Digital Product Passport Regulation — Complete Guide 2026

The Digital Product Passport (DPP) is not defined by a single regulation. It emerges from a cluster of EU legislative acts, each targeting different product categories with different timelines and data requirements. Understanding which regulations apply to your products — and when — is the first step toward compliance.

This guide covers the three main regulations introducing DPP obligations, their timelines, scope, and enforcement mechanisms.

If you are new to the concept of Digital Product Passports, start with our introductory article: Digital Product Passport in 15 minutes.

Key takeaways

Three EU regulations introduce DPP requirements: ESPR, Battery Regulation, and Construction Products Regulation.
The Battery Regulation is the first to take effect — mandatory battery passports from February 2027.
ESPR is a framework regulation — it enables DPP for virtually any product category through delegated acts.
Enforcement is handled at the national level, but the EU is building centralized registries and interoperability standards.
Non-compliance carries financial penalties and potential market access restrictions.

The three regulations introducing DPP

1. Ecodesign for Sustainable Products Regulation (ESPR)

Regulation (EU) 2024/1781 — entered into force on 18 July 2024.

ESPR is the cornerstone of the EU’s Digital Product Passport framework. It replaces the old Ecodesign Directive (2009/125/EC), which only covered energy-related products, and expands the scope to nearly all physical products placed on the EU market.

What ESPR does:

Establishes the legal basis for DPP requirements across product categories
Defines the general framework: what a DPP must contain, how it must be accessed, who is responsible
Delegates the specifics (data points, timelines) to product-specific delegated acts

Key provisions:

Every product covered by a delegated act must have a DPP before being placed on the EU market
DPP data must be accessible via a data carrier (QR code, RFID, NFC) linked to a unique product identifier
Data must be machine-readable and accessible to relevant stakeholders (consumers, authorities, recyclers)
A centralized DPP registry will be established to enable cross-border verification

Product categories under ESPR delegated acts:

The European Commission is developing delegated acts for priority product categories. As of mid-2026, the following are in progress or confirmed:

Product category	Expected delegated act	Estimated DPP obligation
Textiles and footwear	2026	2028–2029
Iron and steel	2026	2028–2029
Aluminium	2026–2027	2029
Furniture	2027	2029–2030
Detergents	2027	2029–2030
Tyres	2027	2029–2030
Electronics and ICT	2028	2030–2031

These timelines are based on the European Commission’s working plan and may shift as delegated acts move through consultation and adoption.

2. EU Battery Regulation

Regulation (EU) 2023/1542 — entered into force on 17 August 2023.

The Battery Regulation is the first EU law to mandate a Digital Product Passport. It applies to all batteries placed on the EU market and introduces the battery passport as a specific implementation of DPP.

Scope:

Industrial batteries with a capacity above 2 kWh
Electric vehicle (EV) batteries
Light means of transport (LMT) batteries

Portable batteries and SLI (starting, lighting, ignition) batteries are currently excluded from the passport requirement, though other obligations under the Battery Regulation still apply to them.

Timeline:

Milestone	Date
Regulation enters into force	17 August 2023
Battery passport mandatory	18 February 2027
Due diligence obligations apply	18 August 2025
Carbon footprint declaration mandatory	18 February 2025

What the battery passport must include:

Battery identification (manufacturer, model, GTIN)
Technical specifications (capacity, voltage, weight, chemistry)
Carbon footprint data (per kWh, calculated per EU methodology)
Recycled content information
Supply chain due diligence data
State of health parameters (for EV batteries)
End-of-life and recycling instructions

The battery passport must be accessible via a QR code on the battery or its packaging, linked to a unique identifier.

3. Construction Products Regulation (CPR)

Regulation (EU) 2024/3110 — adopted in November 2024.

The revised Construction Products Regulation introduces DPP requirements for construction materials and products. This regulation replaces the existing CPR (305/2011) and aligns construction product data with the EU’s digital and sustainability goals.

Scope:

All construction products covered by harmonized technical specifications (hEN) or European Assessment Documents (EAD) — including cement, steel products, insulation materials, windows, doors, and structural timber.

Key DPP provisions:

Manufacturers must provide a DPP for each construction product or product type
The passport must include the Declaration of Performance (DoP) data in machine-readable format
Environmental data (EPD — Environmental Product Declarations) will be integrated into the DPP
Access via a data carrier (QR code) linked to a unique product identifier

Timeline:

The CPR delegated acts specifying DPP data requirements are expected between 2027 and 2029, with DPP obligations phased in starting from 2029–2030 depending on the product category.

How the regulations connect

The three regulations share a common architecture:

Unique product identifier — each product (or product model/batch) gets a unique ID, typically based on GS1 standards
Data carrier — a QR code, RFID chip, or NFC tag that links to the DPP data
Structured data — machine-readable product information following a defined schema
Accessible endpoint — a URL where authorized parties can retrieve the data

ESPR provides the overarching framework. The Battery Regulation and CPR are sector-specific laws that predate or run parallel to ESPR but align with its principles. Over time, all DPP implementations are expected to converge toward the ESPR model.

For more on the role of GS1 standards and Digital Link in DPP, see: QR Code vs GS1 Digital Link — differences for DPP.

Enforcement and penalties

DPP enforcement follows the EU’s established market surveillance framework:

National market surveillance authorities are responsible for checking compliance in each member state
Customs authorities can block products without a valid DPP at the EU border
The EU DPP registry will enable cross-border verification and data sharing between authorities

Penalties for non-compliance:

The specific penalty amounts are defined at the national level, but the regulations establish that penalties must be “effective, proportionate and dissuasive.” In practice, companies can expect:

Fines — proportional to the infringement and company turnover
Product withdrawal — authorities can order removal of non-compliant products from the market
Import bans — products without a valid DPP may be blocked at EU borders
Reputational damage — non-compliance information may become publicly accessible

The Battery Regulation explicitly requires member states to establish penalty regimes by August 2025.

Who is responsible for DPP compliance

The regulations place primary responsibility on the economic operator who places the product on the EU market:

Role	Responsibility
Manufacturer	Creates the DPP, provides all required data, ensures accuracy
Importer	Verifies that the DPP exists and is accessible before importing
Distributor	Ensures the DPP remains accessible, does not alter data
Authorized representative	Acts on behalf of non-EU manufacturers

For companies selling into the EU from outside Europe, the importer or authorized representative bears the compliance burden. This makes DPP a supply chain issue, not just a manufacturer issue.

Practical steps toward compliance

Regardless of which regulation applies to your products, the preparation steps are similar:

Identify applicable regulations — determine which delegated acts apply to your product categories and their timelines.
Audit your product data — map what data you already have (in ERP, PIM, PLM systems) against what the DPP requires. See our guide: DPP and ERP Integration.
Fill data gaps — identify missing data points (e.g., carbon footprint, recycled content) and establish processes to collect them.
Choose a DPP platform — select software that supports the required data schemas, GS1 Digital Link, and integrations with your existing systems.
Pilot with a subset — start with a small batch of products to test the process end-to-end.
Scale and automate — connect your data sources via API and roll out DPP across your catalog.

For a detailed implementation checklist, see: How to implement DPP — complete checklist.

What to expect next

The regulatory landscape around DPP is still evolving. Key developments to watch:

ESPR delegated acts for textiles, iron/steel, and other priority categories — expected throughout 2026–2027
Technical standards for DPP data formats and interoperability — being developed by CEN/CENELEC
EU DPP registry specifications — expected to be finalized in 2026
Pilot programs — several EU-funded pilot projects are testing DPP implementations across sectors

Companies that start preparing now will have a significant advantage when mandatory deadlines arrive.