Which products need a digital product passport, and when?
What EU law requires today, what is coming, and how to tell whether a passport applies to your product.
DPP Shield editorial team · Updated:
A product needs a digital product passport only when an EU act covering its product group requires one. The first binding case is the battery passport: from 18 February 2027, light-means-of-transport batteries, electric-vehicle batteries and industrial batteries with a capacity above 2 kWh placed on the EU market need one. Other product groups follow as delegated acts under the ESPR are adopted, each with its own dates.
Does the ESPR already require passports?
Not by itself. The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, is a framework: it sets out what a passport is and how it must work, and leaves the decision about which products need one to delegated acts for specific product groups.
Until a delegated act for your product group applies, there is no ESPR obligation to publish a passport for it. When one is adopted, it states the data required, the access rights and the date from which the obligation applies.
Which batteries need a battery passport?
Article 77 of the Batteries Regulation, Regulation (EU) 2023/1542, requires an electronic record - the battery passport - for each light-means-of-transport battery, each electric-vehicle battery and each industrial battery with a capacity greater than 2 kWh placed on the market or put into service, from 18 February 2027.
The passport is reached through a QR code, holds information at different access levels (public, persons with a legitimate interest, and authorities), and ceases to exist once the battery has been recycled.
Which product groups are next?
The Commission sets priorities in ESPR working plans. The first plan names product groups such as textiles and apparel, furniture, tyres, mattresses, and intermediate products such as iron, steel and aluminium. Each needs its own delegated act, prepared with stakeholder consultation, before any obligation applies.
Sector legislation can also introduce passports. The revised Construction Products Regulation, Regulation (EU) 2024/3110, provides for a digital product passport system for construction products. Check the act for your own product group rather than relying on general timelines.
What about the EU passport registry?
Article 13 of the ESPR requires the Commission to set up a digital product passport registry, which stores the unique identifiers and links to passports and connects to customs systems. Where a delegated act requires it, the economic operator registers the passport before placing the product on the market.
How can you tell whether your product is in scope?
Identify the product group and the legal acts that cover it, then read the scope article of each act: products are often in or out of scope because of capacity, use or market, not because of their name. Note the date of application and any transitional provisions.
If a passport will be required, start early: the difficult part is collecting supplier data and evidence, which takes longer than building the page. This article is general information, not legal advice; confirm the requirements for your products with a qualified adviser.