As a retailer, do I have to create a product passport myself if I only sell goods from registered suppliers?

It depends on the product group and the role. The main responsibility lies with the economic operators that place the product on the EU market; depending on the act, distributors, dealers in the narrower sense and fulfilment service providers may also be covered. If you only resell, check the obligations for your role in the relevant act and document the status of your suppliers.

What applies to my product group if the delegated act has not yet been adopted?

Then there is no obligation yet. Once the delegated act is adopted, a transition period of at least 18 months applies. Businesses with products in the planned groups, such as textiles or furniture, can use the time to build up their data foundation.

Does the product passport also have to be provided when selling via Amazon and other marketplaces?

Yes, in distance sales, online marketplaces must make the product passports accessible. This does not release the economic operator from its own obligation: it creates the passport, registers it in the DPP registry and keeps the data up to date.

Where is the product passport data stored?

Not centrally in Brussels. The DPP registry stores only the unique identifier and registration data; the full product data stay with the economic operator or a DPP service provider. A data carrier such as a QR code on the product links to the passport.

Does the digital product passport also apply to packaging?

The Packaging and Packaging Waste Regulation (PPWR) is one of the separate laws through which product passport requirements can be defined. Whether and when a passport for packaging actually becomes mandatory will only be settled by the respective acts. Packaging registration and system participation continue unaffected.

Do I need to pay attention to anything special as an importer from a non-EU country?

Imported products whose product group is already subject to a digital product passport obligation also need a corresponding product passport before they are placed on the EU market. The identifier can be checked in customs procedures; registration can be relevant for customs clearance and release for free circulation.

Digital product passport: deadlines and preparation

What is the digital product passport?

The digital product passport (DPP) is a digital record that describes a product, its components and its materials. It makes information on safety, origin, materials, reparability and environmental performance accessible in a standardised way. The European Commission describes it as a digital container for product data that gives businesses, consumers, repairers, recyclers and authorities reliable product information.^[1]

The legal basis is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. It has been in force since 18 July 2024.^[2] It replaces the Ecodesign Directive 2009/125/EC and extends the scope from energy-related products to almost all physical goods on the EU market. Exemptions apply to only a few areas, such as food, feed and medicinal products.^[3]

The ESPR itself does not define what a passport contains. It only sets the framework. The requirements become concrete in two ways: through product-specific delegated acts under the ESPR or through separate EU laws. These separate laws include the Batteries Regulation (EU) 2023/1542 and the Packaging Regulation PPWR.^[1]

Safety and origin of the product
Materials and components used
Reparability, reuse and recycling
Environmental performance across the life cycle

Which of these details become mandatory in a given case is decided by the act for the respective product group. The passport is therefore not a single document for all goods, but a format that is filled with specific requirements one product group at a time.^[1]

Which digital product passport requirements apply to your range depends on the product group and the act that governs it. These DPP requirements need to be checked separately. The ClearoSystems Digital needs analysis focuses on your company's EPR obligations and shows which registration, reporting, system participation or authorised representative obligations arise from your products, roles, sales channels and target countries.

How do the registry, identifier and QR code fit together?

The DPP registry is the EU database that underpins the product passport system. It has been operating since 20 July 2026. It stores each product's unique product identifier and the registration data required by the applicable act. The full product data themselves stay with the economic operator or with a service provider it has commissioned.^[1]

Capture product data: the economic operator provides the product data digitally, following the structure and specifications of the applicable act.
Register the passport: the passport is registered in the DPP registry with the technical details required there.
Attach the data carrier: a physical data carrier, such as a QR code, is placed on the product, its packaging or the accompanying documentation.
Maintain the data: the passport information stays accurate throughout the product's life cycle.

The data carrier is the bridge between the physical product and the digital passport. Scanning the QR code leads to the passport via the unique identifier. Which user role may see which data differs by product group and act.^[4]

For imported products, registration can also be relevant in customs procedures, for example at clearance and release for free circulation. This also makes the product passport a control instrument at the EU's external border.^[4]

When does each product group need a product passport?

So far, only one date is fixed. From 18 February 2027, electric vehicle batteries, batteries for light means of transport and industrial batteries with a capacity above 2 kWh need a battery passport. The legal basis is the Batteries Regulation (EU) 2023/1542.^[1]

Product group	Legal act	Date	Status
Certain batteries (electric vehicles, light means of transport, industrial above 2 kWh)	Batteries Regulation (EU) 2023/1542	18 February 2027	binding^[1]
Iron and steel	Delegated act under the ESPR	2026	indicative^[1]
Energy-related products	Delegated acts under the ESPR	2026 to 2029	indicative^[1]
Textiles, tyres, aluminium	Delegated acts under the ESPR	2027	indicative^[1]
Furniture	Delegated act under the ESPR	2028	indicative^[1]
Mattresses, ICT products	Delegated acts under the ESPR	2029	indicative^[1]

Indicative means that the dates for all groups except batteries depend on when the respective delegated acts are published. The Commission explicitly labels this timeline as provisional.^[1] Once a delegated act is adopted, a transition period of at least 18 months also applies before the obligation takes effect.^[4]

Who has to create and provide the product passport?

Which role must create, register and maintain the digital product passport is set by the relevant product-specific act. Central responsibility usually lies with the economic operator that places the product concerned on the market or puts it into service. Dealers, distributors, online marketplaces and other actors may also have their own verification, information or provision obligations.^[4]

Manufacturers
Importers
Authorised representatives
Dealers and distributors
Fulfilment service providers

Four tasks recur across the product-specific acts: providing product data digitally, attaching a physical data carrier to the product, its packaging or the accompanying documentation, registering the passport in the DPP registry and keeping the data up to date throughout the life cycle. For products for which an applicable act already requires a digital product passport, the passport must be available and registered accordingly before the product is placed on the market or put into service.^[4]

Distance sales add one more task: online marketplaces must make the product passports accessible when products are sold into the EU at a distance.^[4] For retailers who sell through online marketplaces, this means the passport also becomes an issue where EPR evidence is already requested today.

Until an act for your own product group has been adopted, it remains unclear exactly which data will be required. The transition period only starts with that adoption, not with the general date of application of the ESPR.^[4]

What should businesses prepare now?

The timeline points to three steps you can take now, without having to wait for pending acts.

Classify your product group: so far, a fixed obligation exists only for certain batteries, from 18 February 2027. All other groups follow the indicative timeline. Check where your products sit in the working plan and keep track of the announced delegated acts.
Build your data foundation: origin, materials, reparability and environmental performance are often spread across development, purchasing and logistics today. Collecting this data early reduces the effort when the act for your own group arrives.
Plan for the transition period: the period of at least 18 months starts with the adoption of the relevant act. Build this mechanism into your internal planning, not just a single date.

The details of the battery passport, such as which data the Batteries Regulation specifically requires, are covered in a separate article.

The digital product passport complements existing EPR obligations but does not replace them. For packaging, electrical equipment and batteries, registration, reporting, system participation and authorised representative obligations can apply independently of it. The ClearoSystems Digital needs analysis gives you a complete overview of these EPR obligations by product, role, sales channel and target country. Digital product passport requirements must be checked separately from this.

Frequently asked questions

When does the digital product passport become mandatory?: That depends on the product group. So far, only batteries have a fixed date: from 18 February 2027, electric vehicle batteries, batteries for light means of transport and industrial batteries with a capacity above 2 kWh need a battery passport. All other groups follow an indicative timeline that depends on the adoption of the respective delegated acts.
As a retailer, do I have to create a product passport myself if I only sell goods from registered suppliers?: It depends on the product group and the role. The main responsibility lies with the economic operators that place the product on the EU market; depending on the act, distributors, dealers in the narrower sense and fulfilment service providers may also be covered. If you only resell, check the obligations for your role in the relevant act and document the status of your suppliers.
What applies to my product group if the delegated act has not yet been adopted?: Then there is no obligation yet. Once the delegated act is adopted, a transition period of at least 18 months applies. Businesses with products in the planned groups, such as textiles or furniture, can use the time to build up their data foundation.
Does the product passport also have to be provided when selling via Amazon and other marketplaces?: Yes, in distance sales, online marketplaces must make the product passports accessible. This does not release the economic operator from its own obligation: it creates the passport, registers it in the DPP registry and keeps the data up to date.
Where is the product passport data stored?: Not centrally in Brussels. The DPP registry stores only the unique identifier and registration data; the full product data stay with the economic operator or a DPP service provider. A data carrier such as a QR code on the product links to the passport.
Does the digital product passport also apply to packaging?: The Packaging and Packaging Waste Regulation (PPWR) is one of the separate laws through which product passport requirements can be defined. Whether and when a passport for packaging actually becomes mandatory will only be settled by the respective acts. Packaging registration and system participation continue unaffected.
Do I need to pay attention to anything special as an importer from a non-EU country?: Imported products whose product group is already subject to a digital product passport obligation also need a corresponding product passport before they are placed on the EU market. The identifier can be checked in customs procedures; registration can be relevant for customs clearance and release for free circulation.