EU Digital Product Passport questions answered

Under ESPR, a product covered by a delegated act can be placed on the EU market or put into service only if a Digital Product Passport is available as required by that delegated act. The passport data must be accurate, complete, and up to date.

The delegated act for the product group specifies which actors create the passport, which actors may update which data, whether the passport is at model, batch, or item level, how long it remains available, and how customers can access it before purchase. Manufacturers must ensure the passport is available for covered products; the economic operator placing the product on the market must also provide access support to dealers and online marketplaces and make a back-up copy available through a DPP service provider.

ESPR is framework legislation: concrete DPP duties arrive through product-specific or horizontal delegated acts. The adopted 2025-2030 working plan prioritises new work on textiles and apparel, furniture, tyres, mattresses, iron and steel, aluminium, repairability, and recycled content and recyclability of electrical and electronic equipment. It also carries forward work on specified energy-related products.

The working plan is narrower than the list in ESPR Article 18. Detergents, paints, lubricants, and chemicals were not included as product groups in the adopted plan; footwear is subject to a separate study. A working-plan date is an indicative date for adopting a measure, not the date every product in that group must carry a passport.

ESPR does not make every DPP field public. It requires free and easy access for customers, manufacturers, importers, distributors, dealers, repairers, refurbishers, remanufacturers, recyclers, market surveillance authorities, customs authorities, civil society organisations, trade unions, and other relevant actors based on the access rights set in the applicable delegated act.

The DPP Registry went live on 20 July 2026 and stores the identifiers and metadata required by the applicable legal act. Under ESPR, it stores at least unique identifiers and, for products intended for release for free circulation, the commodity code. The separate automatic customs verification applies only when the EU CSW-CERTEX interconnection is operational.

The DPP must be connected through a data carrier to a persistent unique product identifier. The data carrier must be physically present on the product, packaging, or accompanying documentation as specified by the delegated act, and the data must be open-standard, interoperable, machine-readable where appropriate, structured, searchable, and transferable without vendor lock-in.

ESPR does not hard-code QR or NFC as the universal answer in the main regulation. The product delegated act specifies the data carrier and layout. QR codes are a common candidate for electronic access, while NFC or RFID may be relevant where the selected standard and product rule allow them; the governance control is that identifiers, data carriers, access rights, update rights, back-up copies, security, privacy, and service-provider arrangements remain traceable and documented.

Since 15 July 2026, six cited harmonised standards cover DPP data exchange, unique identifiers, data carriers, storage and persistence, lifecycle APIs, and system interoperability. Conformity with a cited standard gives a presumption of conformity for the ESPR Articles 10 and 11 requirements it covers. It does not decide whether a product needs a DPP or which fields and access rights apply.