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Digital product passport

Digital Product Passport ESPR: what the regulation provides

The Digital Product Passport under the ESPR will make sustainability, circularity and compliance data accessible. Find out which products may be covered, when rules apply and what data to prepare.

By the EU Seller Kit editorial teamPublished on Updated on 14 min read

Contents
  1. What is the Digital Product Passport ESPR: what the regulation provides?
  2. Which products and sellers may be affected by the DPP?
  3. What information will a Digital Product Passport need to contain?
  4. When will the DPP become mandatory for your products?
  5. How do you prepare DPP data step by step?
  6. What documents and effort should you plan for?
  7. Which mistakes should you avoid before sector-specific rules arrive?
  8. Tools and services to take action
  9. Frequently asked questions
  10. Official sources

Digital Product Passport ESPR: what the regulation provides is a framework for structured digital data linked to a product, batch or model. Regulation (EU) 2024/1781 creates that framework, but detailed obligations will be introduced progressively through product-specific delegated acts, rather than applying one identical passport to every product sold in the EU.

Key takeaways

  • Regulation (EU) 2024/1781 creates the Digital Product Passport framework, but it does not yet impose one uniform DPP on all products sold in the European Union.
  • The required data, level of detail, access rights and application date will depend on the delegated act for the relevant product group.
  • A QR code alone is not a compliant Digital Product Passport; it must provide access to the required information in the prescribed format and under the applicable rules.
  • Manufacturers, importers, distributors and online sellers should organise product traceability data before sector-specific DPP requirements apply.
  • The DPP complements product safety, CE marking, labelling and economic-operator duties; it does not replace them.

What is the Digital Product Passport ESPR: what the regulation provides?

The Digital Product Passport, or DPP, is a structured electronic record that accompanies a product, batch or model under the rules for its category. It is intended to make relevant information usable throughout the value chain, including information needed for durability, repair, reuse, recycling and regulatory checks.

The legal framework is Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products, commonly called the Ecodesign for Sustainable Products Regulation, or ESPR. It progressively replaces the earlier ecodesign approach focused on certain energy-related products with a broader framework that can cover many categories of physical goods.

In practice, the passport is designed to give different users information appropriate to their role. A consumer may need care or repairability information. A repairer may need to identify relevant parts or instructions. A market-surveillance authority may require more detailed technical data. Access rights will therefore not necessarily be the same for every user.

A DPP is not simply a marketing page or a PDF uploaded to a product listing. It relies on structured data, an identifier or data carrier linked to the product, and an architecture intended to support interoperability. The precise arrangements will be set by the sector-specific measures adopted under the ESPR.

Example: a US brand has jackets made in Vietnam, imports stock into an Amazon FBA warehouse in Germany, then sells in France, Spain and Italy. Once DPP requirements for the relevant textile products apply, the brand will need to collect and maintain the required data for the affected references. Adding a QR code that leads to a generic brand page will not be enough if that page does not contain the required regulatory data.

To map the obligations connected with your products, storage countries and trade flows now, use Country Compliance. It helps you organise checks by country, without replacing the sector-specific rules that will be published.

Which products and sellers may be affected by the DPP?

The DPP may apply to physical products placed on the EU market where the delegated act for that product category requires it. The ESPR identifies priority product groups through its working plan, but you must verify each obligation product by product.

Which economic operators are involved?

The manufacturer will usually have the initial responsibility for assembling information about the product's design, materials, manufacture and performance. Where the manufacturer is established outside the EU, the importer placing the product on the EU market must check that applicable requirements are met.

Distributors and marketplace sellers cannot treat the DPP as an issue for the factory alone. They need to identify affected products, preserve references and traceability information, and avoid publishing an incomplete listing once a sector-specific requirement applies. A platform may also request compliance evidence before or after a listing goes live.

Market-surveillance rules already apply to products made available in the Union, including products sold at a distance. Regulation (EU) 2019/1020 on market surveillance and compliance of products sets the framework for authority checks on products covered by EU harmonisation legislation.

Selling from outside the EU is not an exception

A seller based in China, Great Britain, the United States or Switzerland that targets EU customers must follow the rules applicable to the product placed on the European market. The manufacturing location does not change a future DPP requirement; it mainly makes collecting reliable supplier data more critical.

Before you order, centralise the manufacturer's identity, exact references, variants, materials and available documents with Supplier Check. It does not certify a product, but it can reveal inconsistencies to resolve with the factory early.

EU Seller Kit — Start with the EU Market Entry Compliance Assessment if you do not yet know which obligations apply to your product, sales model and storage countries. It includes checks for DPP data readiness.

What information will a Digital Product Passport need to contain?

The exact data is not yet standardised across all product categories. Each ESPR delegated act will specify the information required, its format, the level at which it applies and who may access it.

The ESPR framework allows for information relating to a product's characteristics, materials and components, environmental performance, durability, repairability, reuse, disassembly and end of life. Depending on the product, compliance information and identifiers may also be relevant.

Separate regulatory data, evidence and commercial content

A common mistake is to confuse an environmental claim with verifiable data. Calling an item “sustainable” does not replace information about its composition, expected service life, spare parts or repair instructions where those details are required.

You should also distinguish between:

  • basic data, such as the reference, model, manufacturer and product identifier;
  • technical and environmental data required by the sector-specific rule;
  • internal evidence supporting that data, such as supplier specifications, test reports, bills of materials or declarations;
  • information intended for a product listing, label or consumer.

This separation matters because not every document in your file will necessarily be public. It also reduces the risk of publishing unverified information on a marketplace.

For textile products, the DPP will not replace the existing fibre-identification rules in Regulation (EU) No 1007/2011 on textile fibre names and related labelling. Both sets of requirements may apply together. Read our guide to EU textile labelling requirements to separate information already required from data you should prepare for a future DPP.

The data carrier must remain linked to the correct product

The data carrier may take different forms under the applicable rules, including a machine-readable identifier. This is not a design exercise: it must retrieve the correct record for the correct reference, including where a product has several sizes, colours, compositions or generations.

Imagine a shoe sold under the same commercial name but made with two different soles during the year. If the composition or declared performance changes, one generic passport may be inadequate. Your reference-management system should therefore retain the history of variants and suppliers.

When will the DPP become mandatory for your products?

The ESPR is in force, but whether a passport is mandatory will depend on the adoption and application date of the delegated acts for each product group. There is no single date on which every seller must create a DPP for their entire catalogue.

The European Commission establishes a working plan and then adopts ecodesign requirements by product category. Those measures will set the product scope, data requirements, economic-operator duties, passport arrangements and transition periods. You should therefore monitor the rule for your actual product rather than rely on a general date found on a marketplace or supplier website.

The separate battery passport regime

Batteries follow their own timetable and rules. Regulation (EU) 2023/1542 concerning batteries and waste batteries provides for a passport for certain batteries. It should not automatically be treated as the same thing as a future ESPR DPP for a product containing a battery.

Example: an e-bike seller must consider requirements for the bicycle, its electrical equipment and its battery. One supplier file may not meet every regime. Our guide to the EU battery passport and data to prepare helps you assess that issue separately.

What you can do before the obligation applies

You do not need to invent data fields or choose a final technical format before the sector-specific rules are published. However, waiting until the application date to request information from suppliers often creates an operational problem: references cannot be matched, certificates have expired, materials are undocumented or variants are not distinguished.

Build a data structure for each reference now and review it whenever a supplier, component or production run changes. For imported products, also check customs flows and storage countries using the EU stock import guide for ecommerce sellers, because product traceability should match your real operations.

How do you prepare DPP data step by step?

The safest approach is to build a product data file before selecting a technical solution. You can then adapt that file to the fields and data carrier required by the applicable delegated act.

1. Map your catalogue and roles

List the references sold in the EU, their variants, brands, manufacturers, production countries, storage countries and sales channels. Then identify your role: manufacturer, importer, distributor, distance seller, or more than one of these at once.

This prevents you from treating an entire catalogue as one homogeneous group. A seller may import non-electrical accessories, distribute CE-marked appliances and sell own-brand textiles; the documents and requirements will not be the same.

2. Create a stable identifier for each product and variant

Assign an internal reference that does not change when you update a marketplace photograph or title. Link it to the SKU, GTIN where available, batch number, supplier and product version. Keep a change record: a new material or subcontractor may require a data update.

3. Request data and evidence at source

Prepare a structured supplier request covering material bills, specifications, care instructions, repair information, available declarations, relevant test reports and, where needed, the identity of production sites. Do not copy a value into your catalogue unless you know who can substantiate it.

For CE-marked products, the DPP does not remove the manufacturer's duty to carry out conformity assessment, compile technical documentation or draw up an EU declaration of conformity. The European Commission explains the core principles on Your Europe: CE marking. See our guide to the CE technical file if you need to check evidence before import.

4. Assess gaps and assign an internal owner

For every field, record whether the data is available, its source, the verification date, the person responsible and the remaining action. Data without a source or date is difficult to defend when a platform or authority asks questions.

5. Prepare publication and consistency checks

Once sector-specific rules apply, check that the data carrier points to the correct passport version and that your product listing does not contradict the technical data. Before publishing or changing a listing, the Marketplace Product Compliance Scanner can flag traceability, safety and compliance information to verify.

DPP preparation checklist

  • I have listed products, variants and batches sold in the European Union.
  • I have identified my role for each reference: manufacturer, importer, distributor or distance seller.
  • Each reference has a stable identifier linked to its supplier and production version.
  • I have requested available technical and environmental data from suppliers, together with supporting evidence.
  • I have separated data intended for the public, repairers and market-surveillance authorities.
  • I have checked existing obligations for product safety, CE marking, labelling, EPR, batteries and WEEE where relevant.
  • I have set an update process for changes to materials, components or manufacturers.
  • I have planned to review ESPR delegated acts relevant to my product categories.

What documents and effort should you plan for?

The DPP will primarily require data governance work. The real effort depends on the number of references, variants, suppliers and countries involved, as well as the quality of information you already hold.

For a small brand producing one model with an identified workshop, the work may mainly involve structuring existing documents. For a marketplace seller buying hundreds of references through several intermediaries, the issue is often deeper: no identifiable manufacturer, incomplete technical sheets, untracked batch changes and evidence scattered across emails.

Documents to organise now

Depending on the product, your file may include:

  • specifications and bills of materials or components;
  • model, batch and variant references;
  • available instructions for use, care, repair or disassembly;
  • relevant declarations and technical reports;
  • packaging and end-of-life information;
  • contact details for the relevant economic operators.

The ESPR does not remove packaging obligations. Regulation (EU) 2025/40 on packaging and packaging waste follows its own framework and timetable. If you send packaged goods to several Member States, assess packaging EPR duties separately with our guide to packaging EPR for marketplace sellers.

Do not confuse data preparation with regulatory representation

A software subscription or DPP database does not automatically appoint an EU representative. For consumer products within the GPSR, an EU-established responsible economic operator may be required depending on your circumstances. Regulation (EU) 2023/988 on general product safety sets out this product-safety framework.

If you are a seller not established in the EU and your consumer products need a responsible economic operator, the GPSR Responsible Person service becomes active only after product review, entity assignment, a signed mandate and active payment. It does not replace your DPP data collection.

Which mistakes should you avoid before sector-specific rules arrive?

The main mistake is believing that a QR code, brand page or sustainability claim is enough. The DPP will be a category-specific obligation with defined data and arrangements. Preparing early does not mean improvising compliance.

Publishing unverified information

A supplier may send a commercial sheet that does not distinguish variants or no longer reflects current production. If you reproduce that information in a passport or product listing, you risk displaying inaccurate data. During a check, you should be able to trace it to a reliable source.

Forgetting products already subject to other rules

The DPP does not replace CE marking, safety warnings, labelling rules or distance-selling obligations. For online offers of products within the GPSR, safety and traceability information already needs attention. Read the guide to GPSR labelling requirements for product listings before treating the DPP as your only compliance project.

Treating all variants as one product

One commercial reference can conceal differences in composition, battery, supplier or performance. Those differences can change the data that must be supplied. Keep a variant matrix and record the start and end dates for each version's sale.

Choosing a closed technical solution too early

You can prepare data without deciding on the final carrier today. Interoperability, identifiers, registers and access requirements must be read in the applicable sector-specific texts. A solution that cannot export or update data may be expensive to correct later.

If your listings have already been suspended or a marketplace has requested documents, see our guide to Amazon listing blocked for compliance: causes and solutions. A DPP will not, by itself, resolve missing existing safety or conformity documents.

Tools and services to take action

  • EU Market Entry Compliance Assessment: use this guided assessment before your first shipment or when expanding your catalogue to identify checks to make, including DPP data readiness.
  • Country Compliance: use this tool when you need to organise customs, tax and product checks by origin, storage and destination country.
  • Supplier Check: use it before an order or factory change to centralise identity, payment and delivery information and review inconsistencies.
  • Marketplace Product Compliance Scanner: use it before publishing a listing to identify traceability, safety and compliance information that needs checking.
  • EU Seller Kit pricing and plans: review available tools and services for your needs, without assuming that a subscription creates regulatory representation.

Frequently asked questions

Is the Digital Product Passport already mandatory for every product?

No. The ESPR creates the legal framework for the DPP, but detailed obligations will be introduced progressively through delegated acts for specified product categories. Always check whether a sector-specific measure covers your product and from which date it applies.

Is a QR code enough to comply with the DPP?

No. A QR code may be an access carrier, but it is not itself a compliant passport. It must lead to the data required by the applicable delegated act, at the correct identification level and with the required access arrangements.

Does a marketplace seller have to create the DPP personally?

That depends on the seller's role and the applicable sector-specific rules. The manufacturer will generally provide core data, but importers, distributors and online sellers must avoid placing or offering a non-compliant product on the market. The seller must also keep the passport, product and sales listing consistent.

Does the DPP replace CE marking?

No. CE marking is governed by separate sectoral legislation and may require conformity assessment, technical documentation and an EU declaration of conformity. A DPP may contain or link useful information, but it does not remove the manufacturer's CE obligations.

Does the DPP replace a GPSR Responsible Person?

No. The DPP is an information and traceability system under the ESPR. A GPSR Responsible Person is an EU-established economic operator required in certain situations for consumer products, so the two issues must be assessed separately.

What should I do if my supplier will not provide composition data or documents?

Do not assume you can complete the information later. Request a written response, specifications and available evidence before ordering or replenishing stock. If essential information cannot be verified, assess the commercial and regulatory risk before placing the product on the EU market.

Are the battery passport and the ESPR DPP the same thing?

No. The Batteries Regulation establishes a specific regime for certain batteries, with its own requirements and timetable. A product containing a battery may therefore require a separate assessment of the battery and the main product.

Official sources

This content provides general information and is not legal advice.

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