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Digital Product Passport (DPP): What It Is, Who Needs One and What It Asks of Your PIM
Stephan Spijkers · 2026-10-17 · 11 min read
The Digital Product Passport (DPP) is often described as a label or a website behind a QR code. It is neither. It is a record that other parties, from a market surveillance authority to a recycler, can read and verify. This guide covers what the DPP is, which products and dates are fixed and which are still open, what data it needs, and what it asks of your product data setup.
Several earlier articles on this site stated dates and scope loosely. This page replaces them and checks every date against the Official Journal or the European Commission.
What a Digital Product Passport is
The ESPR defines a digital product passport as a set of data specific to a product that includes the information specified in the applicable delegated act. The data is reached electronically through a data carrier, which can be a linear barcode, a two-dimensional symbol such as a QR code, or another automatic identification medium. A persistent unique product identifier links the carrier to the passport (Articles 2 and 10 of Regulation (EU) 2024/1781).
The regulation sets the technical frame for every passport:
- The data carrier sits on the product, its packaging or its accompanying documents.
- The data is based on open standards, in an interoperable format, so it can move between systems without vendor lock-in.
- Access follows rights: the public, authorities and professionals see different layers.
- The data stays available after the responsible company stops trading, through a back-up with a DPP service provider.
- Dealers and online marketplaces can ask the operator for a copy of the carrier or identifier, free of charge, and get it within five working days.
Under Article 9, products can only be placed on the EU market once the passport is available, as far as the applicable delegated act requires it. The ESPR does not apply to food, feed or medicinal products, which is why food and pharma are not in scope of the DPP.
Which products need a DPP, and when
Two legal routes exist today. The Battery Regulation applies on a fixed date. The ESPR works product group by product group, through delegated acts that the Commission has still to adopt for most groups.
18 July 2024
ESPR in force
Regulation (EU) 2024/1781 enters into force. The passport rules apply to a product group only once a delegated act for that group applies.
16 April 2025
Working plan 2025 to 2030
The Commission adopts its first ecodesign working plan (COM(2025) 187). Every product with ecodesign measures gets a passport, unless an equivalent system such as EPREL for energy-labelled products already covers it.
20 July 2026
Central DPP registry operational
The ESPR required the Commission to set up the registry by 19 July 2026. The Commission lists it as operational on 20 July 2026, with the implementing rules in Implementing Regulation (EU) 2026/1778. Only verified operators can use it.
18 February 2027
Battery passport
Each light means of transport battery, electric vehicle battery and industrial battery above 2 kWh placed on the market needs a battery passport (Article 77 of Regulation (EU) 2023/1542).
2026 to 2029
ESPR delegated acts, planned
Per the Commission's indicative timeline: iron and steel in Q4 2026, textiles, aluminium and tyres in Q3 to Q4 2027, furniture in 2028, mattresses in 2029. Economic operators get a transition of at least 18 months after each act.
The Commission's Digital Product Passport page labels this timeline indicative and keeps it up to date. The working plan itself is COM(2025) 187.
What data a DPP needs
There is no single DPP data list. The delegated act for each product group sets the required information, and the Battery Regulation does the same for batteries in Annex XIII. What the groups share is the pattern:
- Identification. The product identifier, the economic operator and the facility identifiers. Operator and facility identifiers must follow the standards listed in Annex III of the ESPR.
- Composition and origin. Materials, recycled content and where the product or its parts come from.
- Environmental performance. For batteries this includes the carbon footprint declaration. For other groups the delegated act will say.
- Use and repair. Durability, repairability, spare parts and instructions.
- End of life. How to dismantle, recycle or dispose of the product.
- Compliance evidence. Certificates, test reports and declarations that back the claims.
In our DPP webinars we grouped this into seven working categories: product identification, compliance certifications, bill of materials, environmental impact, circularity and repairability, supply chain provenance, and end-of-life instructions. Use that as a gap-analysis checklist, not as the legal list, which you take from the delegated act for your product.
For batteries, access is tiered. The public sees general information. Notified bodies, market surveillance authorities and the Commission see more. People with a legitimate interest, such as repairers, recyclers and second-life operators, see a further layer. The passport is reached through the QR code, which links to a unique identifier that follows ISO/IEC 15459 or an equivalent standard. The company that places the battery on the market keeps the information accurate, complete and up to date.
The identifier decision: batch or item
The level of the passport decides what your systems must store. A model-level or batch-level passport is cheaper to assign and manage. An item-level passport gives per-unit history, authentication and repair tracking, at a higher operating cost. The delegated act fixes the level for a product group, so you cannot choose freely where it is set. Where the law leaves room, the choice follows product category, expected lifespan, fraud exposure and the use you want beyond compliance.
The battery passport is the clearest case: it is per individual battery. A battery written back with usage and charge history over its life is a lifespan problem most PIM teams have not faced, since a product page used to be retired after a season. A passport has to stay reachable for as long as the product is in the field.
What a DPP asks of your PIM
Most of the data a passport needs already exists in your company. It sits in ERP, PLM, procurement inboxes, certificate folders and PIM, scattered and in formats that do not meet the passport's structure. The task is to surface, structure and govern it.
Map your products to the law
Check each product group against the Battery Regulation and the ESPR working plan. Write down the date and the expected level for each, and mark the groups with no delegated act yet as "watch".
Give every attribute an owner
Name an owner for material, sustainability and lifecycle attributes. Without one, accuracy slips under audit. Our master data management guide covers the ownership layer.
Find where the data lives today
List ERP, PLM, supplier files and certificate folders per attribute. Our PLM and PIM integration guide shows how released engineering data should reach the commercial record once.
Model the passport data and its versions
Keep material, origin and lifecycle data as structured attributes with a version history, not as free text or PDFs. A change in a supplier's declaration should create a new version, not overwrite the old one.
Connect suppliers and validate
A passport for a finished product depends on data from every tier below it. Build supplier data flows with validation and completeness rules, and block publication when required fields are empty.
Pilot on one product line
Start with one product line, establish the governance and surface the real gaps before you scale to the full catalog.
A project approach gives you a passport for today's catalog and nothing for tomorrow's launches. The lasting version is a governed, repeatable workflow in a PIM or MDM, with a feed to wherever the passport is stored. Most existing PIM setups were not built for verified supplier flows and lifecycle records, so expect to extend them. If you are choosing a system, see how to select the right PIM and what a PIM is.
Vendors in our directory that work on passport data include Syndigo, Viamedici and SyncForce. Check each against your product group and the delegated act. Bluestone and Arkive also describe DPP solutions on their own sites.
Blockchain, AI and circular economy claims
Vendor material often ties the passport to blockchain, AI and the circular economy. Read it against the regulation. The ESPR asks for open standards, interoperability, authentication and integrity of the data. It does not prescribe a storage technology, so blockchain is a design choice, used by some to make later changes traceable. AI can help extract data from supplier PDFs, but a human owner still signs off the result, as our guide on what AI inside a PIM actually does explains.
The circular economy is the reason the passport exists. Recyclers need material composition to sort with less contamination, repairers need parts and instructions, and buyers need verified sustainability claims. That only works when the data is complete and comparable, which is why standards for identification and classification matter. ECLASS and GS1 are two that the industry uses; see product classification with GS1, ETIM and ECLASS.
DPP and PPWR: one data foundation, two obligations
The passport covers the product. The PPWR covers the packaging around it. They draw on the same material, supplier and environmental data, but they are separate legal objects with separate duties. A packaging system sits around a sales unit; the passport sits on the product inside it. Treating them as one checklist is where projects go wrong, and treating them as two separate data builds is a waste. Model packaging as its own entity, link it to the product, and both obligations draw on one record. The details are in PPWR packaging compliance and product data.
Compliance data that pays back
The same structured data supports more than the passport. The bill of materials needed for compliance is the base for spare parts sales and after-sales service. Verified material and origin data supports sustainability claims that buyers can check. It also supports authenticity checks for high-value goods and repair or resale models. These are possible uses, not guaranteed returns, and they depend on data that is clean at the source. The same foundation serves AI-ready product data; see AI-ready product data and agentic commerce.
Where to go from here
Frequently asked questions
What is a Digital Product Passport?
A Digital Product Passport (DPP) is a product-specific data set that you reach electronically through a data carrier such as a QR code. The EU defines it in the Ecodesign for Sustainable Products Regulation (ESPR), and the delegated act for each product group sets what it must contain.
Which products need a DPP and from when?
Batteries are first: from 18 February 2027, each light means of transport battery, electric vehicle battery and industrial battery above 2 kWh needs a battery passport. Other products follow once the Commission adopts a delegated act for their group. Steel, textiles, aluminium and tyres are planned first, furniture and mattresses later.
Is a DPP required at model, batch or item level?
The ESPR leaves that to the delegated act of each product group. Do not assume one passport per product category: the act can require the passport per model, per batch or per individual item, and the battery passport is per individual battery.
What data does a DPP contain?
That depends on the product group. The delegated act lists the required information, for example material composition, origin, environmental impact, repair and end-of-life information. Part of the data is public and part is restricted to authorities or professionals such as repairers and recyclers.
Is the Digital Product Passport the same as the PPWR?
No. The DPP comes from the ESPR and the Battery Regulation and applies to the product. The PPWR is a separate regulation for packaging. They draw on the same material and supplier data, so one clean data model can serve both.
Do I need a PIM for the Digital Product Passport?
The law does not require a PIM. But the passport needs structured, versioned product data from several sources, with an owner for every attribute. A PIM that connects to ERP, PLM and supplier data is a practical place to author and publish that record.
Do I need blockchain for a DPP?
No. The ESPR asks for open standards, interoperability and secure, reliable data. It does not require a specific storage technology. Some vendors use blockchain to make changes traceable, but that is their design choice.
Where is the DPP registry?
The European Commission runs a central DPP registry that stores the unique identifiers. The Commission lists it as operational from 20 July 2026. Economic operators register their passports there once a delegated act applies to their product.
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