The Digital Product Passport is often treated as a single new labeling requirement. In fact, it arises from the interplay of an EU framework regulation, product-specific legal acts, and sector-specific regulations. It is therefore crucial for company management to understand that not every announced year is already a binding deadline. Nevertheless, companies should begin building reliable product data at an early stage.

What is the Digital Product Passport?

The Digital Product Passport, or DPP for short, is a structured and electronically accessible dataset for a product, component, or material. It is intended to provide information that supports sustainability, circularity, and compliance with legal requirements.

This may include, among other things, the following information:

• Product identity,
• material composition,
• substances of concern,
• critical raw materials,
• repairability and durability,
• recycled content,
• recyclability,
• environmental or CO₂ impacts.

Which details will actually be mandatory depends on the applicable product-specific legal act. A QR code or other machine-readable medium serves merely as the access point. What is crucial is the structured, up-to-date, machine-readable, and reliable data in the background. (Eur-Lex)

DPP Regulations

The ESPR Sets the Framework

The central legal basis is the Ecodesign for Sustainable Products Regulation, or ESPR for short, Regulation (EU) 2024/1781. It entered into force on July 18, 2024, and extends the previous European ecodesign approach to a significantly broader range of physical products. (Eur-Lex)

The ESPR introduces the Digital Product Passport as a central tool. However, it does not automatically prescribe a ready-made product passport with defined data fields and deadlines for every product group.

Specific requirements are generally established through delegated acts. These may specify, among other things:

• which products and economic operators are affected,
• what data must be provided,
• who is authorized to access which information,
• what technical and environmental requirements apply,
• when the requirements must be applied,
• and what transition periods are provided for.

Thus, the ESPR is already in force, while many product-specific DPP requirements are still being developed and finalized. (Eur-Lex)

Which product groups are the initial focus?

The ESPR Work Plan 2025–2030 currently prioritizes the following new product groups in particular:

• Textiles and clothing,
• Furniture,
• Tires,
• Mattresses,
• Iron and steel,
• Aluminum.

Iron and steel, as well as aluminum, are treated as intermediate products. Textiles and clothing, furniture, tires, and mattresses are considered end-product groups.

In addition, the European Commission plans to introduce horizontal requirements regarding:

Repairability, including a potential assessment system,
Recycled content and recyclability of electrical and electronic equipment.

The years listed in the roadmap refer to the targeted dates for the adoption of the respective measures:

• Iron and steel: 2026,
• Textiles and clothing: 2027,
• Tires: 2027,
• Aluminum: 2027,
• Furniture: 2028,
• Mattresses: 2029.

These dates are indicative planning figures. They are neither immediately binding implementation deadlines nor automatic start dates for a Digital Product Passport. Only the respective legal acts will determine which requirements actually apply and when they are to take effect.

Special Case: Battery Passport

Separate sector-specific regulations must be distinguished from the general ESPR work plan. Of particular relevance is the EU Battery Regulation, Regulation (EU) 2023/1542.

Effective February 18, 2027, any of the following batteries placed on the market or put into service must, as a general rule, have a battery passport:

• Electric vehicle batteries,
• batteries for light-duty vehicles,
• industrial batteries with a capacity exceeding 2 kWh.

This deadline is set by law and is not merely a non-binding planning target. The battery passport is thus one of the first concrete examples of a mandatory digital product passport. (Eur-Lex)

What Do the DPP Deadlines Mean for Companies?

There is no one-size-fits-all DPP deadline for all products and companies. For practical purposes, companies can distinguish between three regulatory statuses:

Binding

A valid legal act specifies the affected product group, the specific requirements, and a binding effective date. An example is the Battery Passport, effective February 18, 2027.

Planned

A work plan or announcement by the European Commission specifies a timeframe for the preparation or adoption of a legal act. This does not yet result in an immediately applicable product passport requirement.

Open

Data fields, technical requirements, access rights, documentation requirements, or transition periods have not yet been definitively established for a product group.

This classification serves as a practical guide for companies and is not an official legal categorization by the European Union.

Nevertheless, this does not mean that management should adopt a wait-and-see approach. Obtaining supplier data, developing suitable data models, adapting system architecture, and defining internal responsibilities often require significantly more time than the subsequent technical implementation of a product passport.

A DPP readiness check should specifically address the following questions:

• Which product groups already have fixed or foreseeable deadlines?
• Which products may fall under multiple regulatory frameworks?
• Where is reliable and verifiable supply chain data missing?
• Which system maintains the relevant product data?
• Is there a defined “single source of truth”?
• Who is responsible for data quality, approval, and updates?
• Can information across the entire product lifecycle be kept up to date?
• Are the data model, interfaces, and processes scalable for additional product groups?
• Can different access rights for customers, business partners, and regulatory authorities be implemented?

asioso can take a holistic view of regulatory strategy, product data management, data architecture, and system integration without prejudging any outstanding detailed requirements.

The fundamentals of DPP begin with a clear regulatory classification: The ESPR provides the European framework, delegated acts establish product-specific obligations, and sector-specific regulations may set their own requirements and deadlines.

Companies should therefore neither rely on supposedly standardized DPP deadlines nor rush to implement an isolated, one-off solution. The most sensible first step is to conduct a prioritized assessment of their product portfolio, data, suppliers, responsibilities, and systems.

FAQ on the Digital Product Passport

1. When does the Digital Product Passport become mandatory?

There is no uniform deadline for all products. The effective date depends on the specific product group and legal basis. For electric vehicle batteries, batteries for light-duty vehicles, and industrial batteries with a capacity of more than 2 kWh, the Battery Passport generally applies as of February 18, 2027. (Eur-Lex)

2. Is the ESPR already in effect?

Yes. Regulation (EU) 2024/1781 entered into force on July 18, 2024. However, specific Digital Product Passport (DPP) requirements for many product groups will only be established through further product-specific legal acts. (Eur-Lex)

3. Is a QR code sufficient for a DPP?

No. A QR code can serve as a machine-readable data carrier and provide access to the Digital Product Passport. Additionally, structured, accurate, up-to-date, machine-readable, and long-term available product data are required. Depending on the specific legal act, other machine-readable data carriers may also be specified. (Eur-Lex)

4. Do companies have to implement a complete DPP platform immediately?

No. As long as the specific requirements for a product group have not yet been finalized, there is a risk of premature or overly rigid implementation. It makes more sense to first conduct a portfolio analysis, take an inventory of data, clarify supplier data, and establish a scalable data architecture.

5. Should industries that have not yet been prioritized also begin implementation?

Yes, but on a risk-based approach. Companies should first assess which product groups and regulatory frameworks might become relevant. Based on this assessment, data gaps, responsibilities, and technical requirements can be addressed step by step.

Bibliography

European Parliament and Council: Regulation (EU) 2024/1781 of June 13, 2024, establishing a framework for setting ecodesign requirements for sustainable products, Official Journal of the European Union, EUR-Lex, accessed on July 29, 2026. (EUR-Lex)
European Commission: Ecodesign for Sustainable Products Regulation, continuously updated information page, accessed on July 29, 2026. (European Commission)
European Commission: Ecodesign for Sustainable Products and Energy Labeling Working Plan 2025–2030, COM(2025) 187 final, April 16, 2025, accessed on July 29, 2026.
European Parliament and Council: Regulation (EU) 2023/1542 of July 12, 2023 on batteries and waste batteries, EUR-Lex, accessed on July 29, 2026. (EUR-Lex)
EUR-Lex: Ecodesign Requirements for Sustainable Products – Summary, accessed on July 29, 2026. (EUR-Lex)