PLMV-KB-013 · Regulation & Compliance · Reviewed 2026-10-16
Digital Product Passport (DPP): Requirements and Timeline
A Digital Product Passport (DPP) is a structured digital record of a product's sustainability, compliance and circularity information, accessed through a data carrier such as a QR code. The EU introduced it through the Ecodesign for Sustainable Products Regulation (EU) 2024/1781. The first mandatory passport is the battery passport from 18 February 2027.
Key takeaways
- The DPP is defined in ESPR, and its content for each product group is set in product-specific delegated acts.
- The EU DPP registry went live on 20 July 2026, and six harmonised technical standards were cited in July 2026.
- Batteries come first (18 February 2027), with iron and steel, textiles, tyres and aluminium following through ESPR delegated acts.
- Passport data originates in PLM, compliance and supply chain systems, so identifiers and data ownership need to be settled early.
How the DPP is defined in EU law
The legal basis is the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, which entered into force on 18 July 2024. ESPR sets the general rules for passports: each must be linked to a unique product identifier, accessible through a data carrier, based on open and interoperable standards, and kept available for a period set per product group. The exact content and granularity (model, batch or individual item) are defined in delegated acts for each product group. Sector laws also use the concept. The EU battery passport under Regulation (EU) 2023/1542 is the first mandatory example, and the revised construction products and toy safety rules also refer to digital passports.
What has been put in place in 2026?
Three building blocks were delivered in July 2026:
- Harmonised standards: Commission Implementing Decision (EU) 2026/1736 of 14 July 2026 cited six CEN/CENELEC standards: EN 18216 (data exchange protocols), EN 18219 (unique identifiers), EN 18220 (data carriers), EN 18221 (data storage, archiving and persistence), EN 18222 (APIs for lifecycle management and searchability) and EN 18223 (interoperability).
- Registry: the EU DPP registry required by Article 13 ESPR went live on 20 July 2026. Its operating rules are set in Implementing Regulation (EU) 2026/1778, applicable since 6 August 2026. The registry stores identifiers and the location of each passport. Passport content stays with the economic operator or a DPP service provider.
- Pending items: two further standards on access rights and data integrity were still in draft at the latest update reviewed (August 2026).
No company had to register product passports at launch. Registration obligations start when the delegated act for a product group applies. ESPR also foresees rules on independent DPP service providers that may host passports on behalf of economic operators, and passports must remain available for the period defined per product group, even if the original operator ceases trading. In practice this pushes organisations towards a backup copy held by a certified service provider.
Which products need a DPP and when?
| Product group | Legal basis | Status (October 2026) |
|---|---|---|
| EV, LMT and industrial batteries over 2 kWh | Regulation (EU) 2023/1542 | Mandatory from 18 February 2027 |
| Iron and steel | ESPR delegated act | Call for evidence closed August 2026; adoption expected Q4 2026 |
| Textiles and apparel, tyres, aluminium | ESPR delegated acts | Indicative adoption 2027 |
| Furniture, mattresses | ESPR delegated acts | Indicative adoption 2028 and 2029 |
ESPR generally provides at least 18 months between adoption of a delegated act and application, so most non-battery passports are unlikely to be mandatory before 2028. These dates come from the ESPR working plan and are indicative. The Environmental Omnibus proposal of December 2025 also names the DPP as a future alternative to the SCIP database for substances in articles, which remains subject to the legislative process.
Which data does a passport need?
Content varies by product group, though the following elements recur in ESPR and the battery passport:
| Data element | Typical source system |
|---|---|
| Unique product, operator and facility identifiers | PLM, ERP, GS1 registries |
| Commodity code (CN/HS) | ERP, trade compliance |
| Material composition and recycled content | PLM bill of materials |
| Substances of concern and their location in the product | Compliance software |
| Carbon or environmental footprint | LCA tools |
| Repair, disassembly and end-of-life instructions | PLM, technical documentation |
| Declarations of conformity and certificates | Compliance, quality |
| User information and warnings | PIM, DAM |
Identifiers and data carriers are covered in GS1 Digital Link and the DPP.
How should PLM and PIM teams prepare?
Passport content is assembled from several systems, so the digital thread between engineering, compliance and commercial data determines how much manual work remains. Start by deciding the passport granularity your products are likely to need, assigning a unique identifier scheme, and tracing each likely data element to an authoritative source. Enterprise PLM platforms such as Siemens Teamcenter and PTC Windchill, and fashion PLM such as Centric Software, are adding passport-related functions, often alongside specialist DPP service providers. PIM systems typically publish the consumer-facing layer; resources such as PIM Selection cover how to assess PIM for regulatory content.
Frequently asked questions
When does the Digital Product Passport become mandatory?
The first mandatory passport is the EU battery passport, from 18 February 2027 for EV batteries, light means of transport batteries and industrial batteries above 2 kWh. Other product groups follow once their ESPR delegated acts are adopted and apply, usually at least 18 months after adoption. Iron and steel is expected first, with textiles, tyres and aluminium indicated for 2027 adoption.
What is the EU DPP registry?
The registry is a Commission-run index required by Article 13 ESPR. It went live on 20 July 2026 under Implementing Regulation (EU) 2026/1778. It records unique product identifiers, where each passport can be found and, for imported goods, commodity codes, so customs and market surveillance can check passports. The passport data itself stays with the economic operator or its DPP service provider.
Does a DPP replace product labels?
No. Labels, markings and instructions required by other EU laws remain. The passport adds a digital layer reached through a data carrier on the product, packaging or documentation. Some information may move from paper to the passport where a delegated act allows it, though physical labelling obligations such as CE marking or energy labels continue to apply.
Sources
- Regulation (EU) 2024/1781 Ecodesign for Sustainable Products (EUR-Lex)
- Implementing Regulation (EU) 2026/1778 on the DPP registry (EUR-Lex)
- European Commission: Ecodesign for Sustainable Products Regulation
Reviewed 16 October 2026 by the PLM Vendors editorial team. Regulatory dates and vendor details change; check the sources for the latest position.