Digital Product Passports in the EU – Comprehensive Expansion under the Ecodesign for Sustainable Products Regulation and what can be learnt from the Battery Passport Pilot

The DPP is part of a broader regulatory push to improve the sustainability performance of products throughout their lifecycle and empower consumers and businesses with reliable information. As part of the Green Deal and Circular Economy Action Plan, it has been formally introduced by the ESPR which entered into force on 18 July 2024 and applies to almost all physical goods placed on the EU market (extending beyond energy-relevant products). The ESPR empowers the European Commission to set specific sustainability criteria, performance and information requirements, and provides the legal basis for the DPP to serve as a tool to ensure compliance and traceability of these criteria. Both the product-specific ecodesign requirements and the DPP requirements need to be established via delegated acts for individual product categories. The European Commission is expected to adopt delegated and implementing acts under ESPR defining DPP data requirements between 2027-2028. Products that are planned to be covered in the first instance include textiles, electronics, furniture, detergents, paints and metals. By 2030, the EU plans a progressive extension to almost all physical consumer and industrial products to adopt DPPs.

The European Standardisation Organisations CEN and CENELEC are already working on harmonized standards to create a functioning IT ecosystem to deploy the DPP. Additionally, major industry consortia (e.g., OPC Foundation, Industrie 4.0, DPP4.0) are collaborating to ensure interoperability between DPP data ecosystems.

Apart from the ESPR, some other regulatory acts such as the Battery Regulation, the Construction Products Regulation and the upcoming Toy Safety Regulations, and the proposed End-Of-Life Vehicle Regulation already include a dedicated DPP (more on the Battery Passport below).

In addition, the European Commission has also recently launched a call for evidence for an initiative to update the New Legislative Framework (NLF) to integrate digital solutions into EU legislation, which also includes the introduction of DPPs. Currently, the regulatory acts that are part of the NLF are being revised to integrate information on digital compliance to avoid inconsistencies and establish a cohesive framework. 

General purpose:

The DPP is envisioned as a digital record for product related information that travels with a product throughout its entire lifecycle. It acts as a centralized source of trustworthy data accessible by different stakeholders such as manufacturers, regulators, recyclers, repairers, and consumers. According to the plans of the European Commission it will allow access to all essential documents required under EU product legislation, even if one product is covered by multiple pieces of legislation. In that case the requirements of the DPP must be met and the specific information for that applicable piece of legislation must be provided in the DPP as well. Details will be specified in the product-specific acts under the ESPR. In this way, the DPP is intended to help promote transparency, traceability and sustainability of products, as the relevant data must be updated throughout the entire life cycle.

Information requirements and accessibility:

While the extents are yet to be defined in product-specific delegated acts, the DPP will likely include the following information:

• Product identification: Model, manufacturer, etc.
• Technical performance: Information on product performance metrics, such as durability, energy efficiency, and technical specifications, digital Declaration of Conformity and digital instructions for use.
• Origin and materials used: Details on materials and their origins, enabling full traceability throughout the product lifecycle.
• Environmental impact: Lifecycle environmental data - including resource use, carbon footprint, environmental performance, and compliance documentation.
• Repair, recycling, and disposal recommendations: Data on repairability, recyclability, recycling options, and proper disposal instructions.

This information will be accessible through a digital system, probably via a QR code on the product, facilitating informed decisions by consumers, businesses, and authorities. This way, voluminous paper documentation is eliminated. The ESPR provides for differentiated access to DPP data depending on the role and legitimate interest of the requesting party which will be further specified in the product-specific acts. For example, market surveillance authorities are expected to gain full access to all relevant data for enforcement, while consumers are expected to have rather limited access, or other economic operators (e.g., importers, distributors, recyclers) are expected to gain access to data needed for their respective legal obligations.   

Technical infrastructure:

According to the ESPR, the DPP is built on a decentralized data system, meaning manufacturers, importers, repairers, recyclers and other economic operators are responsible for managing the DPP for their products. Data hosting and maintenance are to be done by the companies themselves, either directly or through authorized third-party providers. To ensure availability of DPPs even after cessation of activities of economic operators in the EU, e.g., due to insolvency or liquidation, responsible economic operators will further be obliged to provide a back-up copy of the DPP through a DPP Services provider. By July 2026, the European Commission will deploy a central DPP registry to support enforcement and transparency. Furthermore, the European Commission plans to roll out a publicly accessible portal allowing users to search and compare DPP data, in line with delegated act rules.

Regarding third-party DPPs Service Providers the European Commission will define requirements and certification schemes under delegated acts. Such certified providers - software or platform companies - will host product DPP data and ensure compliance with access rules, standards, and cybersecurity obligations. In April 2025, the European Commission launched a public consultation for the first delegated act in that series, the delegated act setting out the requirements that DPP Service Providers are to comply with to become such providers, and, where appropriate, a certification scheme to verify compliance with such requirements. Following this public consultation, the European Commission published a final summary report in August 2025, in which issues such as DPP availability and key DPP characteristics were highlighted and which will build the basis for the upcoming delegated act.

The Battery Regulation offers a sneak peek at how the DPP concept could work in practice. Among the newly introduced innovative tools by the Battery Regulation is the Battery Passport, an electronic record for specific battery types.

The Battery Passport will play a crucial role in ensuring transparency, traceability, and compliance across the battery’s life, supporting circular economy goals.

Implementation timeline:

The Battery Passport becomes mandatory from 18 February 2027. From this date, all covered batteries placed on the EU market or put into service must be accompanied by a Battery Passport in compliance with the EU Battery Regulation.

Batteries covered:

The EU Battery Regulation distinguishes several battery types, but the Battery Passport requirements apply to:

• Industrial batteries with a capacity above 2 kWh
• Electric vehicle (EV) batteries
• Light means of transport (LMT) batteries (e.g., for e-scooters or e-bikes)

Information requirements and accessibility:

The Battery Passport shall be made accessible via a QR code which links to a unique identifier providing access to a secure online database.

It includes key information such as:

• General information: Battery type and model, unique identifier, manufacturer details, place and date of production.
• Battery composition and materials: Details on chemicals, metals, and components used, including critical raw materials.
• Performance, safety and compliance information: Technical specifications, certifications, safety test results, declarations of conformity.
• Environmental impact and carbon footprint: Lifecycle emissions and environmental data.
• Recycling and end-of-life instructions: Guidance for disassembly, repair, and recycling pathways.

A standardization for core Battery Passport data was already released in early 2025. Access to this information will vary with some data restricted to notified bodies, market surveillance authorities, and the European Commission, whilst unrestricted data is publicly accessible or accessible to any natural or legal person with a legitimate interest. The latter group will be specified via implementing acts by the European Commission and this may include, for example, repairers, remanufacturers, second-life operators, and recyclers which may need to get access to information concerning dismantling of the battery, including safety measures, detailed composition of the battery and other essential information to allow them to conduct their activities.

Obligations of main economic operators:

Under the Battery Regulation, obligations differ according to the individual roles of economic operators:

• Manufacturer: The economic operator placing a battery on the EU market must create the battery passport for each individual battery model, ensure the data accuracy and completeness, update the passport throughout the product’s life as needed (e.g., when supply chain or performance data changes), and provide access to it via a QR code on the battery (or its packaging/documents).
• Importers: If the manufacturer is outside the EU, the importer or designated authorized representative assumes the same obligations as a manufacturer once they place the battery on the market.
• Distributor: Distributors must preserve integrity of the battery passports and ensure their accessibility. If they modify or relabel the battery, they assume responsibility of a manufacturer.
• Independent Operator (Repair, Remanufacturing, Repurposing, Re-use): Operators who reuse, repurpose, or remanufacture batteries and place them back on the market or put them into service, must create a new battery passport and assume full legal responsibility for its completeness and maintenance. This new passport must be linked to the original one(s).
• Waste Management Operators / Holders of Waste Batteries: Once a battery becomes waste, the waste holder must ensure the battery passport remains accessible. Waste management operators may add information related to end-of-life treatment, such as recycling efficiency, recovered materials, and compliance with, for instance, extended producer responsibilities.