What Is a Digital Product Passport: A Plain-English Guide for EU Manufacturers

What Is a Digital Product Passport?

A digital product passport is “a set of data specific to a product” that is “accessible via electronic means through a data carrier,” as defined in Article 2, point (28) of Regulation (EU) 2024/1781 (the Ecodesign for Sustainable Products Regulation, or ESPR). In plain terms, it is a structured electronic record tied to a physical product, not a brochure or a marketing page. The data carrier, such as a linear barcode or a two-dimensional symbol, sits on the product itself, its packaging, or its accompanying documentation, as specified in the applicable delegated act (ESPR Article 10(1), point (b)). For more detail, see the what is a Digital Product Passport: detailed guide.

When Does EU Law Actually Require One?

EU law does not require a digital product passport for every product. A passport becomes a legal obligation only where a specific act provides for it. Two routes exist today.

The first route is ESPR. Under Article 9(1) of Regulation (EU) 2024/1781, a passport becomes a condition of placing a product on the market only through a delegated act adopted under Article 4 for that product group. As of 20 September 2026, no ESPR delegated act setting passport requirements for any product group had been adopted. When such acts are adopted, Article 4(4) states they cannot apply earlier than 18 months after entry into force, except in duly justified cases or in cases of partial repeal or amendment of delegated acts.

The second route is product-specific legislation that requires a passport directly. Examples already in force include the following.

• Batteries: Article 77(1) of Regulation (EU) 2023/1542 requires a battery passport for each LMT battery, each industrial battery with a capacity above 2 kWh, and each electric vehicle battery placed on the market or put into service from 18 February 2027.
• Toys: Article 19 of Regulation (EU) 2025/2509 on toy safety requires a manufacturer to create a digital product passport before placing a toy on the market, applying from 1 August 2030.

If your product falls outside these categories, check whether a delegated act under ESPR or another product-specific act, such as the detergents or construction products regulations, provides for a passport for your product group before assuming an obligation exists.

What Data Goes Into a Passport?

The data a passport must contain is set per product group, not by ESPR itself in a single universal list. Under ESPR Article 9(2), each delegated act specifies, as appropriate for the product group and among other things, the data to include, the data carriers to be used, whether the passport is established at model, batch, or item level, and which actors have access to which data.

For batteries, Annex XIII of Regulation (EU) 2023/1542 sets out four numbered points covering what information must be held. Point 1 covers information on the battery model accessible to the public. Point 2 covers information on the battery model that Annex XIII makes accessible only to persons with a legitimate interest and the Commission; Article 77(2), point (b), also gives notified bodies and market surveillance authorities access to it. Point 3 covers test report results accessible only to notified bodies, market surveillance authorities, and the Commission. Point 4 covers information and data on the individual battery accessible only to persons with a legitimate interest. Article 77(2) sets the access groups for each point.

Each ESPR delegated act specifies the test, measurement or calculation standards or methods to be used (ESPR Article 8, point (d), and Article 39(1)). For batteries, the carbon footprint figure combines battery-specific activity data with secondary datasets, as set out in Annex II, point 5 of Regulation (EU) 2023/1542.

One practical note on data volume: the Commission has published a guidance document on Digital Battery Passport data points by category (Version 2.0, 15 August 2026). That document lists numbered data points and marks each one, per battery category, as mandatory, optional, applicable only in certain cases, or not to be filled or displayed when the passport requirement starts in February 2027. It is not binding, states that it does not extend the rights and obligations in the legislation or introduce any additional requirement, and states that it should not be considered representative of the Commission’s official position. The numbering is the guidance’s own, not the Regulation’s.

How Is the Passport Accessed?

The passport must be connected through a data carrier physically present on the product, its packaging, or its accompanying documentation (ESPR Article 10(1)). ESPR’s articles and annexes do not specify QR codes. Recitals 37 and 46 of ESPR mention QR codes only as examples.

The Battery Regulation is more specific. Article 13(6) of Regulation (EU) 2023/1542 requires all batteries to be marked with a QR code from 18 February 2027. Where marking the battery itself is not possible or not warranted because of its nature and size, Article 13(7) requires the QR code to be affixed to the packaging and to the documents accompanying the battery instead.

On access rights, ESPR sets no fixed tiers that apply across all product groups. Each delegated act decides which actors may access which passport data (Article 9(2)(f)), in line with the specific access rights at product group level (Article 10(1)(g)). The Commission and customs authorities may retrieve and use passport data for their duties under Union law (Article 15(4) of ESPR). The phrase “persons with a legitimate interest” is Battery Regulation wording, appearing in Article 77(9) and Annex XIII, points 2 and 4; it does not appear in ESPR.

Who Is Responsible for the Passport?

The passport is a regulatory record, not marketing material. Its data must be accurate, complete, and up to date. ESPR Article 9(1) states this for ESPR passports; Article 77(4) of Regulation (EU) 2023/1542 states the same for battery passports.

Conformity can rest on a declaration by the manufacturer on its sole responsibility. Each ESPR delegated act specifies the conformity assessment module. The options are internal production control (Module A, set out in ESPR Annex IV) or a module from Decision No 768/2008/EC (ESPR Article 4(5)).

For batteries, the picture is more detailed. Module A is available for the requirements in Articles 6, 9, 10, 12, 13, and 14 of Regulation (EU) 2023/1542. Conformity with the carbon footprint and recycled content requirements is assessed under Module D1 or Module G (Article 17 of Regulation (EU) 2023/1542). Under Annex VIII, Parts B and C, Module D1 and Module G involve a notified body, unlike Module A.

What About ESPR Product Groups Not Yet Covered?

ESPR gives the Commission power to adopt delegated acts for specific product groups under Article 4. Each act sets ecodesign requirements, and where it includes passport requirements, it must follow the rules in Articles 9, 10 and 11. The Commission may exempt a product group from the passport requirement only on the grounds listed in Article 9(4).

The Commission published a working plan in COM(2025) 187 that gives indicative adoption years for delegated acts covering named product groups. Those years are indicative, not confirmed. Once a delegated act is adopted and enters into force, Article 4(4) of ESPR sets the earliest possible application date at 18 months after entry into force, except in duly justified cases or in cases of partial repeal or amendment of delegated acts. Until a delegated act for your product group is adopted, no ESPR passport obligation exists for that group.

What Should Manufacturers Do Now?

If you sell batteries in the EU, the 18 February 2027 date in Article 77(1) of Regulation (EU) 2023/1542 is set by the Regulation as in force. You need a conforming battery passport for every LMT battery, every industrial battery above 2 kWh, and every EV battery you place on the market from that date. Work backwards from February 2027 to allow time for data collection, system integration, and conformity assessment under Article 17.

If you sell toys, Article 19 of Regulation (EU) 2025/2509 requires a passport to exist before a toy is placed on the market, and that requirement starts on 1 August 2030 (Article 59). That gives more lead time, but the data requirements will still need preparation.

If you sell other products, monitor the ESPR delegated act pipeline. The Commission working plan COM(2025) 187 lists indicative adoption years by product group. When a delegated act for your group enters into force, Article 4(4) sets the earliest date of application at 18 months later, except in the cases that paragraph lists. Use the time before then to build your data infrastructure.

In all cases, treat the passport as a live compliance record. Passport data must stay accurate, complete and up to date (ESPR Article 9(1); Article 77(4) of Regulation (EU) 2023/1542), so data that becomes inaccurate or incomplete after the product is placed on the market needs correcting.

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