---
title: "Which products come first for the EU Digital Product Passport?"
canonical_url: "https://www.sorena.io/artifacts/eu/digital-product-passport/faq/which-products-come-first"
source_url: "https://www.sorena.io/artifacts/eu/digital-product-passport/faq/which-products-come-first"
author: "Sorena AI"
description: "FAQ on EU Digital Product Passport product priority: batteries have a separate passport rule, while ESPR product groups depend on the working plan and delegated acts."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EU Digital Product Passport"
  - "ESPR product priority"
  - "battery passport"
  - "delegated acts"
  - "Digital Product Passport"
  - "ESPR"
  - "Batteries Regulation"
  - "Working plan"
---
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---

# Which products come first for the EU Digital Product Passport?

FAQ on EU Digital Product Passport product priority: batteries have a separate passport rule, while ESPR product groups depend on the working plan and delegated acts.

*FAQ* *DPP* *EU*

## Which Products Come First EU Digital Product Passport priority

Batteries are the first separately grounded passport obligation. For ESPR products, priority in the working plan is not the same as a live passport duty.

Use the ESPR working-plan list to watch product groups, then wait for the applicable delegated act to confirm DPP data, carrier, access, and timing requirements.

The short answer is: covered batteries come first under the separate EU Batteries Regulation, while ESPR product groups come through a working-plan and delegated-act process. A product group appearing on the ESPR priority list is an early warning for preparation, not by itself a finished Digital Product Passport go-live rule.

## Which products come first for the EU Digital Product Passport?

For binding passport planning, separate the battery passport from the ESPR Digital Product Passport. The Batteries Regulation says that from 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service must have an electronic battery passport.

For ESPR product groups, there is no single universal DPP start date in the grounded sources for this page. ESPR creates the framework, requires the Commission to prioritise product groups in a working plan, and makes product-specific passport obligations depend on delegated acts adopted for the product group.

- Treat covered batteries as a separate first-passport workstream under Regulation (EU) 2023/1542.
- Treat ESPR priority product groups as a watchlist for upcoming ecodesign and DPP requirements, not as automatic passport obligations.
- Do not publish a product-group DPP launch date unless the applicable delegated act or official working-plan material supports it.

Sources for this answer:

- [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Supports the separate battery passport obligation, the covered battery categories, and the 18 February 2027 date.
- [Regulation (EU) 2024/1781 establishing ESPR](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Supports that ESPR DPP requirements are tied to product-specific delegated acts rather than a single across-the-board passport date.

## Which ESPR product groups are priority candidates?

ESPR Article 18 sets the first working-plan priority list. The listed groups are iron and steel; aluminium; textiles, especially garments and footwear; furniture, including mattresses; tyres; detergents; paints; lubricants; chemicals; relevant energy-related products; and information and communication technology products and other electronics.

That list is useful for sequencing preparation because it tells product, sustainability, supply-chain, and data teams where to watch first. It does not answer the operational DPP questions by itself: what data must be in the passport, where the carrier sits, who gets which access rights, what conformity route applies, and when the product-specific requirements apply.

- Start inventory work for products that fall into the Article 18 priority groups.
- Keep batteries in a separate regulatory tracker because their passport rule is in the Batteries Regulation.
- For each ESPR product group, link the watch item to the future delegated act rather than copying a generic DPP deadline across all products.

Sources for this answer:

- [Regulation (EU) 2024/1781 establishing ESPR](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Supports the Article 18 first working-plan product groups and the point that working-plan priority is a planning step.
- [European Commission ESPR overview](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Supports the Commission framing of ESPR as the product-sustainability framework behind future product-specific measures.

## Why does the delegated act matter?

Under ESPR, the delegated act is where the general framework becomes product-specific. ESPR Article 9 says 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 acts, and Article 9 also says those acts specify which data must be included, the data carriers to be used, and how the carrier is presented and positioned.

That is why a company should avoid treating a priority category, a consultation, or a technical standard as the final compliance rule. They can justify early architecture work, but the delegated act is the source to check before locking product labels, QR placement, access tiers, registry fields, or contractual supplier data duties.

- Create one tracking row per product group and delegated act, not one generic DPP row for every SKU.
- Record the affected product models, market role, passport data owner, carrier decision owner, and supplier-data dependencies.
- Update the row when the delegated act defines the product scope, data elements, carrier layout, access rights, conformity assessment route, and application timing.

Sources for this answer:

- [Regulation (EU) 2024/1781 establishing ESPR](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Supports that ESPR passport availability, data content, carriers, layout, and positioning are specified through applicable delegated acts.

## What should teams do now?

For batteries, build against the grounded Batteries Regulation passport scope if the business places covered LMT, industrial greater-than-2 kWh, or electric vehicle batteries on the EU market or puts them into service. That work should include the battery category decision, the responsible economic operator, QR-code access, and the information set in Annex XIII.

For ESPR products, prepare the parts that are unlikely to be wasted: product-group mapping, supplier data ownership, identifier strategy, data-quality controls, and change monitoring. Hold back from asserting final product-group passport dates, mandatory fields, or carrier layout until the delegated act for that group exists and has been reviewed.

- Segment the portfolio into battery-passport products, ESPR Article 18 priority groups, and products not yet matched to a grounded DPP priority source.
- Assign a regulatory owner for delegated-act monitoring and a data owner for each product family likely to need passport data.
- For public pages, customer notices, supplier questionnaires, and internal roadmaps, label unfinalised ESPR product-group timing as dependent on the delegated act.

Sources for this answer:

- [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Supports the battery categories, QR-code link to the battery passport, responsibility for passport information, and Annex XIII information structure.
- [Regulation (EU) 2024/1781 establishing ESPR](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Supports the need to wait for product-specific delegated acts before treating ESPR DPP details as binding for a product group.

## Primary sources

- [Regulation (EU) 2024/1781 establishing ESPR](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Primary ESPR source for working-plan prioritisation, the delegated-act mechanism, and DPP requirements that are specified per product group.
  - Quote: "prioritise the following product groups"
- [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Primary source for the separate battery passport obligation covering LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries.
  - Quote: "shall have an electronic record"
- [European Commission ESPR overview](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview source for ESPR as the framework for sustainable-product requirements and Digital Product Passport implementation.
  - Quote: "Ecodesign for Sustainable Products Regulation"

## Topic Guides

- [Annex III Data Model Planning for EU Digital Product Passports](/artifacts/eu/digital-product-passport/annex-iii-data-model-planning.md): Plan EU Digital Product Passport data fields, identifiers, access rights, update owners, registry inputs, and evidence records against ESPR Annex III and product-specific delegated acts.
- [Digital Product Passport vs Digital Twin](/artifacts/eu/digital-product-passport/dpp-vs-digital-twin.md): Compare EU Digital Product Passports with digital twins: legal access duties, identifiers, public and restricted data, evidence, governance, and reuse limits.
- [Digital Product Passport vs Paper Product Passports](/artifacts/eu/digital-product-passport/dpp-vs-traditional-product-passports.md): Compare EU regulated digital product passports with paper, PDF, web, and internal product passports across access, identifiers, data carriers, restricted data, customs checks, registry, and interoperability.
- [DPP customs access review workflow for ESPR products](/artifacts/eu/digital-product-passport/customs-access-review-workflow.md): Review public, restricted, and customs access for EU Digital Product Passports, including registry handoffs, portal access rights, and release-for-free-circulation evidence.
- [DPP Data Governance RACI Template for EU Digital Product Passports](/artifacts/eu/digital-product-passport/dpp-data-governance-raci-template.md): Assign accountable owners for EU Digital Product Passport data, access rights, supplier inputs, resolver links, registry uploads, verification checks, and retained evidence.
- [DPP data-model intake workflow for EU Digital Product Passports](/artifacts/eu/digital-product-passport/dpp-data-model-intake-workflow.md): A grounded intake workflow for EU Digital Product Passport data models: product group, delegated-act status, source owner, supplier data, access class, identifiers, carrier, checks, and publication readiness.
- [DPP Governance, Verification and Audit Controls](/artifacts/eu/digital-product-passport/governance-verification-and-audit.md): Build EU Digital Product Passport governance controls for data owners, supplier evidence, access logs, validation checks, audit records, and product release gates.
- [DPP QR code vs NFC data carrier choices under EU ESPR](/artifacts/eu/digital-product-passport/faq/qr-code-vs-nfc-carrier-choices.md): How to choose QR code, NFC, or another data carrier for an EU Digital Product Passport without assuming ESPR mandates one universal carrier.
- [DPP registry and web portal integration under EU ESPR](/artifacts/eu/digital-product-passport/dpp-registry-and-web-portal-integration.md): Grounded guide to EU Digital Product Passport registry and web portal integration under ESPR, covering identifiers, data carriers, access rights, service providers, and lookup design.
- [DPP vs Battery Passport: ESPR and Battery Regulation Comparison](/artifacts/eu/digital-product-passport/dpp-vs-battery-passport.md): Compare the ESPR Digital Product Passport framework with the EU Batteries Regulation battery passport by scope, timing, data, access rights, identifiers, registry, governance, and evidence.
- [DPP vs EPREL Comparison](/artifacts/eu/digital-product-passport/dpp-vs-eprel.md): Compare the EU Digital Product Passport with EPREL: product-passport scope, energy-label database role, access model, identifiers, data carriers, and overlap limits.
- [DPP vs GS1 Digital Link: Duties vs Standard](/artifacts/eu/digital-product-passport/dpp-vs-gs1-digital-link.md): Compare EU Digital Product Passport requirements with GS1 Digital Link: legal scope, identifiers, data carriers, access rights, registry, portal, customs checks, and implementation consequences.
- [EU Digital Product Passport access: public, restricted, and customs views](/artifacts/eu/digital-product-passport/public-restricted-and-customs-access.md): How ESPR Digital Product Passport access should be split across public users, restricted actors, authorities, customs, the EU registry, and the web portal.
- [EU Digital Product Passport API and resolver architecture](/artifacts/eu/digital-product-passport/api-and-resolver-architecture.md): Grounded DPP architecture guidance for data carriers, product identifiers, resolver lookup paths, access rights, registry integration, and interoperability without premature protocol mandates.
- [EU Digital Product Passport Applicability Test](/artifacts/eu/digital-product-passport/applicability-test.md): Check whether an ESPR delegated act or battery passport rule may require a Digital Product Passport, which operator owns it, and what evidence to keep.
- [EU Digital Product Passport architecture and integration](/artifacts/eu/digital-product-passport/architecture-and-integration.md): Grounded guide to EU Digital Product Passport architecture: data carriers, identifiers, access rights, registry, portal, supplier flows, customs checks, and governance.
- [EU Digital Product Passport checklist](/artifacts/eu/digital-product-passport/checklist.md): A concrete EU Digital Product Passport readiness checklist covering product-group scope, passport fields, identifiers, data carriers, access rights, supplier evidence, registry preparation, and publication controls.
- [EU Digital Product Passport compliance: ESPR requirements](/artifacts/eu/digital-product-passport/compliance.md): Grounded EU Digital Product Passport compliance guide covering ESPR passport data, identifiers, data carriers, access rights, registry readiness, supplier validation, and evidence.
- [EU Digital Product Passport Data Carriers, Access Control, and UX](/artifacts/eu/digital-product-passport/data-carriers-access-control-and-ux.md): How to choose DPP data carriers, identifiers, access rights, and scanning UX under ESPR Articles 9-14, with QR, NFC, RFID, registry, and customs constraints.
- [EU Digital Product Passport data requirements and fields](/artifacts/eu/digital-product-passport/data-requirements-and-fields.md): How to plan Digital Product Passport data fields under ESPR: delegated-act scope, Annex III data categories, access rights, customs data, and supplier validation.
- [EU Digital Product Passport deadlines and compliance calendar](/artifacts/eu/digital-product-passport/deadlines-and-compliance-calendar.md): Grounded EU Digital Product Passport calendar for ESPR and battery passport milestones, with product-group dates flagged as dependent on delegated acts.
- [EU Digital Product Passport FAQ](/artifacts/eu/digital-product-passport/faq.md): Direct answers on EU Digital Product Passport scope, creators, product groups, registry, customs checks, access rights, identifiers, data carriers, and governance.
- [EU Digital Product Passport identifier and data carrier design](/artifacts/eu/digital-product-passport/unique-identifier-and-data-carrier-design.md): How to design Digital Product Passport identifiers, QR or other data carriers, resolver links, registry records, access paths, and evidence without overclaiming the EU rules.
- [EU Digital Product Passport penalties and enforcement](/artifacts/eu/digital-product-passport/penalties-and-fines.md): What ESPR says about Digital Product Passport penalties, Member State fine rules, market surveillance, customs checks, and unresolved product-specific delegated acts.
- [EU Digital Product Passport Product Group Readiness](/artifacts/eu/digital-product-passport/product-group-readiness.md): Prepare product groups for EU Digital Product Passport rules by tracking ESPR delegated-act status, data fields, suppliers, identifiers, access rights, and registry handoffs.
- [EU Digital Product Passport requirements under ESPR](/artifacts/eu/digital-product-passport/requirements.md): source-linked overview of EU Digital Product Passport requirements under ESPR: product-specific delegated acts, data fields, identifiers, carriers, registry, access rights, supplier data validation, and open points.
- [EU Digital Product Passport supplier data validation controls](/artifacts/eu/digital-product-passport/supplier-data-validation.md): Build a supplier data validation file for EU Digital Product Passports: source owner, product link, access class, data model fit, evidence quality, approval record, and release gate.
- [EU DPP customs access: registry, portal, and restricted data](/artifacts/eu/digital-product-passport/faq/customs-access.md): FAQ on customs access under the EU Digital Product Passport: what customs can verify, how the registry and public portal differ, and how access rights limit DPP data.
- [EU DPP implementation playbook and vendor selection](/artifacts/eu/digital-product-passport/implementation-playbook-and-vendor-selection.md): Select Digital Product Passport vendors against ESPR requirements for identifiers, data carriers, access rights, decentralized storage, registry readiness, portal access, and verification evidence.
- [EU DPP Product-Group Readiness Checklist](/artifacts/eu/digital-product-passport/product-group-readiness-checklist.md): A source-grounded checklist for preparing a product group for an EU Digital Product Passport delegated act, covering data fields, suppliers, identifiers, carriers, access rights, and registry readiness.
- [EU DPP QR Code and Data Carrier Implementation Guide](/artifacts/eu/digital-product-passport/dpp-qr-code-implementation-guide.md): Grounded guidance for using QR codes and other data carriers in EU Digital Product Passport programs, including unique identifiers, access, resolver testing, and evidence.
- [EU DPP supplier data validation workflow](/artifacts/eu/digital-product-passport/supplier-data-validation-workflow.md): A grounded workflow for checking supplier data before it is used in an EU Digital Product Passport, covering product linkage, evidence, owners, access class, and approval records.
- [EU DPP unique identifier requirements: product, operator and facility IDs](/artifacts/eu/digital-product-passport/faq/unique-identifier-requirements.md): FAQ on how ESPR Digital Product Passport identifiers connect products, economic operators, facilities, data carriers, resolvers and registry evidence.
- [Public vs restricted EU Digital Product Passport data](/artifacts/eu/digital-product-passport/faq/public-vs-restricted-passport-data.md): How to separate public, restricted, authority, and customs access in EU Digital Product Passport designs under ESPR and battery passport rules.
- [What is a Digital Product Passport under ESPR?](/artifacts/eu/digital-product-passport/what-is-a-dpp.md): A visitor-friendly explanation of EU Digital Product Passports under ESPR: product data, identifiers, data carriers, access rights, registry, web portal, and delegated acts.
- [What is the EU Digital Product Passport registry?](/artifacts/eu/digital-product-passport/faq/dpp-registry.md): FAQ on the ESPR Digital Product Passport registry: what it stores, who uploads data, how identifiers work, and what teams should avoid assuming.
- [Who must create an EU Digital Product Passport?](/artifacts/eu/digital-product-passport/faq/who-must-create-a-digital-product-passport.md): DPP responsibility under the EU ESPR: how manufacturers, importers, distributors, suppliers, service providers, and delegated acts fit together.

*Recommended next step*

*Placement: after delegated-act section*

## Separate battery passport work from ESPR product-group monitoring

Use this DPP FAQ to split covered batteries from ESPR priority groups, then track delegated acts before committing to product-group passport dates or mandatory data fields.

- [Open Research Copilot](/solutions/research-copilot.md): Check DPP product-group claims against official EU source material.
- [Discuss DPP readiness](/contact.md): Review battery passport scope, ESPR product priorities, and delegated-act monitoring with Sorena.


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