EU Digital Product Passport — Frequently Asked Questions

A Digital Product Passport (DPP) is a structured, machine-readable data record that accompanies a physical product throughout its lifecycle. The law that requires it sets its content, which can include the product's composition, origin, environmental footprint, repairability and end-of-life handling. The first mandatory passports are battery passports under Regulation (EU) 2023/1542, from 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric-vehicle batteries. Under ESPR 2024/1781, passports become mandatory product group by product group through delegated acts; none had been adopted as of 26 September 2026.

The economic operator that places a product covered by a passport requirement on the EU market, usually the manufacturer or, for an imported product, the importer. For batteries this is Article 77 of Regulation (EU) 2023/1542, for LMT batteries, industrial batteries above 2 kWh and electric-vehicle batteries. For textiles, tyres and electronics, passport duties will depend on ESPR delegated acts, none of which had been adopted as of 26 September 2026. Supply chain data usually has to come from upstream suppliers.

EU Battery Regulation 2023/1542 requires battery passports from 18 February 2027 for EV, LMT, and industrial batteries above 2 kWh. No ESPR delegated act had been adopted for textiles, tyres, or electronics as of 26 September 2026. The Commission's working plan (COM(2025) 187) gives 2027 as the indicative adoption date for textiles and tyres; electronics are covered through horizontal measures on repairability (2027) and on recycled content and recyclability of electrical and electronic equipment (2029). No binding compliance date exists for any of these categories until the relevant delegated act is adopted. The Commission announced the EU digital product passport registry as live on 20 July 2026, one day after the 19 July 2026 set-up deadline in ESPR Article 13(1).

Penalties are set by each Member State and must be "effective, proportionate and dissuasive" (ESPR Article 74; for batteries, Article 93 of Regulation (EU) 2023/1542). Neither regulation sets EU-wide fine amounts, so the exact penalty varies by country. A product that lacks a required passport cannot lawfully be placed on the EU market: authorities can order corrective action, withdrawal or recall, and customs can refuse its release for free circulation under Regulation (EU) 2019/1020.

Upload your existing technical documents (test reports, certificates, BOMs). AI extraction proposes structured compliance data for the correct DPP fields, each value with a High, Medium or Low confidence rating, and you review and approve every extraction. The platform scores your compliance, collects missing data from your suppliers through structured requests in the supplier portal, and publishes a machine-readable passport with a QR code, in GS1 Digital Link format where the product has a GTIN.

It depends mainly on how complete your existing technical documentation is. AI document extraction proposes values for you to review and approve. The longer part is usually gathering supply chain data from upstream suppliers, which you can request through the supplier portal.

We offer a free trial with the full platform rather than a capped permanent plan: product creation, compliance scoring, GS1 Digital Link QR codes, public passport pages and export. No credit card required. AI document extraction is billed separately, based on the number of documents processed, in the trial as on every plan. After the trial you choose an annual plan, priced per published passport from €15 on Starter down to €6 or below on Custom, with a one-time activation fee, or pay as you go at €18 per published passport.

Yes. Most DPP data already exists in your technical documentation: test reports, IEC certificates, REACH declarations, carbon footprint studies and bills of materials. Traceable's AI extraction reads PDF, PNG and JPG files and proposes values for the correct regulatory fields, each with a High, Medium or Low confidence rating, for you to approve instead of retyping them.

Traceable covers batteries (EV, LMT, industrial, SLI and portable) and textiles.

Traceable's AI capabilities include single and bulk document extraction, automatic document type detection, cross-document field mapping, product data autofill, certificate requirements suggestion, compliance checking, jurisdictional compliance, product compliance analysis, recall risk analysis, supply chain traceability checking, product category suggestion, and passport access-level enforcement. AI-extracted values enter your passport only after a person approves them.

Your suppliers receive an email with a one-time access code. They log in without creating an account, see only the data request you sent, enter component data, upload certificates, and leave. No friction, no cost to them. Every interaction is audit-logged. Your product data is invisible to your suppliers.

GS1 Digital Link is a GS1 standard for encoding product identifiers such as the GTIN in a web address that a QR code can carry. Traceable generates a QR code in GS1 Digital Link format for each product that has a GTIN; scanning it opens the public passport. GS1 is not required by the ESPR or the Battery Regulation: the Battery Regulation requires a QR code (Article 13(6)) linked to a unique identifier complying with ISO/IEC 15459 or equivalent (Article 77(3)), and ESPR identifiers must comply with the ISO/IEC 15459 series where relevant (Annex III).

Yes. Traceable's v1 REST API lets you draft, validate and submit passports programmatically, with ERP mapping endpoints and machine-readable JSON output. Headless API access is included on Scale and Custom plans; Starter and Growth use the operator portal.

The primary database and file storage run in the EU, in Ireland, and the application runs in Dublin. AI features run on Anthropic's Claude models through Amazon Bedrock in the European Union. AWS states in its Amazon Bedrock FAQ that neither AWS nor third-party model providers use inputs to or outputs from Amazon Bedrock to train models, and that inputs and outputs are not shared with model providers. Encryption at rest and in transit. GDPR-compliant by architecture with data processing agreements, subprocessor transparency, and data minimisation throughout.

Yes. Traceable is GDPR-compliant by design. We provide data processing agreements, maintain a transparent subprocessor list, support data subject requests, implement data minimisation, and offer full data export and deletion on request. Built-in GDPR tools help you manage the privacy aspects of your DPP data.

Yes. CSV export is available on every plan, and JSON-LD export from the Growth plan. Your data is yours: portable, exportable, and deletable on request.

When your account ends, your company is set to inactive and your published passports stay online, read-only, with a notice that the passport is kept available. You can export all your data before cancelling. Contact us for specific data retention details.

Partly. Passports can carry your company's branding on the public passport page: logo, brand name, colours, support link and footer text. Custom domains are not available as of 26 September 2026.