The Digital Product Passport is a framework tool, not a blanket duty. This page separates what the Ecodesign for Sustainable Products Regulation already says from what depends on product-specific acts the Commission has still to adopt.
Summary
The Digital Product Passport (DPP) comes from Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation, usually called the ESPR. The Regulation entered into force on the twentieth day after its publication in the Official Journal on 28 June 2024, which is 18 July 2024. It is a framework: it creates the legal tools for passports but does not by itself oblige every manufacturer to issue one.
A passport becomes mandatory for a product only when a delegated act adopted under Article 4 covers its product group. Article 9(1) says that products can be placed on the market or put into service only if a digital product passport is available in accordance with the applicable delegated act and with Articles 10 and 11. Where no delegated act exists for your product group, the ESPR creates no passport duty for it.
Delegated acts have to leave businesses time to prepare. Under Article 4(4) the date of application of a delegated act shall not be earlier than 18 months after its entry into force, except in duly justified cases. The same Regulation provides that the first delegated act could not enter into force before 19 July 2025 (Article 4(7)). A deadline for your product therefore cannot be read from the ESPR alone; it has to be read from the act that covers your product group.
Which product groups come first? Article 18(5) required the first working plan, due by 19 April 2025, to prioritise iron and steel, aluminium, textiles (in particular garments and footwear), furniture including mattresses, tyres, detergents, paints, lubricants, chemicals, energy-related products, and ICT and other electronics. Packaging is not on that statutory list. For cement, ecodesign requirements may be set not earlier than 31 December 2028 and not later than 1 January 2030 if the construction products rules lack adequate requirements.
The Commission also had to set up a digital registry that stores at least the unique identifiers of passports by 19 July 2026 (Article 13). We have not verified whether the registry is operational, and nothing on this page depends on it. Treat every date for a product group as provisional until the delegated act is published in the Official Journal.
The terms that decide whether you are affected
The ESPR works through a chain of defined roles and instruments. Knowing which of them applies to you answers most of the question.
- Digital product passport
- A set of product-specific data that includes the information specified in the applicable delegated act adopted under Article 4 and that is accessible through a data carrier. The content, the level of detail and the access rights differ by product group.
- Delegated act (Article 4)
- The instrument that sets ecodesign requirements for a product group, including whether a passport is needed. It must specify the data to be included, the data carrier and its position, whether the passport is at model, batch or item level, pre-purchase access, the actors with read and write rights, and how long the passport must remain available, which shall be at least the expected lifetime of the product.
- Working plan (Article 18)
- The Commission's published list of priority product groups and indicative timelines, covering at least three years and regularly updated. It tells you the order in which delegated acts are prepared, but it is not itself binding on manufacturers.
- Economic operator
- The ESPR addresses the manufacturer, the authorised representative, the importer, the distributor, the dealer and the fulfilment service provider. The DPP duties are distributed among them in the delegated act and in the operator Articles of the Regulation.
- Data carrier
- A linear barcode, a two-dimensional symbol or another medium for automatic capture of identification data that a device can read. The passport is linked to a persistent unique product identifier through the data carrier, which must be physically present on the product, its packaging or accompanying documentation as the delegated act specifies.
What the Regulation itself says about the passport
| Article | Provision | Who | Applies from | Status | Depends on |
|---|---|---|---|---|---|
| 4(4) | A delegated act applies not earlier than 18 months after it enters into force, except in duly justified cases; it must give economic operators sufficient time to comply, taking particular account of SMEs. | European Commission; all operators covered by a delegated act | 18 July 2024 Rule in force since the ESPR entered into force; each delegated act sets its own date of application. | Product-specific delegated acts under Article 4 that create passport obligations. Application not earlier than 18 months after entry into force, except in duly justified cases | |
| 9(1) | Products covered by a delegated act can be placed on the market or put into service only if a digital product passport is available in accordance with that act and Articles 10 and 11. Data must be accurate, complete and up to date. | Economic operators placing covered products on the market | Set by the delegated act for each product group. | Depends on an act not verified as adopted | Product-specific delegated acts under Article 4 that create passport obligations. Application not earlier than 18 months after entry into force, except in duly justified cases |
| 9(2) | The delegated act specifies the data (Annex III), the data carrier, its layout and position, model, batch or item level, access before purchase including distance selling, access rights, who creates and updates data, and the retention period (at least the expected product lifetime). | European Commission (in the act); operators (in compliance) | Set by the delegated act for each product group. | Depends on an act not verified as adopted | Product-specific delegated acts under Article 4 that create passport obligations. Application not earlier than 18 months after entry into force, except in duly justified cases |
| 9(4) | The Commission may exempt a product group from the passport where technical specifications are not available or where other Union law already provides digital information that achieves the same objectives. | European Commission | Decided act by act; no date applies to businesses until a delegated act is adopted. | Depends on an act not verified as adopted | Product-specific delegated acts under Article 4 that create passport obligations. Application not earlier than 18 months after entry into force, except in duly justified cases |
| 13 | The Commission sets up a digital registry that stores at least the unique identifiers (and commodity codes for products under release for free circulation). | European Commission | 19 July 2026 By 19 July 2026. Operational status not verified. | — | |
| 18(3), 18(5) | The Commission adopts and updates a working plan with priority product groups; the first plan was to prioritise the eleven groups listed in Article 18(5). Packaging is not among them. | European Commission | 18 July 2024 First working plan due by 19 April 2025; updated regularly. | — |
How to read this for your own products
Start from the delegated act, not from the ESPR. If no delegated act covers your product group, the ESPR does not oblige you to issue a passport, although other Union law may require product information of its own. If a delegated act exists, it tells you which of the Article 9(2) elements apply and from which date, and the operator Articles tell you who in the chain must do what.
Do not assume that a priority listed in Article 18(5) is an obligation. The list defines what the Commission had to consider first when preparing the working plan; it does not itself apply a passport duty to any product. The first practical question is therefore whether your product falls within a product group for which an act has been adopted, and if not, which group it would belong to.
Plan for the 18-month rule. Because a delegated act cannot apply earlier than 18 months after its entry into force except in duly justified cases, the date of publication of an act is the earliest reliable signal for planning. Until then, preparation can be limited to data you will need in any case, such as unique product identifiers, commodity codes and compliance documentation.
What the text leaves open
The ESPR text does not settle the following, and we offer no view on them.
- Which product groups will in the end be covered, and from which dates, because those are fixed only by delegated acts.
- Whether the registry required by Article 13 is operational and what exactly it contains for your products.
- Which concrete data-carrier format will be required. The Regulation names standards for identifiers but not a single carrier format.
Exemptions
The ESPR allows the Commission to exempt entire product groups from the passport in defined cases. There is no general exemption for small businesses in Article 9; SME support is addressed in Article 22.
- Article 9(4): the Commission may exempt a product group where technical specifications are not available or where other Union law already provides digital information that achieves the same objectives.
Acts that decide your dates
Whether and when a passport applies to your product depends on a product-specific delegated act. We have not verified the adoption status of any of them.
- Product-specific delegated acts under Article 4 that create passport obligations. Application not earlier than 18 months after entry into force, except in duly justified cases (Article 4(4)).
Where to start
This list is a practical suggestion, not wording taken from the Regulation.
- Map your products to the product groups in Article 18(5) and note which are plausible candidates for a delegated act.
- Check the Official Journal and the Commission's pages for adopted delegated acts that cover those groups.
- Inventory the product data you already hold: identifiers, commodity codes, technical documentation and conformity documents.
- Decide who in your organisation would own the passport data if an act were adopted for your group.
- Re-check this page's dates whenever a new delegated act is published.
Frequently asked questions
Is a Digital Product Passport mandatory for all products?
No. It becomes mandatory only for product groups covered by a delegated act under ESPR Art 4, and not earlier than 18 months after that act enters into force.
Does packaging need a Digital Product Passport?
Packaging is not on the ESPR statutory priority list (Art 18(5)). PPWR separately requires labels and, in some cases, QR codes or other digital data carriers on packaging.
Sources
Facts last checked against the Official Journal text on 6 November 2026.
This page is general information, not legal advice. Obligations depend on your role, packaging and Member State. Check the official text on EUR-Lex.