What is Extended Producer Responsibility (EPR)? The EU's per-country register/report/pay regime, in plain English

EPR makes the company placing a product on the market financially responsible for its post-consumer stage. It runs per-country and per-stream — packaging, WEEE, batteries, textiles — with marketplace delisting now the sharpest enforcement lever. Here's what it actually is.

EU Responsible Person (EU RP): who needs one, what they actually do, and how to designate one

An EU Responsible Person is the EU-established economic operator that authorities can reach when a non-EU brand sells into the Union. Since 13 December 2024, every covered consumer product placed on the EU market must have one named on the listing, the product, or the packaging. Here is what the role does, who needs it, and what to put in place this quarter.

GPSR for Shopify sellers: the Article 19 block, the EU Responsible Person, and what changes for every EU-shipping store

Shopify is not a marketplace under GPSR Article 22 — which makes the seller, not the platform, responsible for Article 19 compliance on every listing. Here is the exact listing block, the EU Responsible Person requirement, the theme-template change, and the per-region catalogue audit every Shopify store needs to run for the EU 27.

What is GPSR? A plain-English overview

The EU General Product Safety Regulation has been enforceable since 13 December 2024. Here is what it actually changes for online sellers — the obligations, the dates, and the practical baseline.

What is REACH SVHC? The 0.1% w/w per-article threshold and Article 33 communication duty, in plain English

REACH — Regulation (EC) 1907/2006 — requires anyone supplying an article in the EU that contains a Substance of Very High Concern above 0.1% w/w per article to (a) communicate sufficient information up the B2B chain under Article 33(1), (b) respond to consumer requests within 45 days under Article 33(2), and (c) notify the ECHA SCIP database. The Candidate List is updated by ECHA roughly each January and June — every update can pull new substances into your existing products.

What is CE marking? The EU self-declaration that lets you place a product on the market

CE marking is the manufacturer's declaration that a product meets every applicable EU product directive — Toy Safety, LVD, EMC, RED, PPE or Machinery, in most ecommerce cases. It is self-declared (Module A) for non-Annex-IV products, but you must hold a technical file and a signed EU Declaration of Conformity (EN ISO/IEC 17050-1) for ten years. Amazon EU has intensified DoC requests since August 2025 and delists ASINs that cannot produce one.

What is EmpCo? The EU's anti-greenwashing law, in plain English

EmpCo — Directive (EU) 2024/825 — is the live EU law banning vague eco-claims, offset-based 'carbon neutral' product claims and unverified sustainability labels. Enforcement starts 27 September 2026. Here's what it actually does.

What is the EU Right to Repair Directive? Plain-English overview of (EU) 2024/1799

The Right to Repair Directive — (EU) 2024/1799 — forces manufacturers of regulated product categories (washing machines, dishwashers, fridges, vacuum cleaners, smartphones, tablets and the categories ESPR expands to) to repair on request, offer spare parts and tools at a non-discriminatory price, and provide an indicative repair price up front using the standardised European Repair Information Form (Annex I). Repaired products get a 12-month warranty extension. Member states must apply the directive by 31 July 2026.

What is PPWR? The EU's directly-applicable packaging law, in plain English

PPWR — Regulation (EU) 2025/40 — is the EU's new packaging law. Same text in all 27 member states. General application starts 12 August 2026, with tightening milestones through 2038. Here's what it actually does.

GPSR on Amazon EU: the Manufacturer Contact attribute, the EU Responsible Person field, and how Seller Central enforces Article 22

Amazon is the EU's largest GPSR enforcer. The Manufacturer Contact and Responsible Person attributes in Seller Central are mandatory on covered listings since 13 December 2024, and Amazon delists non-compliant ASINs automatically. Here is what each field expects, the per-marketplace differences, and the audit every Amazon EU seller needs to run this quarter.

Non-EU seller obligations: the actual EU compliance stack for brands shipping into the Union from outside

If you sell physical consumer products into the EU from outside it, six regimes attach to every order: GPSR, EU Responsible Person, EPR, PPWR, EmpCo, and (from 2027 onwards) DPP. Here is the full obligation stack, the deadlines that are already live, and the operational checklist for 2026.

Banned green claims under EmpCo: the six practices to remove from your marketing

Under Directive (EU) 2024/825, six specific marketing practices are banned outright across the EU 27 from 27 September 2026 — no balancing test, no defence. Here are the six, with concrete before/after examples.

PPWR packaging requirements: the seven checks every EU seller must pass

PPWR (Regulation (EU) 2025/40) imposes seven concrete packaging requirements that phase in between 12 August 2026 and 2038. This guide walks each check with what is enforceable now versus what to capture for upcoming milestones.

EPR registration by country: the EU 27 register/report/pay map sellers actually need

EPR is implemented per member state — LUCID, ADEME, CONAI, Verpact and 24 others. Here's how the national registers work for packaging, WEEE, batteries and textiles, what PPWR Art. 44 changes from 12 August 2026, and where non-EU sellers need an Authorised Representative.

DPP for textiles: what sellers should track now

The Digital Product Passport lands on textiles before most other categories. Here is what fashion and apparel sellers should be capturing in 2026 to be ready.

Seller responsibilities under GPSR

GPSR assigns specific duties to manufacturers, importers, distributors and fulfilment providers. This guide maps the obligations to the role you actually play — and what 'documented' means when an authority asks.

Required product information under GPSR

GPSR Article 19 lists the information online sellers must surface before checkout — manufacturer details, Responsible Person, identifiers, warnings, safe-use instructions. Here is what each field really means in practice.

EPR for online sellers: how marketplaces enforce it, and what gets your listings delisted

For e-commerce sellers, the sharpest EPR risk in 2026 isn't national fines — it's marketplace delisting under the Digital Services Act. Here's how Amazon EU, Otto, Bol.com and others enforce EPR, what pay-on-behalf actually costs, and how to pre-empt suspension.

PPWR for e-commerce sellers: the parcel, the marketplace, and what changes 12 August 2026

PPWR explicitly covers e-commerce packaging and names online marketplaces as responsible actors. From 12 August 2026, the shipping box, mailer and polybag are in scope — and listing-level enforcement is the sharpest stick. Here's the practical guide.

GPSR for Etsy sellers: handmade is not exempt, the Responsible Person field, and what changes for makers shipping into the EU

Etsy is a marketplace under GPSR Article 22, and 'handmade' carries no exemption from the General Product Safety Regulation. Since 13 December 2024, every Etsy listing shipped into the EU 27 must carry manufacturer, Responsible Person, and warnings — and Etsy delists listings missing them. Here is what an Etsy shop actually needs to do.

EmpCo for fashion and textile brands: the highest-risk sector, mapped to the six bans

Fashion is the most-scrutinised sector under EmpCo. Generic 'sustainable' collections, offset-based 'climate neutral' garments, and self-made eco-badges are squarely in the banned set. Here's the sector-specific playbook for 2026.

DPP and product traceability: the supply-chain data work the passport actually demands

The Digital Product Passport is a traceability instrument before it is a consumer-facing artefact. Here's the data chain — identifier, components, suppliers, substances, country of origin, evidence — that any DPP under ESPR or the Batteries Regulation will demand, and how to start capturing it now.

GPSR for online marketplaces

GPSR Article 22 layers product-safety duties on top of the Digital Services Act. Here is what online marketplaces must now do, and what sellers should expect from the platforms they list on.

Common GPSR mistakes online sellers make

After a year of GPSR enforcement, the same gaps appear over and over in marketplace suppressions and national-authority findings. Here are the seven most common — and what a clean fix looks like.

Ecommerce compliance readiness: the per-SKU, per-regime readiness framework for EU-shipping catalogues in 2026

EU compliance is not a single 'are we compliant?' verdict — it is a per-SKU, per-regime readiness state across GPSR, EU RP, EPR, PPWR, EmpCo and DPP. Here is the five-layer framework, the per-SKU score that drives prioritisation, and the catalogue-audit pattern that turns a regulatory backlog into a shippable engineering ticket list.

What is a Digital Product Passport (DPP)? The EU's per-SKU data record, in plain English

The Digital Product Passport is the structured digital record the EU is rolling out under ESPR — batteries first (Feb 2027), textiles next, then most physical product categories through 2030. Here's what it actually contains, who has to issue one, and what to do this quarter.

9 MIN READ · UPDATED 7 JUNE 2026

If you place physical products on the EU market, the Digital Product Passport is the regulatory data record those products will travel with through the late 2020s. Batteries first, textiles next, then most product categories through 2030. It is not a label, not a marketing artefact, and not a single-document compliance certificate. It is a persistent per-SKU (or per-unit, depending on category) digital record bound to a data carrier on the physical product.

This guide explains what a DPP actually is, what it contains, when it bites for which category, who has to issue one, and what a defensible 2026 posture looks like.

What a DPP actually is

A Digital Product Passport is a structured digital record:

Bound to a persistent unique product identifier (often a GS1-style identifier in textiles, a battery-specific identifier in batteries).
Accessed via a data carrier on the physical product — a QR code, a data-matrix code, or an NFC tag.
Holding the regulatory dataset defined for the product category by the applicable Commission delegated act under ESPR (or, for batteries, by the Batteries Regulation).
Maintained across the product's lifecycle — from placement on the market through use, repair, second life, and end-of-life processing.
Linked to a central EU registry component that records the passport's existence and its identifier; the actual content is served by the economic operator's system or a delegated DPP provider.

The carrier is not the passport. The passport is the data; the carrier is how a scanner — consumer, retailer, recycler, customs officer — gets to it.

The legal framework

Two instruments matter:

ESPR — Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation). Adopted July 2024, in force from 18 July 2024. ESPR is the framework that introduces DPP as a tool. It does not by itself impose DPP on any specific product category. Concrete obligations are set per category by Commission delegated acts, prioritised in the ESPR working plan published by the Commission.

Batteries Regulation (EU) 2023/1542. Already in force. Introduces the first mandatory DPP — the battery passport — from 18 February 2027 for industrial batteries above 2 kWh, electric vehicle batteries, and LMT (light means of transport) batteries. This is the live deadline that anyone in battery supply chains is already working against.

For every other category, the binding instrument is the ESPR delegated act for that category — adopted by the Commission, typically applicable 18–36 months after adoption. Textiles is widely expected to be first; electronics, furniture, construction products, chemicals, paints, tyres follow.

What a DPP contains

The exact dataset is category-specific. Across the categories announced so far, a DPP typically holds:

A unique product identifier (GS1 GTIN-style or category-specific).
Producer / economic operator identification — name, address, role.
Material and substance composition — bill of materials, weights, presence of substances of concern.
Country of origin — including supply-chain country information at material or component level for some categories.
Repair, disassembly and end-of-life guidance — how to repair, how to recycle, how to dispose.
Environmental indicators — for some categories, carbon footprint or other lifecycle metrics under the applicable methodology.
Certifications and compliance declarations — EC Declaration of Conformity references, applicable certifications.
Category-specific fields — for batteries: state of health, charge cycles, performance; for textiles: fibre composition, traceability fields; for electronics: spare-parts availability, software-update commitments.

Claims surfaced on a DPP are subject to the same EmpCo (Dir. 2024/825) substantiation rules as any other consumer-facing claim. A DPP that asserts "100% recycled cotton" without supplier-level evidence is the same enforcement risk as the equivalent claim on a marketing page — only with the audit trail attached to it.

Who has to issue a DPP

The economic operator placing the product on the EU market:

EU-established manufacturers — for products they manufacture.
Importers — for products they import into the EU.
Non-EU brands shipping into the EU — typically the importer carries the obligation; for some regimes the EU Responsible Person is the named addressee.
Distributors and online retailers — generally not the issuer, but may be required to verify the passport's existence as a listing condition.
Online marketplaces — increasingly named as joint responsible actors and required to verify DPPs before listing covered products.

There is no general SME exemption from the core DPP obligation, though some delegated acts may scale specific data fields for very small operators.

The category rollout — what to plan against in 2026

The dates that matter through 2027–2030:

18 February 2027 — Battery Regulation DPP for industrial batteries >2 kWh, EV batteries, and LMT batteries. Already binding, anyone in battery supply chains is in late preparation.
2027 onwards — Textiles delegated act under ESPR expected; applicability typically 18–36 months after adoption. The first non-battery category to ship a DPP at consumer scale.
2028–2030 — Electronics, furniture, construction products, chemicals, paints, tyres rolling in via subsequent ESPR delegated acts.
Through 2030 — Most physical product categories sold into the EU expected to carry a DPP.

The ESPR working plan published by the Commission is the source of truth for the order and pace.

What to do in 2026 — the no-regrets baseline

Even before your category's delegated act lands, six things pay back regardless:

Persistent per-SKU unique identifier. Adopt GS1 GTIN or equivalent and use it consistently across systems. Without a stable identifier you cannot bind a passport to a unit.
Standardised SKU-level dataset. Bill of materials, country of origin per component, supplier identifier per component, substance presence. The fields are the same across most delegated acts; capture them now.
Supplier-data collection workflow. A documented process for asking suppliers for material composition, substance declarations, and origin data — and storing the response with provenance.
Data-carrier strategy. QR or data-matrix on the product or its primary packaging, generated from the unique identifier, resolvable to a passport URL.
EU Responsible Person coverage. For non-EU brands, an EU RP is already required under GPSR and several other regimes; the same entity is typically the named addressee for DPP delegated acts.
Evidence retention. Dated retention of every substantiation document — DPP, EmpCo, GPSR technical file all draw from the same well.

Teams that do this work in 2026 treat the eventual DPP deadline for their category as a switch-on, not a project.

How Regonance helps

Regonance gives you a per-SKU passport with a persistent identifier, a resolvable public URL, a QR code, and a structured dataset that mirrors the ESPR field-set anticipated for textiles and aligns with the GPSR technical-file requirement you already owe today. Versioning means a recall or correction is traceable. The EU Responsible Person details render on every passport, closing the overlap with GPSR. The same evidence ledger feeds EmpCo claim substantiation and EPR volume reporting. Available on Growth, Pro and Agency plans.

Glossary

DPP. Digital Product Passport — the structured per-SKU digital record introduced as a tool under ESPR and rolled out per category via delegated acts.

ESPR. Ecodesign for Sustainable Products Regulation — Regulation (EU) 2024/1781. The framework regulation under which category-specific DPP obligations are issued.

Delegated act. A category-specific implementing rule adopted by the European Commission that turns the ESPR framework into concrete DPP and ecodesign obligations.

Data carrier. The physical or digital medium (QR, data-matrix, NFC) that links a product unit to its DPP record.

Battery passport. The first mandatory DPP, under the Batteries Regulation (EU) 2023/1542, from 18 February 2027 for in-scope batteries.

Persistent unique identifier. A stable identifier (often GS1 GTIN-based) bound to the product or unit and used to address its passport.

Educational information, not legal advice. The ESPR working plan and category delegated acts evolve frequently — validate scope and applicability with a qualified advisor before acting.

Frequently asked questions

What is a Digital Product Passport in one sentence?+

A Digital Product Passport (DPP) is a structured digital record bound to a persistent unique product identifier and accessed via a data carrier (typically a QR or data-matrix code), that holds the product's regulatory data — material composition, substances of concern, repair and end-of-life information, country of origin, certifications, and category-specific fields — across its lifecycle.

Is DPP one EU regulation or many?+

DPP is a framework introduced by the Ecodesign for Sustainable Products Regulation (ESPR — Regulation (EU) 2024/1781), with the concrete obligations set per product category by Commission delegated acts. The Batteries Regulation (EU) 2023/1542 introduces the first mandatory passport (battery passport from 18 February 2027). ESPR delegated acts for textiles, electronics, furniture, construction products and more follow through 2027–2030.

When does DPP become mandatory for my category?+

Batteries — 18 February 2027 under the Batteries Regulation. Textiles — first ESPR delegated act expected 2027, with applicability typically 18–36 months after adoption. Electronics, furniture, construction products, chemicals, paints, tyres — phased through 2028–2030 via subsequent delegated acts. The ESPR working plan published by the Commission is the live roadmap.

Who creates the DPP?+

The economic operator placing the product on the EU market. For an EU manufacturer that's the manufacturer; for non-EU brands shipping into the EU it's typically the importer (or the EU Responsible Person where one is required). The data must be accurate, complete, and kept available across the product's lifecycle.

What technology is required?+

ESPR is technology-neutral on the data carrier. QR codes, data-matrix codes and NFC tags are all eligible, provided the underlying data model conforms to the applicable delegated act and the passport is accessible to any party scanning the carrier without proprietary apps. There will be a central EU registry component, with the passport content served from the economic operator's own system or a delegated DPP provider.

Is DPP the same as a product label or a sustainability report?+

No. A product label is a static print on packaging; a sustainability report is brand-level disclosure. A DPP is per-unit (or per-batch/per-model depending on the delegated act), accessed via a data carrier on the physical product, and contains regulatory data — not marketing copy. Claims surfaced on a DPP are subject to the same EmpCo (Dir. 2024/825) substantiation rules as any other claim.

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AI-assisted informational guidance. Not legal advice. Consult qualified counsel for your specific situation.