Last updated: 26th August 2026
Digital product passports are a requirement under the EU’s Ecodesign for Sustainable Products Regulation (ESPR).
The ESPR provides an ‘ecodesign’ framework, aiming to improve the environmental impact and circularity of products placed on the EU market. Precise design requirements will be detailed in each delegated act (see below), but the general objectives include improving product circularity, durability, reusability and refurbishment, recyclability and environmental impact (including carbon emissions, water efficiency and pollutants) – see Article 5.
The aim of introducing digital product passports is to enable digital traceability for all products present on the EU market, evidencing compliance with ESPR.
The business entity first placing a product onto the EU market is responsible for obligations under ESPR, although they will be reliant upon upstream suppliers to provide compliant products and the required data.
Eventually, all product types will require a DPP. However, specific industries are being prioritised initially – Textiles, Furniture, Tyres, Mattresses, Iron/Steel, Aluminium, Construction products, Batteries, Detergents and Toys (in the guidance below we have excluded product categories that are not relevant).
Delegated Acts
Although the ESPR outlines the overall compliance framework, the EU intends to publish product-specific delegated acts for each priority sector, allowing for variation in requirements between different product types. These delegated acts will provide the detailed obligations applicable to each sector. Specifically for DPPs, they will outline the precise data that must be included – see Article 8.
Below we have outlined the estimated date each delegated act is expected, these are all subject to change. After adopting a delegated act, the EU generally provides a 12-18 month grace period, allowing businesses time to comply.
Estimated Timeline
- Delegated act: late 2027
- Compliance deadline: early-mid 2029
Regulated under the EU’s Toy Safety Regulation, already published
- Compliance deadline: 1st August 2030
- Delegated act: early 2027
- Compliance deadline: late 2028
Includes intermediate materials, not finished products (CN codes to be confirmed in delegated act).
- Delegated act: mid 2028
- Compliance deadline: late 2029
Includes intermediate materials, not finished products (CN codes to be confirmed in delegated act).
DPP General Data Requirements
Based on the information currently available, listed below is the general data that is expected to be required (subject to delegated acts):
- Product Identifiers – model/batch/serial, manufacturer details, importer details, country of origin
- Material Composition – raw materials, recycled content, substances of concern (PFAS and heavy metals)
- Environmental Impact – carbon emissions data, energy and water consumption, environmental footprint
- Durability/Repairability – spare part availability, repair and maintenance instructions, compatibility with upgrades
- Reusability & Recycling – disassembly instructions, recyclability, EOL information, refurbishment
- Compliance Documentation for all relevant policies
EU Electronic Registry
As of July 2026, the EU have launched their electronic DPP registry. This registry acts as an indexing service, holding unique identifiers and key data only.
Detailed product data remains with the relevant business or service provider (under ESPR, at least one back up copy of each DPP must be available via a third-party service provider).
The EU have also provided a testing environment, allowing businesses to trial the process before going live.
Further Guidance
Webinar Recording: Digital Product Passports: What does my business need to do to prepare?
EU Digital Product Passport Guidance
UK Export Support: Ask the export support team a question
DPP Service Providers:
