EU DPP Glossary — Digital Product Passport Terms Explained

Every term a manufacturer needs to understand when navigating EU ESPR and Battery Regulation compliance. Plain English definitions with regulation references.

A

Annex XIII

Annex XIII of EU Battery Regulation 2023/1542 specifies the mandatory and recommended data fields that must be included in a battery passport. It covers six sections: general information, carbon footprint, recycled content, performance and durability, hazardous substances, and supply chain due diligence.

EU Battery Regulation 2023/1542, Annex XIII

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Authorised Representative

A natural or legal person established in the EU who has been mandated by a manufacturer established outside the EU to act on their behalf in relation to specified obligations under EU product legislation. The authorised representative can be the responsible party for DPP obligations.

ESPR 2024/1781, Article 4

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B

Battery Passport

A machine-readable data record that accompanies every EV, LMT, and industrial battery above 2 kWh placed on the EU market from February 18, 2027. The battery passport contains data specified in Annex XIII of Regulation 2023/1542, accessible via a QR code and unique identifier.

EU Battery Regulation 2023/1542, Article 77

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C

Carbon Footprint Declaration

A documented statement of the carbon footprint of a product, typically expressed per functional unit (e.g., kg CO2e per kWh for batteries). Required under Annex XIII for battery passports and expected for other ESPR product categories.

EU Battery Regulation 2023/1542, Annex XIII Section 2

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D

Data Carrier

The physical medium through which a Digital Product Passport is accessed. Under EU regulations, this is a QR code encoded with a GS1 Digital Link URI. The data carrier must be affixed to the product, its packaging, or accompanying documentation.

ESPR 2024/1781, Article 9

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Delegated Act

A legally binding EU regulation adopted by the European Commission that supplements the ESPR framework regulation. Each delegated act sets the specific DPP requirements, data fields, and compliance deadlines for a particular product category.

ESPR 2024/1781, Article 4

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Digital Product Passport

A structured, machine-readable data record that contains information about a product's composition, environmental footprint, durability, repairability, and supply chain. Required by EU law for an expanding set of product categories under ESPR and the Battery Regulation.

ESPR 2024/1781, Article 9

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E

Economic Operator

Any manufacturer, importer, distributor, authorised representative, or fulfilment service provider involved in placing a product on the EU market. Different economic operators have different obligations under DPP regulations.

ESPR 2024/1781, Article 2

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ESPR

Ecodesign for Sustainable Products Regulation (EU 2024/1781). The framework regulation that establishes the legal basis for Digital Product Passports across all product categories sold in the EU. Specific requirements are set through delegated acts per product category.

Regulation (EU) 2024/1781

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G

H

Hazardous Substance

A chemical substance present in a product that is classified as hazardous under EU REACH regulation. DPP requirements include declaring the presence, concentration, and location of substances of very high concern (SVHCs) above 0.1% by weight.

Related: SVHC REACH

REACH Regulation 1907/2006, Article 33

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I

Importer

Any natural or legal person established in the EU who places a product from a non-EU country on the EU market. Importers share responsibility for DPP compliance — if the non-EU manufacturer has not created a passport, the importer must.

ESPR 2024/1781, Article 4

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L

LMT Battery

Light Means of Transport battery — a battery with a capacity between 25 Wh and 5 kWh used in light electric vehicles including e-bikes, e-scooters, and similar vehicles. LMT batteries require a battery passport from February 18, 2027.

EU Battery Regulation 2023/1542, Article 3(11)

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M

Manufacturer

Any natural or legal person who manufactures a product, or has a product designed or manufactured, and markets that product under their name or trademark. The manufacturer is the primary responsible party for creating and maintaining a product's DPP.

ESPR 2024/1781, Article 2

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Market Surveillance Authority

A national authority designated by each EU Member State to enforce product compliance regulations. Market surveillance authorities can inspect DPP data, require corrections, order market withdrawal, and impose penalties for non-compliance.

Regulation (EU) 2019/1020

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P

Persons of Legitimate Interest

Third parties with a legitimate reason to access specific DPP data beyond the publicly available information. Under Battery Regulation Article 77(3), this includes recyclers, repairers, second-life operators, and market surveillance authorities, each with different data access tiers.

EU Battery Regulation 2023/1542, Article 77(3)

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R

REACH

Registration, Evaluation, Authorisation and Restriction of Chemicals — EU Regulation 1907/2006. REACH requires manufacturers and importers to declare substances of very high concern (SVHCs) in their products. This data feeds directly into DPP hazardous substance fields.

Regulation (EC) 1907/2006

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Recycled Content

The proportion of recycled material in a product, expressed as a percentage by weight. For batteries, Annex XIII requires declaration of recycled cobalt, lithium, nickel, and lead content, with separate pre-consumer and post-consumer shares.

EU Battery Regulation 2023/1542, Annex XIII Section 3

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S

Supply Chain Due Diligence

The process of identifying, preventing, and mitigating adverse impacts in a product's value chain. For battery passports, this includes declaring the origin and certification status of critical raw materials including cobalt, lithium, nickel, manganese, and graphite.

EU Battery Regulation 2023/1542, Annex XIII Section 6; CS3D

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SVHC

Substance of Very High Concern — a chemical substance identified under REACH as having serious effects on human health or the environment. SVHCs present above 0.1% concentration by weight must be declared in the DPP hazardous substances section.

REACH Regulation 1907/2006, Article 57

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