ESPR enters into force across all 27 EU member states.
DPP
Digital Product Passport (DPP)
The Ecodesign for Sustainable Products Regulation (ESPR) requires companies placing products on the EU market to create and maintain a Digital Product Passport for every product group covered by a product-specific delegated act.
A Digital Product Passport is a machine-readable, uniquely identified digital record linked to a physical product at model, batch or item level. It provides structured access to lifecycle-level data.
The first mandatory deadline is the battery passport under the EU Batteries Regulation, applying from February 18, 2027.
E-Book
Product Compliance & Digital Product Passport for Dummies
"Product Compliance & Digital Product Passport For Dummies" is your practical guide to understanding the next generation of product compliance requirements. Learn how to navigate evolving regulations, improve product transparency, and prepare for the Digital Product Passport (DPP). The book also shows how the osapiens HUB helps companies manage product data, ensure compliance, and build transparency across the value chain.
Prepare for the Digital Product Passport with clarity and confidence.
- Understand DPP requirements: Get a clear overview of Product Compliance obligations and upcoming Digital Product Passport requirements.
- Improve product transparency: Learn how to manage product data and support traceability across the value chain.
- Prepare with confidence: Discover practical guidance, expert tips, and proven approaches to stay ahead of future regulations.
"Product Compliance & Digital Product Passport For Dummies" is your practical guide to understanding the next generation of product compliance requirements. Learn how to navigate evolving regulations, improve product transparency, and prepare for the Digital Product Passport (DPP). The book also shows how the osapiens HUB helps companies manage product data, ensure compliance, and build transparency across the value chain.
Prepare for the Digital Product Passport with clarity and confidence.
- Understand DPP requirements: Get a clear overview of Product Compliance obligations and upcoming Digital Product Passport requirements.
- Improve product transparency: Learn how to manage product data and support traceability across the value chain.
- Prepare with confidence: Discover practical guidance, expert tips, and proven approaches to stay ahead of future regulations.
Next relevant deadline
February 18, 2027. Battery passports become mandatory for electric vehicle batteries, light means of transport batteries, and industrial batteries with a capacity greater than 2 kWh placed on the EU market or put into service.
The requirement is legally fixed: from that date, every in-scope battery placed on the EU market must have a battery passport linked to the physical battery through a QR code and unique identifier. Responsibility lies with the economic operator placing the battery on the market.
Product categories beyond batteries are entering their own delegated act cycles under ESPR. The delegated act for iron and steel is expected in Q4 2026, followed by textiles and apparel, tires, and aluminum in 2027, and furniture in 2028.
Key dates and milestones
What ESPR and the Digital Product Passport require
The Ecodesign for Sustainable Products Regulation entered into force on July 18, 2024. It applies directly across all 27 EU member states and covers any company that manufactures, imports, or places physical products on the EU market, regardless of where those products are produced.
A Digital Product Passport is a machine-readable, uniquely identified digital record linked to a physical product through a data carrier, most commonly a QR code. It provides structured access to lifecycle-level product data, which, depending on the product group, can include material composition, recycled content, carbon footprint, substances of concern, disassembly and repair instructions, and end-of-life handling. The DPP must remain available for the period set in each delegated act, including in the event of insolvency, liquidation or market exit.
ESPR does not define DPP requirements product by product. The European Commission publishes delegated acts that specify mandatory data fields, access rights, and interoperability standards for each product category. The first ESPR Working Plan, adopted on April 16, 2025, identifies iron and steel as the first priority product group, with a delegated act expected in Q4 2026. Textiles and apparel, tires, and aluminum follow with delegated acts expected in 2027, and furniture in 2028.
From February 18, 2027, electric vehicle batteries, light means of transport batteries, and industrial batteries with a capacity greater than 2 kWh placed on the EU market must carry a battery passport accessible via QR code and unique product identifier. DPP requirements for additional product categories take effect as each product-specific delegated act is published and its compliance window closes.
Beyond ESPR and batteries, other EU laws set their own DPP requirements, including the Construction Products Regulation, the Toy Safety Regulation and the Detergents and Surfactants Regulation. Every DPP, whatever its legal basis, is registered in the EU DPP Registry before the product is placed on the market.
Main challenges for companies
Each product category operates on its own delegated act timeline
DPP-capable data infrastructure must be built once and extended category by category. Most ERP and PLM systems were not designed to output structured, GS1-compliant, lifecycle-linked product records.
Product-level data at the granularity ESPR mandates rarely exists in structured form
A compliant DPP requires precise material composition at component level, recycled content percentages with verifiable sourcing evidence, carbon footprint per product, substance-of-concern declarations, and disassembly instructions. The majority of this data sits with tier 2 and tier 3 suppliers and requires structured data requests, not document attachments, to collect at catalog scale.
Each regulation that overlaps with DPP data fields creates a separate supplier collection event
PPWR recycled content and substance declarations, REACH and RoHS compliance records, PFAS obligations, and EUDR geodata all contribute to fields a DPP must contain. Without a shared data layer, every new delegated act triggers another round of supplier outreach for information already held somewhere in the organization. Between 40% and 70% of the data points required under DPP, PPWR, EUDR, CSDDD, CSRD and CBAM overlap.
Registry connection and GS1 interoperability require technical integration
The EU DPP Registry stores each passport's unique identifiers and registration data, while the passport data itself remains decentralized. DPPs must follow the harmonised European standards for identifiers, data carriers and data exchange, with GS1 Digital Link as an established way to implement them, and support tiered access rights for consumers, regulators, recyclers, and repair operators.
A Scalable Data Backbone for Digital Product Passports
A Digital Product Passport is only as credible as the data behind it. The osapiens HUB for Digital Product Passports connects product master data, supplier declarations, and existing compliance records into a GS1-compliant DPP data model, prepared for registration in the EU DPP Registry and structured to the access rights requirements of each stakeholder group. It builds on the osapiens HUB, with more than 2,500 customers and 3.5M+ suppliers managed, and on a long-term partnership with GS1.
Turn existing compliance records into DPP input
The osapiens HUB maps PPWR substance and material declarations, PFAS records, REACH and RoHS compliance data, and EUDR geodata directly into the DPP data model. A supplier response collected for a PPWR substance request is available immediately as a DPP data field without re-collection. More than 100,000 suppliers are registered on the osapiens Supplier Portal, where they share declarations and certificates once and reuse them across business partners. Every data point carries an attestation level: self-declared, certificate-backed or third-party verified.
Generate GS1-compliant DPPs, ready for the EU Registry
The osapiens HUB creates GS1 Digital Link identifiers, QR codes and item-level passports in bulk, with versions and completeness checks per item. Access is governed by legal access classes per data point, with public, legitimate-interest and authority views, so each stakeholder sees only the information relevant to their role. Every value stays linked to its source, attestation level and evidence, with a full audit trail.
Cover DPP data, carbon footprints and supplier due diligence in one platform
Product carbon footprints and supplier due diligence run on the same osapiens HUB foundation as the DPP. Carbon footprints are calculated from the bill of materials and shared with customers and business partners. Supplier data collected for due diligence obligations such as CSDDD connects to osapiens Supplier 360 for risk and performance assessment. Suppliers are asked once, and their responses are reused across DPP, CSDDD and PPWR requests, without duplicate outreach.
Turn compliance data into commercial value
The same verified product data answers customer and retailer inquiries quickly and backs consumer-facing sustainability claims with evidence. Plus, event data from repair and end-of-life can be turned into insights for product design, refurbishment and circular business models.
October 27, 2026, 15:00–10:00 AM (ET) / 4:00 PM (CET)
Digital Product Passports: What’s Confirmed, What’s Next, and How to Prepare
Join osapiens and cattwyk to explore what’s confirmed in the Digital Product Passport regulatory framework, what’s still evolving, and which practical steps your company can take now to prepare.
Get a clear view of the regulatory landscape and what your company can do now to prepare.
Which Digital Product Passport requirements are already confirmed? What is still evolving? And what does this mean for your company’s next steps?
Join osapiens and cattwyk for a webinar focused on the DPP regulatory framework. We will distinguish confirmed requirements from open questions, discuss upcoming developments and outline practical preparation steps.
What you’ll learn
- What’s confirmed: Understand the established regulatory framework and its implications for DPP preparation.
- What’s next: Explore pending decisions and developments that companies should monitor.
- How to prepare: Identify initial steps to assess relevant requirements, map product data and involve the right teams.
- Where to prioritise: Understand what you can start today and where further regulatory clarification is needed.
Frequently asked questions
The economic operator placing the product on the EU market is responsible for ensuring the DPP is accurate, complete, and current. Manufacturers, importers, and distributors each carry distinct obligations depending on their supply chain role and the applicable delegated act. Under Regulation (EU) 2024/1781, the DPP must remain accessible throughout the product's lifetime plus ten years, including in the event of manufacturer insolvency or market exit.
The ESPR Working Plan 2025-2030, adopted April 16, 2025, identifies iron and steel as the first priority group with a delegated act expected in 2026, followed by textiles and apparel, tires, and aluminum in 2027, and furniture in 2028. A binding compliance date is not set by the Working Plan itself. Each delegated act confirms the binding compliance date and specific data requirements for its product category; a compliance window of approximately 18 months typically follows delegated act adoption. The first legally fixed DPP deadline is the battery passport under Regulation (EU) 2023/1542, mandatory from February 18, 2027 for electric vehicle batteries, light means of transport batteries, and industrial batteries with a capacity greater than 2 kWh.
Required data fields are defined by the delegated act for each product category and vary by product group. The common core across categories includes a unique product identifier compliant with ISO/IEC 15459, material composition and component-level sourcing data, verified recycled content percentages, substance-of-concern declarations, carbon footprint per product, and repairability and end-of-life instructions. A DPP must be dynamic and updatable throughout the product lifecycle; a static document or PDF does not meet the requirements of Regulation (EU) 2024/1781.
ESPR Article 13 requires the European Commission to establish the EU DPP Registry by July 19, 2026. The Registry provides the infrastructure for unique product identifier registration and lookup across the EU single market; it is not a central database storing proprietary product data. DPPs must work with the Registry in line with GS1 Digital Link standards and the harmonized standards being developed by CEN, CENELEC, and ETSI under Standardization Request M/604.
Yes. Regulation (EU) 2024/1781 applies to any company placing in-scope products on the EU market regardless of where the company or its manufacturing operations are based. An importer placing an in-scope product on the EU market carries the same DPP obligations as a European manufacturer. International companies need to identify which product categories they supply, track the applicable delegated act timelines, and confirm that product-level data can be collected, structured, and submitted in line with each delegated act's requirements before the applicable compliance window closes.
PPWR recycled content data, substance declarations, and material composition records directly populate DPP data fields. CSDDD supply chain due diligence data, including sourcing country records and supplier risk assessments, maps to the DPP's sourcing transparency fields. REACH, RoHS, and PFAS compliance records contribute substance-of-concern data. In the osapiens HUB for Digital Product Passport, data collected for any of these regulations feeds the DPP data model without a separate supplier collection step, because all compliance programs run on the same shared product and supplier data layer. One supplier engagement covers multiple regulatory data requirements at the same time.
The osapiens HUB for Digital Product Passport is built around a shared product and supplier data layer that extends to each new product category as its delegated act is adopted. Companies preparing for the battery passport deadline can use the same data infrastructure for textiles, tires, aluminum, and furniture obligations as each delegated act enters its compliance window. The DPP data model in the platform is updated as each delegated act confirms its specific data fields and access rights requirements.
DPPs must be structured to GS1 Digital Link standards and carry unique product identifiers compliant with ISO/IEC 15459. Harmonized European standards for DPP interoperability, data structure, data carriers, and access rights are being developed by CEN, CENELEC, and ETSI under Standardization Request M/604, issued by the European Commission on July 31, 2024. The first six technical standards under M/604 were published by CEN and CENELEC in May 2026.
