Digital Product Passport (DPP): regulation, requirements and timelines

The Digital Product Passport (DPP) is a digital record, linked to each product, that brings together information on its composition, origin, durability, repairability and environmental footprint across its entire life cycle. It is neither a distant utopia nor an immediate obligation for everyone: the legal framework already exists, the first obligation with a fixed date is the battery passport of February 2027, and the remaining sectors will start coming in from 2028.

What began as an idea of the European Green Deal is now taking shape as a data infrastructure with which the European Union wants to drive a more transparent circular economy. The DPP is not just one more regulation: it is the foundation on which the EU wants to build a market where repairing, reusing and recycling is easier.

What is the Digital Product Passport?

The DPP is not a PDF hosted on a website. It is a dynamic digital inventory linked to a physical product through an identifier (QR code, RFID or NFC) that gives access to critical data across the whole life cycle.

Its logic is twofold. On one hand, to improve the transparency and traceability of the products sold on the European market. On the other, to enable a more circular model in which goods can be repaired, reused or recycled more easily.

Which regulation governs the DPP?

The Digital Product Passport does not come from a single isolated rule, but from the new European ecodesign policy:

• The general framework is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, in force since 18 July 2024. The ESPR enables the DPP but leaves the specific requirements for each product family to future delegated acts.
• In April 2025, the Commission published the first ESPR Working Plan 2025-2030, which sets out the priority product groups.
• Separately, the Batteries Regulation (EU) 2023/1542 already establishes its own battery passport, mandatory for certain batteries from 18 February 2027. It is the first product passport with a fixed date.

Timeline: when will it be your sector's turn?

Implementation is progressive and category by category. As of August 2026 the Commission has not yet adopted any ESPR delegated act, so this remains a year of preparation. The regulation itself also states that the date of application of a delegated act cannot be earlier than 18 months after it enters into force, which explains the gap between adoption and compliance.

According to the 2025-2030 Working Plan and the batteries regulation, the expected order is roughly this:

The specific dates depend on each delegated act and may be adjusted: they are indicative, and the working plan itself foresees a mid-term review in 2028, so it is worth following the Commission's official publications. The underlying idea is clear: start with the products that have the highest environmental impact and the largest consumption volumes. Energy-related products meanwhile remain under the ecodesign regulations already in force, which the ESPR will progressively replace.

A change that goes beyond Europe

Although the regulation originates in Brussels, its impact will be global. Any company that wants to sell products on the European market, wherever it is based, will have to meet the requirements applicable to its category.

This means that suppliers in Asia, manufacturers in the Americas and global brands will have to adapt their systems to generate and share information compatible with the new European standard. As already happened with data protection rules, the DPP may end up exporting standards beyond the EU's borders.

From compliance to competitive advantage

In the short term, many companies see it as just another regulatory challenge. But a well-structured product information system also opens up strategic opportunities: it improves ecodesign, optimises the use of materials and enables business models based on repair, refurbishment or resale.

The DPP also connects with extended producer responsibility: the better the information on composition and recyclability, the more efficient the management of the product at the end of its useful life. In parallel, specialised platforms are emerging, such as Manglai, that help centralise product environmental data and get it ready for the future passport requirements.

The European Union has spent years trying to change the rules of consumption: first with energy labelling, then with ecodesign rules and now with the digital passport. The difference is that this time it is not only about making products more efficient, but about creating a data infrastructure that accompanies each object throughout its useful life. For thousands of companies, the work to make it possible starts now.

Frequently asked questions about the Digital Product Passport (DPP)

Is the Digital Product Passport mandatory in 2026?

No. As of August 2026 the Commission has not yet adopted any ESPR delegated act, and each act carries a minimum transition period of 18 months. The only passport with a fixed date is the battery passport, mandatory from 18 February 2027.

Which regulation governs the DPP?

The general framework is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, complemented by sector-specific delegated acts. The battery passport is regulated separately, in Regulation (EU) 2023/1542.

Does it affect companies outside the EU?

Yes. Any company that wants to sell products on the European market will have to meet the requirements applicable to its category.

Does the DPP replace the CSRD?

No. They are different but complementary frameworks: the CSRD governs sustainability reporting at company level and the DPP governs information at product level.

What happens if a company does not comply?

Once the requirement applies to its sector, it could face restrictions on placing the product on the European market.