Your questions answered
Answers checked against texts published in the Official Journal of the EU. Last checked: 21 October 2026.
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A Digital Product Passport is a set of information linked to a product and accessed through a data carrier, such as a QR code, placed on the product, its packaging or its accompanying documents. It was created by the EU Ecodesign for Sustainable Products Regulation (ESPR) and has since been taken up by other sector-specific laws. Each product in scope carries a unique identifier. The information required, its level of granularity (model, batch or item) and who may access it are set category by category.
Source: Regulation (EU) 2024/1781, Art. 2, 9 and 10.
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The EU passport registry currently covers products falling under five regulations: the ESPR (2024/1781), for each product category the Commission addresses through a delegated act; the Batteries Regulation (2023/1542); the Construction Products Regulation (2024/3110); the Toy Safety Regulation (2025/2509); and the Detergents Regulation (2026/405). Vehicles have passports of their own: the Environmental Vehicle Passport introduced by Euro 7 (2024/1257) and the circularity vehicle passport introduced by the End-of-Life Vehicles Regulation (2026/1738). Other laws require closely related product data without calling it a passport, such as the Critical Raw Materials Act for permanent magnets.
Source: Implementing Regulation (EU) 2026/1778, Art. 1; Regulation (EU) 2024/1257, Art. 7; Regulation (EU) 2026/1738, Art. 13.
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The first passport to apply is the Environmental Vehicle Passport, from 29 November 2026 for new types of passenger cars and light commercial vehicles. The first passport recorded in the EU registry is the battery passport, from 18 February 2027. For products under the ESPR, the Commission's indicative timeline places the iron and steel delegated act at the end of 2026, followed by textiles, tyres and aluminium in the second half of 2027; each act normally applies no earlier than 18 months after it enters into force. Detergents follow on 23 September 2029, toys on 1 August 2030 and the circularity vehicle passport on 1 September 2032. An announced date remains indicative until the text is published.
Source: European Commission DPP page, indicative timeline; Regulations (EU) 2024/1257, Art. 21; 2023/1542, Art. 77; 2024/1781, Art. 4; 2026/405, Art. 37; 2025/2509, Art. 59; 2026/1738, Art. 13.
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The registry, run by the European Commission, records each passport's unique identifier and where the passport can be accessed; it does not host the data, which stays with the company or its service provider. Provided for in Article 13 of the ESPR, it went live in July 2026 and operates under Implementing Regulation (EU) 2026/1778. To register a passport, a company must have its identity verified, through a qualified electronic seal under eIDAS for a legal entity; verified-operator status lasts for 3 years at most. A successful automated check on a registration does not prove that the product complies.
Source: Implementing Regulation (EU) 2026/1778, Art. 3, 4 and 8, recital 16.
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The battery passport is mandatory from 18 February 2027 for light means of transport (LMT) batteries, industrial batteries above 2 kWh and electric vehicle batteries. From the same date, all batteries must bear a QR code. The passport is linked to the battery's unique identifier and accessed through that QR code. Who has a legitimate interest in the non-public information depends on an implementing act the Commission had not adopted at the date of verification.
Source: Regulation (EU) 2023/1542, Art. 13(6) and 77.
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No date has been set for textiles yet. It will be fixed by the ESPR delegated act for textiles, which the Commission indicatively expects to adopt in the second half of 2027. The ESPR leaves at least 18 months between such an act's entry into force and its application, save in duly justified cases, so the textile passport is unlikely to apply before 2029. Studies by the Commission's Joint Research Centre (JRC), published in December 2025 and May 2026, give a preview of its content, such as robustness and recyclability scores, recycled content and substances of concern; they are not binding.
Source: Regulation (EU) 2024/1781, Art. 4; European Commission DPP page; JRC textile documents.
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There is no single date for electrical and electronic equipment. Some products already covered by ecodesign rules move under the ESPR as their measures are revised, by 2030 under the Commission's working plan, and each revision may introduce a passport; the others are still revised under the former Ecodesign Directive, without an ESPR passport. A horizontal measure on repairability is announced for 2027. For washing machines, dishwashers, vacuum cleaners, heat pumps and other appliances containing certain permanent magnets, the Critical Raw Materials Act requires a data carrier 2 years after an implementing act that has not yet been adopted. In France, the repairability and durability indexes already cover part of this data.
Source: Regulation (EU) 2024/1781, Art. 18 and 79; working plan COM(2025) 187; Regulation (EU) 2024/1252, Art. 28.
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Construction products: the passport under Regulation (EU) 2024/3110 will be set up by a delegated act, indicatively announced for Q2 2027; manufacturers will then have 18 months to make the passport available. Toys: the passport under Regulation (EU) 2025/2509 applies from 1 August 2030; its technical content depends on delegated acts not yet adopted. Detergents: the passport under Regulation (EU) 2026/405 is due on the date the regulation applies, 23 September 2029, with technical requirements set by an implementing act.
Source: Regulation (EU) 2024/3110, Art. 22(7), 75 and 80; Regulation (EU) 2025/2509, Art. 19 and 59; Regulation (EU) 2026/405, Art. 21 and 37.
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The obligation lies with the economic operator placing the product on the EU market: the manufacturer, or the importer for a product made outside the EU. An importer or distributor selling a product under its own brand (private label) takes on the manufacturer's obligations. The law designates no internal function, and the company remains fully responsible when it entrusts registration to a service provider. In practice, the topic involves sustainability, compliance, product, quality, IT and data, supply chain and procurement, and the question to settle is which function arbitrates between them.
Source: Regulation (EU) 2024/1781, Art. 27, 29 and 34; Implementing Regulation (EU) 2026/1778, Art. 19.
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The act covering each product category sets the list. The ESPR provides the pool it draws from: unique identifier and GTIN, customs codes, compliance documentation, manuals and safety information, manufacturer and importer details, information on use, repair and end of life, and substances of concern. Access is free of charge and tiered: some information is public, some is reserved for repairers, recyclers or authorities, for example. The passport may not contain customers' personal data without their consent.
Source: Regulation (EU) 2024/1781, Art. 7, 9, 10 and 11, Annex III.
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The ESPR sets a baseline: data based on open standards, interoperable and transferable without lock-in to a single provider, and a backup copy held by an independent third-party provider. Since 15 July 2026, 6 European standards (EN 18216, 18219, 18220, 18221, 18222 and 18223) confer a presumption of conformity with these requirements; the standards on access rights (EN 18239) and authentication (EN 18246) had not been cited in the Official Journal at the date of verification. Compliance with standards is only one criterion among several. The choice depends first on what the company hands over to the provider and what it keeps in house: upstream data quality, integration with existing systems (PLM, ERP), access-rights management, reversibility and portability, which are negotiated before signing, and the ability to cover several product categories and passport regimes. A delegated act on DPP service providers is announced for 2027.
Source: Regulation (EU) 2024/1781, Art. 10 and 41; Implementing Decision (EU) 2026/1736.
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The act for a given product category will set the passport's content, granularity and deadline. It will not say whether the company holds that data, what it can obtain from its suppliers, or who is accountable for it internally. An obligation arising from the passport framework is not always a passport obligation: the ESPR already requires large companies to disclose every year the unsold goods they destroy and, since 19 July 2026, bans them from destroying unsold apparel, clothing accessories and footwear. These obligations rely on a data foundation close to the passport's, with different purposes, owners and levels of proof: one foundation is built and orchestrated for several uses. Some decisions, by contrast, are best left open until the act is published, such as the exact content of the fields and the product identification level (model, batch or item).
Source: Regulation (EU) 2024/1781, Art. 24, 25 and Annex VII.
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No law sets an amount, and the cost depends on product volumes, the required level of granularity (model, batch or item) and the state of the starting data. The cost items can be named: collecting and structuring data, including from suppliers; the platform or provider hosting the passport; identifiers and data carriers; a qualified electronic identity for the registry; a backup copy held by a third party; and updates over time. The weight of each item can only be measured on an actual scope.
Source: Regulation (EU) 2024/1781, Art. 10 and 12; Implementing Regulation (EU) 2026/1778, Art. 4.