Regulations •

Digital Product Passport EU: All Regulations and Obligations at a Glance

Digital Product Passport EU obligation: Which regulations (ESPR, Battery Regulation, Construction Products Regulation) mandate the DPP, which products are affected, the timeline through 2030, and what companies need to do now.

Author: myDPP Team

Digital Product Passport EU: All Regulations and Obligations at a Glance

Key Takeaways

The Digital Product Passport (DPP) is not introduced by a single EU regulation but through several parallel legislative processes. The four most important are the ESPR (Ecodesign for Sustainable Products Regulation), the EU Battery Regulation, the Construction Products Regulation (CPR) and the EU Toy Safety Regulation. For companies operating in the European single market, the key question is: Does the DPP obligation apply to my products, and if so, from when? This article provides a complete overview of all EU regulations that mandate a Digital Product Passport, the respective timelines, and the specific obligations for manufacturers, importers, and distributors.

If you are not yet familiar with the DPP as a concept, we recommend our introductory article Digital Product Passport in 15 Minutes.

Why Multiple Regulations?

The EU is pursuing an overarching goal through the Green Deal and the Circular Economy Action Plan: to accelerate the transition to a circular economy and increase transparency along value chains. The Digital Product Passport is a central tool in this effort. Since different product categories have different requirements, the EU has not issued a single regulation but instead integrated the DPP into multiple sector-specific regulatory frameworks.

The result: There is no single “DPP deadline” for all products. Instead, obligations, data fields, and deadlines depend on the respective regulation and product category. For companies with a diverse product portfolio, this means they may fall under multiple regulations simultaneously.

The Four Core EU Regulations with DPP Obligations

1. ESPR - Ecodesign for Sustainable Products Regulation

The ESPR (Regulation (EU) 2024/1781) is the most comprehensive regulatory framework and forms the general framework for the DPP. It replaces the old Ecodesign Directive from 2009 and massively expands its scope.

Affected products: Nearly all physical products placed on the EU market. The specific requirements are defined through delegated acts for each product category.

Prioritised categories:

  • Textiles and apparel
  • Iron and steel
  • Aluminium
  • Furniture (including mattresses)
  • Tyres
  • Detergents
  • Paints and coatings
  • Electronics and ICT equipment (later wave)

DPP requirements:

  • Structured digital dataset per product
  • Accessible via data carrier (QR code/GS1 Digital Link)
  • Machine-readable and human-readable
  • Linked to EU DPP Registry
  • Data fields defined per category in the delegated act

Timeline: First delegated acts from 2025/2026, product-specific obligations from 2026-2028 (depending on the category).

2. EU Battery Regulation

The EU Battery Regulation (Regulation (EU) 2023/1542) was the first EU regulation to explicitly mandate a Digital Product Passport. It is considered the blueprint for the DPP in other sectors.

Affected products:

  • Industrial batteries with a capacity above 2 kWh
  • Traction batteries (for electric vehicles)
  • Batteries for light means of transport (e-bikes, e-scooters)

DPP requirements (Battery Passport):

  • Information on capacity, performance, durability, and lifespan
  • Carbon footprint of battery production
  • Share of recycled material (cobalt, lithium, nickel, lead)
  • Information on collection, treatment, and recyclability
  • Supply chain information and due diligence obligations
  • Access via QR code with unique identifier

Timeline:

DateMilestone
August 2023Battery Regulation entered into force
February 2025Carbon footprint declaration for EV batteries
February 2027Battery Passport (DPP) mandatory for industrial, traction, and LV batteries
August 2028Minimum recycled content shares (first stage)
August 2031Minimum recycled content shares (second stage)

The Battery Regulation is particularly relevant for the automotive and energy storage industries. Detailed information can be found in our article on the Battery Passport.

3. Construction Products Regulation (CPR)

The new Construction Products Regulation (EU) 2024/3110 also introduces a DPP for construction products. It was adopted on 27 November 2024, entered into force on 7 January 2025 and applies from 8 January 2026, replacing Regulation (EU) No 305/2011. The passport obligation itself, however, arrives product family by product family, together with the new harmonised technical specifications.

Affected products:

  • Cement, concrete, and aggregates
  • Steel and metal components
  • Insulation materials
  • Windows and doors
  • Sanitary products
  • Other construction products falling under harmonised standards

DPP requirements:

  • Declaration of Performance in digital form
  • Environmental Product Declaration with life cycle data
  • Information on recyclability and reusability
  • Information on hazardous substances
  • Machine-readable data for BIM systems (Building Information Modeling)

Timeline: Adopted on 27 November 2024, in force since 7 January 2025, applicable from 8 January 2026. The passport obligation itself arrives product family by product family with the new harmonised technical specifications - realistically from around 2028, with the old regime phasing out into the 2030s.

4. EU Toy Safety Regulation

The EU Toy Safety Regulation (EU) 2025/2509 goes further than any of the above: it is the first piece of EU product law in which the digital product passport does not sit alongside an existing obligation but replaces one. For toys, the passport takes the place of the EU declaration of conformity. It was adopted on 25 November 2025, published on 12 December 2025 and entered into force on 1 January 2026.

Affected products: every toy placed on the EU market - no size or category threshold.

DPP requirements:

  • Passport mandatory for every toy, replacing the EU declaration of conformity
  • Data carrier on the toy itself or on an attached label, accessible before purchase
  • Available in the official languages of every member state of sale
  • Statement of conformity, CE marking, customs commodity code, notified body details
  • Instructions, warnings and safety information including allergenic fragrances
  • Contact channel for safety matters and a reference to the DPP service provider
  • Product identifier and operator identifier registered in the central EU registry set up under the ESPR

Timeline: general application from 1 August 2030, when Directive 2009/48/EC is repealed; type-examination certificates issued under the old directive expire on 1 February 2031. Technical specifications for the passport are to be set by delegated act before then.

How this substitution works across sectors is covered in our article on the DPP replacing the EU declaration of conformity.

In addition to the four core regulations, there are further EU initiatives that relate to or complement the DPP:

  • EU Textile Strategy: Specific requirements for textile products are implemented through ESPR delegated acts, but the Textile Strategy defines additional transparency requirements (e.g., prohibition of greenwashing claims).
  • EU Deforestation Regulation (EUDR): Requires traceability data for raw materials such as soy, palm oil, timber, and rubber. This data can feed into the DPP.
  • Corporate Sustainability Reporting Directive (CSRD): Requires comprehensive sustainability reporting. DPP data can serve as a basis for product-related reporting.

Digital Product Passport: Which Products Are Subject to the Obligation?

The following table summarises which product categories fall under which regulation and when the DPP obligation is expected to apply.

Product categoryRegulationDPP obligation from (expected)
Industrial and EV batteriesBattery RegulationFebruary 2027
Textiles and apparelESPR (delegated act)2027-2028
Iron and steelESPR (delegated act)2027-2028
AluminiumESPR (delegated act)2027-2028
Furniture and mattressesESPR (delegated act)2027-2028
TyresESPR (delegated act)2027-2028
Construction products (cement, steel, insulation)CPR (revised)2028-2030
Electronics and ICTESPR (delegated act)2028-2030
Plastics and polymersESPR (delegated act)2029-2030

Note: The exact dates depend on the adoption of the respective delegated acts. The table shows the current state of planning by the European Commission.

Mandatory vs. Voluntary: When Does an Early DPP Pay Off?

Even if the DPP obligation for your product category does not come into effect for another two or three years, there are good reasons to act early:

  • Improve data quality: Capturing and structuring product data takes longer in practice than expected, especially when supplier data needs to be included.
  • Competitive advantage: Companies that voluntarily provide transparency strengthen trust among B2B customers and end consumers.
  • Preparation for tenders: Public procurement bodies are increasingly integrating sustainability criteria into procurement procedures. A DPP can be a differentiating factor.
  • Pilot projects minimise risks: A limited pilot run with a DPP platform like myDPP reveals early on which processes need to be adapted.
  • Regulatory certainty: Experience shows that EU deadlines are rarely postponed. Those who start late face time pressure.

Sanctions and Consequences for Non-Compliance

All four core regulations provide for sanctions that are implemented nationally by the member states:

  • Fines: Based on the company’s annual turnover. The Battery Regulation, for example, provides for “effective, proportionate, and dissuasive” penalties.
  • Market access ban: Products without a compliant DPP can be excluded from the EU market.
  • Customs controls: Non-compliant products can be detained at EU external borders.
  • Reputational damage: Market surveillance authorities can publicly announce violations.

For companies with significant EU revenue, non-compliance is not a calculable option.

How to Check if Your Products Are Affected

  1. Identify product categories: List all product groups you sell on the EU market.
  2. Regulation mapping: Check whether your products fall under ESPR, the Battery Regulation, or CPR.
  3. Monitor delegated acts: Subscribe to European Commission updates for your product categories.
  4. Align timelines: Determine when the DPP obligation is expected to come into effect for your categories.
  5. Data gap analysis: Check which data fields are likely to be required and where you currently have gaps.
  6. Start project planning: Plan at least 6-12 months of lead time for data collection, tool selection, and piloting.

Frequently Asked Questions (FAQ)

Is there a central EU database for all Digital Product Passports?

Yes. The EU DPP Registry has been live since 20 July 2026, and Implementing Regulation (EU) 2026/1778 setting out its operating rules applies from 6 August 2026. Registering a passport requires first obtaining verified economic operator status under eIDAS. The first mandatory deadline is 18 February 2027 for battery passports. The registry serves market surveillance and ensures interoperability, but the data itself remains hosted decentrally by companies or their DPP providers — the registry holds identifiers, metadata and a version hash.

Do retailers need to create their own DPP?

Generally not. The DPP obligation lies with the manufacturer or importer who first places the product on the EU market. However, retailers must ensure that the DPP is present and accessible on the product. If retailers sell own-brand products, they bear the manufacturer’s obligations.

What happens if my product category does not yet have a delegated act?

Then there is currently no DPP obligation for this category. However, the Commission can issue new delegated acts at any time. It is advisable to monitor developments and begin structuring data internally.

Can I cover all regulations with a single DPP system?

In principle, yes, if the system is flexible enough to map different data fields and schemas. Since data fields vary by regulation and product category, a configurable platform with template support is recommended.

Further Reading

Sources

Back to Knowledge Base