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What is a Digital Product Passport and when does your product need one?

A Digital Product Passport (DPP) is a machine-readable digital record that consolidates essential information about a product's identity, composition, compliance, sustainability, and lifecycle. Mandated under the EU's Ecodesign for Sustainable Products Regulation (ESPR) — Regulation (EU) 2024/1781 — the DPP is intended to make supply chains more transparent, support circular economy objectives, and give consumers, regulators, and recyclers structured access to product information.

4 MIN READ · UPDATED 30 AUGUST 2026 · REVIEWED BY THE REGONANCE EDITORIAL TEAM

A Digital Product Passport (DPP) is a machine-readable digital record that consolidates essential information about a product's identity, composition, compliance, sustainability, and lifecycle. Mandated under the EU's Ecodesign for Sustainable Products Regulation (ESPR) — Regulation (EU) 2024/1781 — the DPP is intended to make supply chains more transparent, support circular economy objectives, and give consumers, regulators, and recyclers structured access to product information.

The DPP is not yet required for most product categories. But the framework is in force, delegated acts are under development, and the first categories are expected to receive requirements in 2027. This guide explains what the DPP is, what it contains, which products will need one, and the current timeline.


What the DPP contains

A DPP is accessed through a data carrier — typically a QR code, barcode, NFC tag, or other machine-readable identifier — placed on the product, its packaging, or its accompanying documentation. Scanning the data carrier connects the physical product to its digital record.

The specific data fields vary by product category (defined through delegated acts), but the ESPR framework establishes a common structure:

Product identity. Unique product identifier, manufacturer details, model and batch information, product category.

Material composition. Materials used, including recycled content percentages, substances of concern, and (where applicable) full bill-of-materials.

Environmental performance. Carbon footprint, energy consumption during use, water usage in manufacturing, and other environmental indicators defined by the category-specific delegated act.

Durability and repairability. Expected product lifespan, repairability score or assessment, availability of spare parts, repair instructions.

Care and maintenance. Instructions for extending product life through proper use and maintenance.

End-of-life information. Recycling instructions, disassembly guidance, material recovery potential.

Compliance data. Declarations of conformity, applicable standards, regulatory references.

Supply chain traceability. Country of manufacture, key suppliers (where required by the delegated act), due diligence information.


Which products will need a DPP

The ESPR framework applies across product categories, but DPP requirements are introduced through delegated acts — category-specific regulations that define exactly which data fields are required for each product type. Until a delegated act is adopted for a product category, the DPP is not required for that category.

Categories expected to receive delegated acts first

Textiles and footwear. Expected to be among the first categories. The textile DPP will likely require fibre composition, country of manufacture, environmental footprint, care instructions, and recycling information.

Electronics and ICT. Consumer electronics, smartphones, tablets, and IT equipment are priority categories for DPP requirements — particularly for repairability and material composition data.

Batteries. The EU Battery Regulation (2023/1542) already introduces a Battery Passport for industrial and EV batteries, with portable battery requirements phased in later. This is a DPP in practice, though created under a different regulation.

Iron and steel. Prioritised under ESPR for environmental footprint and recycled content disclosure.

Furniture. Expected to receive DPP requirements, though the timeline is less certain than textiles or electronics.

Categories expected later

Paints and coatings, tyres, detergents, construction products, and other categories are on the ESPR work programme but are not expected to receive delegated acts in the first wave.


The timeline

DateWhat happens
18 July 2024ESPR published in Official Journal
18 July 2024ESPR entered into force
2025–2026European Commission developing delegated acts for priority categories
2026–2027First delegated acts expected to be adopted (textiles, electronics)
2027–2028DPP requirements expected to apply for first categories (subject to transitional periods in delegated acts)
2028–2030Additional categories phased in
2030+Broader coverage as more delegated acts are adopted

The exact timeline for each category depends on when the Commission adopts the relevant delegated act and what transitional period it includes. Sellers should not wait for the final date — the data collection and structuring work takes time, and starting now avoids a scramble.


What the DPP means for sellers

Data collection starts now

Even though DPP is not yet mandatory for most categories, the data it will require — material composition, country of manufacture, environmental performance, care instructions — takes time to collect, structure, and verify. Sellers who start organising this data now will be ready when requirements apply. Sellers who wait will face a data-collection sprint under deadline pressure.

Digital infrastructure needed

The DPP requires a digital record accessible via a data carrier. This means: a hosting infrastructure for the passport data, a system for generating and managing unique product identifiers, and a method for placing data carriers (QR codes) on products or packaging. For sellers with large catalogues, this is an infrastructure project, not a labelling change.

Interoperability

The ESPR framework requires DPP data to be interoperable — meaning it must be structured in a standardised format that different systems can read. The European Commission is developing technical specifications for DPP data formats. Sellers should avoid building proprietary systems that may not meet the interoperability requirements.


How Regonance helps

Regonance is building Digital Product Passport capability into its platform — enabling sellers to generate, host, and manage DPP data for their products alongside GPSR, PPWR, EmpCo, and other EU compliance requirements. The platform structures product data in the format the DPP will require, so when delegated acts apply to your product category, the data is already organised.

Start by scanning your products to see which compliance data you already have and what is missing — including the data fields that the DPP will eventually require.

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Compliance guidance based on published EU regulatory texts. Does not constitute legal advice. ESPR delegated acts are under development — specific DPP requirements and timelines may change.

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Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.