DPPEPRELEU

DPP vs EPREL Product passport versus energy-labelling database

DPP and both connect product information to EU rules, but they are not the same system.

This comparison helps separate the horizontal ESPR product passport from the existing energy-label/product database role of .

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

The Digital Product Passport is a horizontal product-information mechanism under the Ecodesign for Sustainable Products Regulation. is the product database established by Article 12 of Regulation (EU) 2017/1369 for energy-labelled product models. Since 1 January 2019, a supplier must register a new model covered by an energy-labelling delegated act before placing a unit of that model on the Union market. An EPREL model record, energy label, QR code, or registration number does not by itself satisfy an ESPR DPP obligation.

Comparison matrix

DPP vs EPREL: what each system is for

Read the rows as implementation boundaries: DPP governs passport architecture and access under ESPR; remains tied to energy labelling and product-database functions.

Review all sources
First framework
Digital Product Passport

A product passport under ESPR for product-related sustainability, circularity, traceability, compliance, access-rights, and registry use, with details set by product-specific delegated acts.

Second framework
EPREL

The European Product Registry for Energy Labelling, referenced as an existing Union database/tool and as the target of energy-label QR access for relevant energy-labelled products.

Scope boundary

Digital Product Passport

DPP is the ESPR mechanism for making product information available across the value chain. It is expected to improve access to relevant information, end-to-end traceability, and competent-authority work without exposing confidential business information beyond the access rights set for the product group.

EPREL

is the European Product Registry for Energy Labelling. Its public part provides product information, energy labels, and product information sheets; its compliance part contains specified technical documentation and is accessible to market surveillance authorities and the Commission.

Operational implication

Do not call an record a DPP unless the applicable ESPR delegated act and DPP technical requirements are also satisfied.

Product coverage

Digital Product Passport

DPP requirements arise under ESPR delegated acts for product groups. Depending on the product-specific rule, the passport can contain sustainability, circularity, traceability, and compliance information.

EPREL

applies to models covered by energy-labelling delegated acts. The supplier enters the prescribed model information before placing a unit of a new model on the market; the product database does not apply to every product merely because it is energy-related.

Operational implication

Start by asking whether the product is covered by an ESPR delegated act requiring a DPP, whether it is energy-labelled, or both. The overlap is product-specific, not automatic.

Data granularity

Digital Product Passport

DPP data is product-passport data. ESPR says the passport can be specific to the item, batch, or product model, with the level selected in the product-specific delegated act. ETSI describes DPP information as product-specific data conveyed through a unique identifier.

EPREL

is model-and-label oriented: energy labels identify a model and link via QR code to EPREL for additional technical specifications and information. An energy-label model record should not be treated as an item-level lifecycle passport.

Operational implication

Map DPP data at the granularity required by the ESPR delegated act. Reuse model data only where the same attribute, product group, and access need are explicitly supported.

Data access and entry rights

Digital Product Passport

DPP access is role-based. ESPR names customers, manufacturers, importers, distributors, dealers, repairers, recyclers, market surveillance authorities, customs authorities, and others, but access is controlled by the rights set in the delegated act. Rights to introduce, modify, or update data are also restricted.

EPREL

separates public model information from compliance information. Suppliers enter the prescribed data; the public system exposes labels and product information sheets, while market surveillance authorities and the Commission have access to the compliance part.

Operational implication

Build DPP access and update rights from the applicable ESPR delegated act. Build registration and access workflows from the Energy Labelling Regulation and current EPREL operating rules; do not copy one system's permissions into the other.

Identifiers and data carriers

Digital Product Passport

DPP must be linked to a unique product identifier. Where appropriate it can also link to unique operator and facility identifiers. ESPR requires the passport to be connected through a data carrier and requires that carrier to be physically present on the product, its packaging, or accompanying documentation, as specified by the applicable delegated act.

EPREL

Energy-label QR codes provide access to model information. The JRC label material describes QR codes on energy labels as links to EPREL; it does not establish EPREL as the DPP data carrier or passport identifier system.

Operational implication

A physical QR code can be involved in both user experiences, but the encoded target and identifier governance must be checked separately.

Infrastructure and integration

Digital Product Passport

DPP is designed as a decentralised data system set up and managed by economic operators, with a Commission-managed registry storing at least unique identifiers and, for customs release, commodity codes. The Commission also has to provide a public web portal for searching and comparing passport data according to access rights.

EPREL

is an existing Union database/tool that ESPR says the Commission should consider linking to the DPP where feasible. That makes EPREL a possible linked system, not the same as the DPP registry.

Operational implication

Architect integrations as links between systems. Do not collapse the DPP registry, DPP web portal, economic-operator passport data stores, and into one internal data model.

Enforcement

Digital Product Passport

DPP has explicit customs mechanics in ESPR. Once the registry is operational, a person placing a covered product under release for free circulation must provide or make available the unique registration identifier. The automated requirement for customs to check the identifier and commodity code against registry data applies when the EU CSW-CERTEX interconnection is operational.

EPREL

registration does not by itself establish that the ESPR customs identifier handoff has been completed. Keep the DPP Registry identifier and commodity-code evidence separately.

Operational implication

Use the DPP Registry identifier for the ESPR customs handoff and track when the EU CSW-CERTEX interconnection becomes operational.

Overlap and reuse

Digital Product Passport

DPP can potentially reuse existing product information where the delegated act permits it and the data fits the required passport field, granularity, access level, freshness, and identifier mapping.

EPREL

data can supply energy-label and model-level information. Map those fields to the applicable DPP rule and obtain separate inputs for any required circularity, repair, substances, lifecycle, supply-chain, or customs-registry fields.

Operational implication

Reuse data as a mapped input, not as a compliance shortcut. Keep a field-by-field trace showing the source, passport field, access rule, and update owner.

Labels and information access

Digital Product Passport

DPP can sit behind an ESPR label or other product information route. ESPR says labels can include data carriers or other means to access additional information, including the DPP.

EPREL

is tied to the energy label: the JRC material describes energy labels with QR codes linking to EPREL, and ESPR says energy labels remain a successful instrument for energy-related products.

Operational implication

For an energy-related product, decide whether ESPR information can be supplementary information on the energy label, whether a separate ESPR label is needed, and whether DPP access belongs on or near that label.

Practical decision rule

Practical decision rule

  • Check whether an applicable ESPR delegated act requires a DPP for the product and what passport level, fields, and access rights it sets.
  • Check the applicable energy-labelling delegated act and registration requirements for the product model.
  • If both apply, map reusable model data field by field and preserve separate registration and DPP Registry evidence.
Section 1

How to use the comparison

This page is relevant when an energy-labelled product is also being assessed for ESPR/DPP readiness. The comparison is designed to prevent a common architecture mistake: treating , an energy-labelling product database, as though it were the full DPP infrastructure.

ESPR says the Commission should consider linking DPP information requirements to existing Union databases and tools such as where feasible. Plan for linkage rather than substitution. EPREL registration remains a model-level supplier duty with separate public and compliance information, while a DPP must follow the product-specific rules for identifiers, data carriers, access rights, registry upload, availability, security, and passport data.

  • Use fields as candidate inputs only after mapping the exact DPP field, product granularity, access right, and update owner.
  • Keep the energy-label QR journey and the DPP data-carrier journey distinct until the product-specific rules and technical design prove they can converge.
  • Use the Energy Labelling Regulation and current Commission guidance for supplier verification, registration, public fields, compliance fields, and operational deadlines; keep DPP customs claims on the ESPR registry path.
Recommended next step

Map DPP and EPREL data before implementation

Build a field-level matrix for product identifiers, label data, passport fields, access rights, registry fields, and source ownership before merging DPP and EPREL workstreams.

Primary sources

References and citations

eur-lex.europa.eu20 citations
Referenced sections
  • Primary source for DPP scope, access rights, unique identifiers, data carriers, registry, web portal, customs checks, and EPREL linkage language.
  • Primary legal source for DPP requirements, access rights, registry design, and possible linkage to EPREL.
  • Supports DPP as the ESPR tool for value-chain product information, traceability, differentiated access, and competent-authority use.
Show 17 more
  • ESPR says DPP requirements are specified through delegated acts and access rights, so an EPREL record alone should not be treated as passport compliance.
  • Supports item, batch, or product-model granularity for DPP data depending on product-specific rules.
  • DPP granularity and data content depend on the applicable delegated act, so EPREL reuse needs an attribute-level mapping.
  • Lists actors with DPP access and requires access and update rights to follow delegated-act rules.
  • Supports the need to implement DPP access controls rather than assuming energy-label database access rules apply.
  • Supports the DPP link to unique product identifiers and access through a data carrier.
  • Supports keeping DPP identifier and data-carrier rules separate from energy-label QR implementation.
  • Supports the decentralised DPP design, Commission registry, registry contents, and public web portal.
  • Names EPREL as an existing Union database/tool that may be linked where feasible.
  • Supports treating the DPP registry and web portal as distinct ESPR infrastructure rather than EPREL replacements.
  • Supports DPP registry customs checks for unique registration identifier and commodity code.
  • The same ESPR source ties customs mechanics to the DPP registry, not to EPREL in the available source support.
  • Supports treating customs-release checks as DPP-registry obligations when these cited sources are used.
  • Supports linking DPP to existing Union databases where feasible while preserving DPP requirements.
  • DPP fields and access rights are delegated-act dependent, so reuse needs field-level evidence.
  • Supports labels including data carriers or other means to access additional product information and the DPP.
  • Supports the continued parallel role of energy labels for energy-related products.
"link the digital product passport to existing Union databases"
More quoted passages
"European Product Registry for Energy Labelling (EPREL)"
"making information available to actors along the entire value chain"
"as specified in the delegated act"
"specific to the item, batch or product model"
"what data are to or can be included"
"based on their respective access rights"
"rights to introduce, modify or update data"
"linked to a unique product identifier"
"unique identifiers and data carriers"
"based on a decentralised data system"
"publicly accessible web portal"
"customs authorities may release a product"
"data stored in the registry"
"EU Customs Single Window"
"Where feasible"
"access rights at product group level"
"including means allowing access to the digital product passport"
"Energy labels are a successful instrument"
publications.jrc.ec.europa.eu8 citations
Referenced sections
  • Supports the energy-label and EPREL side, including QR-code access to EPREL and the interaction between ESPR labels and energy labels.
  • Grounds the energy-label side of the comparison, including QR-code links to EPREL and interaction between ESPR and energy labels.
  • Explains that products can sit under both ESPR label considerations and the energy-labelling framework.
Show 5 more
  • Supports the energy-label QR link to EPREL and the model identifier context on energy-label layouts.
  • Supports EPREL as the QR-code target on EU energy labels.
  • Supports EPREL as a source of energy-label-linked technical information, not a complete DPP substitute.
  • Supports the energy-label QR connection to EPREL and discussion of ESPR label interaction with energy labels.
  • Supports assessing whether ESPR information should be integrated into an energy label or handled through a separate ESPR label.
"QR code with link to EPREL"
More quoted passages
"QR code that links to the European Product Database"
"covered by both Regulation (EU) 2017/1369"
"MODEL IDENTIFIER"
"additional technical specifications and information"
"European Product Database for Energy Labelling"
"incorporate classes of performance"
eur-lex.europa.eu5 citations
Referenced sections
  • Primary legal source for EPREL supplier registration duties, database structure, access boundaries, and purposes.
  • Primary legal source for supplier model registration and the separate public and compliance parts of the product database.
  • Articles 4 and 12 establish supplier registration duties and the public, compliance, and portal parts and purposes of the product database.
Show 2 more
  • Article 4 limits the model-registration duty to new models covered by an energy-labelling delegated act and requires registration before market placement.
  • Articles 4 and 12 establish supplier data entry and separate the public and compliance parts and their access rules.
doi.org3 citations
Referenced sections
  • Supports DPP architecture concepts: unique product identifier, data carrier, product-centric access, and sustainability/circularity information scope.
  • Defines the DPP scope around product-related data for sustainability, circularity, value retention, recycling, and legal compliance.
  • Defines DPP architecture around a unique product identifier and data carrier.
"structured collection of mandatory, machine-readable"
More quoted passages
"sustainability, circularity, value retention for reuse"
"accessible via electronic means through a Data Carrier"
energy-efficient-products.ec.europa.eu3 citations
Referenced sections
  • Current official operational source for EPREL registration, supplier verification, public model information, and authority access to compliance data.
  • Current Commission explanation of EPREL registration, supplier verification, public information, and authority-only compliance information.
  • Current operational guidance for supplier registration and the public and authority-facing EPREL systems.
cirpassproject.eu2 citations
Referenced sections
  • Supports the limited reuse point: some DPP data requirements may already be fulfilled by existing databases such as EPREL, but this is an integration claim rather than a substitution claim.
  • Supports policy-coherence concerns and reducing duplicate effort when DPP data overlaps with existing databases such as EPREL.
"Some data requirements are already fulfilled"
etsi.org2 citations
Referenced sections
  • Supports the DPP information-model framing as structured product-specific data conveyed through a unique identifier.
  • Defines a digital product passport as structured product-specific data conveyed through a unique identifier.
"structured collection of product-specific data"
etsi.org
Referenced sections
  • Supports EPREL's acronym expansion in the DPP standards landscape.
"European Product Registry for Energy Labelling"
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