ESPR enters into force across all 27 EU member states.
Digital Product Passport (DPP)
The Ecodesign for Sustainable Products Regulation (ESPR) requires any company placing physical products on the EU market to create and maintain a Digital Product Passport for each in-scope product.
A Digital Product Passport is a machine-readable, uniquely identified digital record linked to each physical product It provides structured access to lifecycle-level data.
The first mandatory deadline is the battery passport under the EU Battery Regulation, applying from February 18, 2027.
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: any manufacturer, importer, or distributor placing in-scope batteries on the EU market must have a functioning battery passport linked to each physical battery through a QR code and unique identifier by that date.
Product categories beyond batteries are entering their own delegated act cycles under ESPR. Textiles and apparel, tires, and aluminum are expected to follow in 2027, with furniture phasing in through 2028.
Keydates 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 each physical product through a data carrier, most commonly a QR code. It provides structured access to lifecycle-level product data: material composition, recycled content, carbon footprint, substances of concern, disassembly and repair instructions, and end-of-life handling. The DPP must remain accessible for the product's typical lifetime plus an additional ten years, including in the event of manufacturer insolvency 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 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.
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.
Registry connection and GS1 interoperability require technical integration
The EU DPP Registry functions as an access point for unique product identifiers. DPPs must be structured to GS1 Digital Link standards, carry unique identifiers compliant with ISO/IEC 15459, and support tiered access rights for consumers, regulators, recyclers, and repair operators.
A Scalable Data Backbone for Digital Product Passports
The osapiens HUB for Digital Product Passport connects product master data, supplier declarations, and existing compliance records into a GS1-compliant DPP data model, linked to the EU DPP Registry and structured to the access rights requirements of each stakeholder group. The solution was co-developed with OTTO, one of Germany's largest online retailers, to handle enterprise product catalog scale.
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