The Digital Product Passport (DPP) is the EU's most ambitious product transparency initiative. No product needs a DPP in 2026 — the first obligation arrives for batteries on 18 February 2027 — but 2026 is the year the EU's registry infrastructure and delegated act pipeline take shape. — containing sustainability data, repair information, recycled content, and supply chain details. The rollout happens in waves, and 2026 is when the infrastructure goes live.
What Is the Digital Product Passport?
The Digital Product Passport is a digital record attached to a physical product — typically via a QR code, RFID tag, or NFC chip — that carries standardized sustainability and circularity data throughout the product's lifecycle. It's anchored in the Ecodesign for Sustainable Products Regulation (ESPR, Regulation EU 2024/1781), which entered into force in July 2024.
The DPP data includes: material composition, recycled content percentages, carbon footprint, repair and disassembly instructions, hazardous substance declarations, supply chain origin, and end-of-life instructions. The goal is to enable recyclers, repair shops, consumers, and regulators to make informed decisions at every stage of the product lifecycle.
2026: The EU Registry Goes Live
The European Commission launched the central DPP registry on 20 July 2026 — one day after the 19 July 2026 deadline set by Article 13(1) ESPR — together with a testing environment for economic operators. This registry stores the unique product identifiers assigned by economic operators, links to product passports, and enables enforcement checks by customs authorities and market surveillance bodies.
The registry going live does not mean any product needs a DPP yet: no product category is currently subject to a passport requirement, so there is no registration obligation. Mandatory requirements follow by product category according to the schedule below, starting with batteries on 18 February 2027.
Sector Timeline: One Binding Date, the Rest Indicative
| Timeframe | Products | Legal basis / status |
|---|---|---|
| 18 February 2027 | Batteries: EV, industrial >2 kWh, LMT (portable batteries are not covered) | EU Battery Regulation 2023/1542 — the only binding passport date |
| 2026 (indicative adoption) | Iron and steel | ESPR delegated act expected; applies at least 18 months after adoption |
| 2027 (indicative adoption) | Textiles, tyres, aluminium | ESPR delegated acts expected; apply at least 18 months after adoption |
| 2028 (indicative adoption) | Furniture | ESPR delegated act expected |
| 2029 (indicative adoption) | Mattresses | ESPR delegated act expected; applies at least 18 months after adoption |
| No single delegated act | Electronics and ICT | Not a standalone delegated act: covered by two horizontal requirements (reparability, indicative 2027; recycled content & recyclability of electrical and electronic equipment, indicative 2029) plus a separate energy-related measure for mobile phones and tablets (indicative adoption end 2030) |
No catch-all date exists: categories outside this list have no scheduled DPP requirement, and the working plan years are adoption estimates that have shifted before.
Battery Passport: The 2026 Pioneer
The Battery Regulation (Regulation EU 2023/1542) is the first to mandate DPPs, with the passport requirement applying from 18 February 2027 for EV, industrial (>2 kWh), and LMT batteries. It's the most detailed DPP specification to date and serves as the template other sectors will follow.
Key battery passport requirements include: carbon footprint per kWh, recycled content percentages for cobalt, lithium, nickel and lead, supply chain due diligence documentation, state-of-health data for EV batteries and industrial batteries above 2 kWh, and end-of-life handling instructions.
For EV battery manufacturers, the 18 February 2027 battery passport requirement is not optional. Non-compliance blocks market access in the EU. This is the most immediate DPP obligation any business needs to address.
What Companies Need to Do Now
Even if your product category's mandatory date is 2027 or later, preparation in 2026 is essential. The data collection required for a DPP typically takes 12-18 months to set up properly — especially the supply chain traceability components.
- Identify your product's DPP timeline — check the ESPR regulation and delegated acts for your category
- Audit your current data availability — which sustainability data points do you already collect, and which require new supplier surveys or testing?
- Choose a DPP technology provider — evaluate platforms against the EU registry integration requirements
- Map your supply chain — DPP requires traceable origin data that may require new supplier agreements
- Integrate with your product information systems — PLM, ERP, and QA systems will need to feed into the DPP
Use our DPP readiness scanner to assess your organization's current preparedness and identify the highest-priority gaps.
How DPP Differs From Existing Product Declarations
Companies already producing Environmental Product Declarations (EPDs), CE markings, or REACH compliance documents often ask how the DPP relates. The answer: DPP is not a replacement — it's an integration layer. It references and links existing declarations but adds lifecycle data, reparability information, and real-time state-of-health data (for batteries) that existing frameworks don't require.
The DPP is also machine-readable by design. Unlike an EPD document, a DPP can be queried programmatically by recycling robots, customs systems, and supply chain management tools. This machine-readable requirement is a fundamental design difference from previous product information regimes.