ESPR 2024/1781: The EU Digital Product Passport Is Coming to Nearly Every Product

The EU Digital Product Passport will not stop at batteries and textiles. ESPR 2024/1781 extends it to nearly every physical product sold in the EU, and the data work behind a passport takes far longer to assemble than the format takes to publish.

This post explains what ESPR 2024/1781 actually requires, how it relates to the EU Battery Regulation already in force, which deadlines are fixed versus still being written, and the practical steps a manufacturer can take now. The aim is clarity, not alarm: ESPR is a framework, and understanding how it is structured tells you exactly where to direct your preparation.

What ESPR 2024/1781 actually is

Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation, replaces and significantly expands the previous Ecodesign Directive. The old directive applied mainly to energy-related products such as appliances and lighting. ESPR widens that scope to cover nearly all physical goods placed on the EU market, with defined exclusions such as food, feed, and medicinal products.

ESPR is a framework regulation. It does not, by itself, set detailed rules for every product. Instead it establishes the legal machinery, then hands the specifics to delegated acts adopted product group by product group. Two things matter for manufacturers:

• Ecodesign requirements: rules on durability, reusability, reparability, recycled content, energy efficiency, and the presence of substances of concern.
• The Digital Product Passport (DPP): a structured electronic record of a product’s sustainability and compliance data, accessible via a data carrier such as a QR code.

In short, ESPR sets the rules; the delegated acts decide when those rules apply to your category. You can read the full text on EUR-Lex, and we maintain a plain-language summary on our ESPR 2024/1781 regulatory page.

How ESPR relates to the EU Battery Regulation

If you make batteries, you face a different and earlier obligation than most other product groups, and it is worth being precise about why.

The battery passport is mandated not by ESPR but by the EU Battery Regulation, Regulation (EU) 2023/1542. Its passport provisions sit in Article 77 and apply from 18 February 2027. Three categories of battery are in scope:

• All electric vehicle (traction) batteries, regardless of capacity
• All light means of transport (LMT) batteries, defined in Article 3(11) as sealed batteries of 25 kg or less for wheeled vehicles such as e-bikes and e-scooters
• Industrial batteries with a capacity above 2 kWh

Where to look in the Regulation:

• Required data set: Annex XIII
• Carbon footprint methodology: Annex II
• Data carrier and QR on the battery label: Article 13
• Electronic accessibility of the passport: Article 77

The practical takeaway: ESPR and the Battery Regulation are two parallel legal bases for the same underlying concept, a Digital Product Passport. Batteries already have a fixed date and a defined data set. Most other product groups are waiting on their own delegated acts. A platform built to handle one passport schema should handle both, which is the logic behind a regulation-agnostic approach. We cover the battery side in detail on our EU Battery Regulation page.

The timelines that are actually fixed

One of the most common questions is simply: when does this apply to me? The honest answer is that it depends on your product, but a few dates are already concrete.

1. The EU DPP Registry: ESPR establishes a central registry under Article 13, and the Commission is to set it up by 19 July 2026. This registry is where DPP data carriers are recorded so that authorities, including customs, can verify products. How it actually operates — identity verification, registration, and data retention — is set out in Commission Implementing Regulation (EU) 2026/1778.
2. Product-specific DPP rules: these arrive through delegated acts, each on its own timeline per product group. Priority groups identified in the Commission’s first ESPR working plan include textiles, iron and steel, aluminium, furniture, and tyres, among others. Until a delegated act for your category is adopted, the precise DPP data fields for that category are not yet fixed.
3. The battery passport: as above, 18 February 2027 under Regulation (EU) 2023/1542.

So when does this hit you? Sooner than the deadline suggests. The data underlying a passport, your bill of materials, supplier declarations, recycled-content figures, and substance information, takes time to gather no matter which delegated act lands first. Supplier declarations and recycled-content data typically take multiple quarters to collect across a fragmented supply chain, so a 2027 or 2028 delegated act effectively means starting the data work in 2026. The format is uncertain; the need for clean, sourced supply-chain data is not.

What this means for non-EU manufacturers

ESPR applies to products placed on the EU market regardless of where they are made. For a manufacturer outside the EU, the obligation typically lands on the economic operator that places the product on the market, often an importer or an authorised representative. Under the Battery Regulation, for example, Article 4 sets out how responsibility falls to importers and distributors when the producer is established outside the EU. The consequence chain is short and concrete:

1. The legal duty falls to the importer or authorised representative under Article 4.
2. Without a compliant passport and data carrier, the goods can be held at the border by customs.
3. Market access is refused, and your importer looks for a supplier who can deliver the data.

That is the part a non-EU manufacturer should not wave away as someone else’s problem. The legal duty may sit with the importer, but the data can only come from you. Your importer cannot build a compliant passport without your bill of materials, supplier declarations, and substance information, and if you cannot supply clean, structured supply-chain data on request, the work and the liability risk come straight back to you, often at the worst possible moment. The simplest way to stay on the shelf is to hand your importer a passport-ready data foundation rather than a pile of PDFs. Member states set penalties that, under the Battery Regulation’s Article 89, must be effective, proportionate, and dissuasive; the specific amounts are determined nationally rather than in the regulation itself. You can follow how customs verification ties into the registry on our EU Central Registry page.

How manufacturers can prepare now

You cannot finalise a passport whose fields are not yet published. You can do almost everything else. A regulation-agnostic compliance platform is built precisely for this gap, mapping one data foundation to whichever schema a delegated act ultimately requires.

• Consolidate your product and supplier data. The bottleneck is rarely the technology; it is assembling accurate material, sourcing, and substance data from a fragmented supply chain. Once a supplier verifies a material declaration, that data can be reused across every product and regulation it appears in, so you collect it once rather than per product.
• Use AI to cut the manual burden. AI-assisted extraction reads your existing PDFs, test reports, and technical datasheets and pre-populates the structured passport fields (Annex XIII for batteries), so your team verifies values instead of transcribing them. How much it saves depends on document quality; the mechanism is the point. See our AI Document Intelligence page.
• Generate compliant data carriers. ESPR and the Battery Regulation both rely on a standardised data carrier. Traceable generates GS1 Digital Link QR codes that resolve to the passport.
• Run a gap analysis. Compliance gap scoring shows you, field by field, what data you hold and what is missing against a target schema, so you know exactly where to focus before any deadline. You can start a gap analysis on the free tier, see our pricing.
• Plan for verification. Give auditors and regulators controlled, read-only access to inspect records, with passport data validated for schema and structure. This is structural validation, not a certification of authenticity, and being precise about that distinction protects you in an audit.

For a fuller view of the regulatory landscape across product groups, our regulatory hub tracks each regulation and its status.

Conclusion

ESPR 2024/1781 is the framework that brings the Digital Product Passport to nearly every product sold in the EU, with the battery passport leading the way under Regulation (EU) 2023/1542 from 18 February 2027 and most other product rules arriving through delegated acts on their own timelines. The data work, not the format, is the real lead time, so the manufacturers who start consolidating supplier and product data now will be ready whichever delegated act lands first.

See how Traceable turns scattered documents into a passport-ready data foundation: book a demo. (Prefer to look first? See how it works, or start free on our pricing page.)