"What is a digital product passport, when is it mandatory, and which data do we need to collect?" For companies that sell products to the European Union, this question is now an agenda item with dates attached. The European Commission launched the Digital Product Passport (DPP) Registry, together with a testing environment, on 20 July 2026. The first mandatory date is also set: for certain battery types, the passport becomes mandatory on 18 February 2027.
In this article, we look at what the passport is, which product groups it will reach and in what order, and how a company that exports to the EU can start preparing its data infrastructure now.
What is a digital product passport?
The Commission describes the DPP as a digital container that stores information about products, components and materials; its aim is to support sustainability, circularity and regulatory compliance. Depending on the product group, a passport can include information on safety, origin, materials, repairability, environmental performance, reuse and recycling.
The system's legal basis is the Ecodesign for Sustainable Products Regulation (ESPR, 2024/1781). The Regulation requires the data in the passport to be based on open standards and to be interoperable and, where appropriate, machine-readable, structured, searchable and transferable without supplier lock-in.
The architecture is distributed rather than centralized. Product data is held by the economic operator or by a DPP service provider; the operator registers each passport in the Registry, and the system stores the unique identifiers and the related metadata. A data carrier such as a QR code links the product to its passport; once registration is complete, the system generates a unique registration identifier.
Timeline: batteries first, then other product groups
According to the Commission's indicative timeline, the sequence is as follows:
- February 2027 – batteries: Under Article 77 of the Battery Regulation, a passport is mandatory for light means of transport (LMT) batteries, industrial batteries with a capacity above 2 kWh, and electric vehicle batteries. The Commission's page also counts home storage batteries and e-bike and e-scooter batteries as in scope.
- ESPR working plan: passports are envisaged for iron and steel in 2026; energy-related products in 2026–2029; textiles, tires and aluminum in 2027; furniture in 2028; and mattresses and ICT products in 2029.
- Transition period: once a product-group-specific regulation under the ESPR has been adopted, operators are given a transition period of at least 18 months.
For groups such as packaging, toys, construction products and detergents, the passport requirement comes from separate EU legislation. The Commission notes that these dates are indicative and subject to publication requirements; planning should therefore be based on the final regulation for each product group.
What changes for manufacturers outside the EU?
The obligation applies to operators that place a product on the EU market, whether the product was manufactured in the EU or imported. Whether a Turkish manufacturer is directly bound therefore depends on who places the product on the market in the EU. However, because most of the data originates on the production side, an EU buyer or importer will in all likelihood ask its supplier for it.
For batteries in particular, the Q&A document prepared for the Commission clarifies this: the operator that places the battery on the EU market registers the passport; a manufacturer outside the EU can create or update the passport with written authorization, but ultimate legal responsibility is not transferred. When a product with a finished battery built in is imported, responsibility normally lies with the importer.
The customs dimension matters too. For products that will fall within the scope of the ESPR, the framework envisages that the unique registration identifier is presented to customs for release for free circulation, and that customs compares this identifier and the commodity code with the data in the Registry. For batteries, however, the identifier does not have to be entered in the electronic customs declaration; the registration obligation still applies.
What data goes into the passport?
The battery passport is a good example. According to Annex XIII of the Battery Regulation, the publicly accessible part includes the material composition (including chemistry), hazardous substances and critical raw materials, as well as nominal capacity, voltage ranges, expected lifetime, warranty period and the EU declaration of conformity. Detailed composition, spare-parts information and dismantling instructions are accessible only to persons with a legitimate interest and to the Commission, while conformity test reports are accessible only to notified bodies, market surveillance authorities and the Commission.
Not every field has to be filled in by February 2027. Carbon footprint, recycled content and due diligence information are not yet required at that date; the due diligence report is required from August 2027. Starting now to collect supply chain data for these items prevents a last-minute squeeze later on.
The ESPR's general requirements bear directly on data infrastructure as well: the operator placing the product on the market must keep a back-up copy of the passport accessible through a DPP service provider, and the passport must remain accessible for the period set in the relevant regulation even if the operator becomes insolvent or ceases its activity in the EU.
Checklist for preparing your data infrastructure
The steps below are a general framework derived from the sources above; it has to be adapted to each company's product group and business model in the EU.
- Define the scope. Map the products you ship to the EU against the groups in the Commission's timeline. For products that contain a battery, also note the battery's category and capacity.
- Clarify the chain of responsibility. For each product, identify the operator that places it on the market in the EU; settle in the contract whether you or your buyer will create the passport and who will hold the written authorization.
- Build a data inventory. List where, and in what format, you hold material composition, hazardous substances, technical performance, conformity documents and test reports today. Data sitting in scattered spreadsheets is the biggest risk for the passport.
- Put product identity into your systems. Set up identification at model, batch and individual-item level. The Battery Regulation requires specific ISO/IEC 15459 standards for the QR code and the unique identifier.
- Start requesting supplier data today. Carbon footprint, recycled content and raw-material sourcing information will have to come from your suppliers. Tie this request to a standard data form.
- Choose your integration route. Registration can be done through a secure user interface or an application programming interface (API); the Commission also offers machine-readable data models free of charge. Try out in the testing environment how your ERP and product lifecycle systems will connect to this structure.
- Plan hosting and access. Decide whether the data will sit in your own system or with a DPP service provider, and which fields will be opened to whom. When sharing data, also assess the obligations under the EU Data Act alongside these.
- Define who is responsible for updates. The passport requires information to remain accurate throughout the product's lifecycle. Set out in a written process who will update which field, and on which event.
Conclusion
The digital product passport is more a data management issue than a labeling project. The Registry is operational, the date for batteries is set, and the timeline for the other product groups has been announced. For companies that export to the EU, the first step is to see where, and in what quality, product data is held today; when the mandatory date approaches, most of the work will rest on this inventory.
Why logistics experience matters here. A passport is only as reliable as the product identity behind it, and keeping that identity straight is core logistics work: stock identified by model, batch and serial number, recorded at goods receipt and kept accurate through to dispatch. Steps 3 to 5 of the checklist ask for the same habits: know where every piece of data sits instead of leaving it in scattered spreadsheets, give each product one unambiguous identity, and request supplier data on a standard form. The spare-parts information and dismantling instructions that the battery passport restricts to persons with a legitimate interest and the Commission are also the kind of material that technical service and warehouse teams work with every day. One of our consultants brings more than 30 years in operations, logistics and supply chain: at a technology distribution company of roughly one billion dollars in scale, he ran logistics, warehousing, technical service and administrative operations end-to-end, building and leading teams of 100+ people and delivering lasting gains in operational performance through KPI-driven programs. He has also managed nationwide warehouse and transport operations and large-scale distribution networks. An industrial engineer, he now brings that supply-chain discipline to SMEs through AI and automation. Meet our consultants.
This article is for general information purposes only and is not a substitute for legal advice.
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