself as the identification system: a URL that contains the product's GTIN and optionally a batch or serial number, for example https://id.beispielmarke.de/01/04012345678901/21/SN12345. The same URL works for checkout scanners, smartphones and machines.

The passport data itself remains with the manufacturer or a service provider commissioned by it. The EU does not store it centrally. The registry contains only the identifiers, basic data and proof of registration; authorities and customs use it to find and check passports. A back-up with an independent third-party provider ensures that the passport remains accessible even if the manufacturer disappears from the market.

Example: battery passport for an e-bike

From February 2027, a manufacturer of e-bike batteries places every battery on the market with a QR code. Behind the code is a passport at individual item level: cell chemistry, capacity, date of manufacture, recycled content of cobalt, lithium and nickel, carbon footprint, information on disassembly and take-back. The basic information is publicly visible; workshops and recyclers can additionally see data on the battery's state of health. The bicycle retailer selling the battery in the shop or online checks that the labelling and QR code are present and sensibly links to the passport on the product page, even though the Battery Regulation does not expressly require this. For textiles and tyres, precisely this accessibility before purchase will become mandatory under the ESPR.

What the digital product passport means for online shops

The passport is created by the economic operator placing the product on the market, i.e. the manufacturer or, for imported goods, the importer. Under Article 31 ESPR, retailers must ensure that customers and potential customers have access to the product information, expressly including in distance selling. For an online shop, this means that the passport must be accessible on the product detail page as a QR code or link before the customer adds the item to the basket. For this, the shop needs the unique identifier for each item, for item-level passports the serial number down to the order line, a field for the passport URL and an import process that takes this data over from the supplier. In Shopware, this can be implemented with custom fields on the product, the GTIN in the standard field and a storefront block. The article digital product passport: what's in store for your online shop provides detailed instructions.

Distinction: product passport, battery passport, material passport

The battery passport is the product-specific forerunner of the DPP from the Battery Regulation; the ESPR recognises such systems from other EU law and then dispenses with a duplicate passport. A material passport or building resource passport comes from the construction industry and documents the materials installed in a building; it is voluntary or regulated nationally and not part of the ESPR. A supply chain due diligence record under the German Supply Chain Act concerns due diligence obligations in the supply chain, not product information on the individual item. The digital product passport is the only one of these instruments that is mandatory EU-wide and is being rolled out product group by product group.

How companies prepare for the product passport

Because the specific data catalogues for each product group are still being drawn up, it is worth first creating the foundations that will be needed in every act. Manufacturers and brands should consolidate their master data, above all material composition, suppliers and production sites, and define a GS1-compliant identification strategy: GTIN per variant, serial number where the passport is kept at item level. Retailers should check whether their shop system can store identifiers and a passport URL per item, and include the topic in supplier contracts so that passport data is supplied in machine-readable form.

1. Assign product groups: which items fall under the Battery Regulation, which under the priority groups of the ESPR working plan?
2. Clarify identifiers: GTIN per variant, serial numbers down to the order line, identifiers for economic operator and production site.
3. Define the data source: PIM or ERP as the leading system, the shop only as an output channel.
4. Involve suppliers: agree passport URLs and identifiers as part of the catalogue data.
5. Prepare the display: space on the product page, in the order confirmation and in the customer account.

Frequently asked questions about the digital product passport

Is the digital product passport already mandatory?
For batteries for light means of transport, industrial batteries over 2 kWh and electric vehicle batteries from 18 February 2027. For textiles, tyres, furniture and other product groups only once the respective delegated act under the ESPR applies, probably step by step from 2028.

Who has to create the product passport?
The economic operator placing the product on the market in the EU: the manufacturer or, for imported goods, the importer. Retailers do not create passports but must make them accessible.

What happens if a product is offered without a passport?
As soon as an act applies, the product may not be placed on the market without a passport. Market surveillance authorities can prohibit its sale; the penalties are set by the Member States.

What role does the QR code play?
It is the data carrier that bears the unique product identifier and leads to the passport. Which data carriers are permissible is defined by the respective act; QR codes based on GS1 Digital Link are considered the standard solution.

Does the product passport also apply in B2B?
Yes. The ESPR defines customers as persons who buy, rent or receive a product for their own use, regardless of whether they are consumers or businesses. Pure resellers count as dealers.