EU Ecodesign for Sustainable Products Regulation DPP obligations FAQ

No. ESPR sets a horizontal framework. Article 9 says information requirements shall provide that 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 act and Articles 10 and 11.

The operative obligation depends on the product rule. First identify whether an ESPR delegated act covers the product group, then read that act for the required data, carrier, passport level, access rights, update rights, and availability period.

The delegated act is where ESPR turns the passport framework into product-group instructions. Article 9 requires delegated acts to specify the passport data, data carrier, carrier layout and position, whether the passport is at model, batch or item level, customer pre-contract access, stakeholder access rights, who may create or update data, update arrangements, and how long the passport remains available.

Annex III lists candidate data categories, including the unique product identifier, commodity codes, compliance documentation, user manuals or warnings, manufacturer and importer information, operator and facility identifiers, and the DPP service provider hosting the back-up copy. It does not mean every listed element is mandatory for every product.

Article 10 requires the passport to 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 in the applicable delegated act.

Article 11 adds technical design requirements: passports must be interoperable, access must be free of charge and easy based on delegated-act access rights, data and update rights must be controlled, reliability and integrity must be ensured, and the passport must remain available for the specified period, including after insolvency, liquidation, or cessation of activity of the responsible operator.

Articles 12 to 14 cover unique identifiers, the Commission registry, and a public web portal for searching and comparing passport data according to access rights. The Commission launched the registry with a testing environment on 20 July 2026. The current testing phase precedes the first implementation deadline on 18 February 2027 for certain large batteries. The registry and portal do not replace the product-specific delegated act.

Commission Implementing Regulation (EU) 2026/1778 enters into force on 6 August 2026 and sets the DPP registry process. For a product whose applicable Union rule requires both a passport and registry registration, a verified economic operator registers the passport at the model, batch, or item level required by that rule. The registry returns a unique registration identifier and can generate downloadable proof of registration. That proof remains available for 90 calendar days and can be regenerated. Automated registry checks and proof of registration do not establish substantive product compliance.

Map data lineage before fixing a field list. For each likely passport data point, identify the internal owner, supplier source, calculation method, update trigger, evidence location, access classification, and whether the field is required by law, proposed in draft product work, or voluntary.

Supplier evidence should be tied to the data it supports. CIRPASS and CEN-CENELEC materials both highlight practical design issues around supply-chain information exchange, interoperability, access control, traceability, and data availability, but they are not substitutes for the legal delegated act.

Do not state final DPP fields, universal product deadlines, penalties, certification obligations, or mandatory service-provider arrangements unless the claim is based on ESPR, an applicable delegated act, or a later binding act. The Commission consultation material shows that service-provider storage, management, and certification questions are still part of policy development.

For now, the reliable answer is conditional: ESPR defines the DPP framework, core technical and governance requirements, and delegated-act mechanism; product-specific obligations mature through the relevant delegated act and supporting standards or common specifications.