The EU Digital Product Passport Registry is live. What must companies put in it?
The QR code is the easy part..
The European Union has opened the infrastructure designed to give physical products a digital history.
Since 20 July 2026, companies have been able to enrol in the EU Digital Product Passport Registry and register passports through either a secure user interface or an application programming interface. The system will eventually support products ranging from electric vehicle batteries and industrial materials to clothing, furniture and electronics.
It sounds deceptively simple. Attach a QR code or another data carrier to a product and allow customers, repairers, recyclers and regulators to retrieve information about it.
The difficult part sits behind that code. Companies must collect reliable data from suppliers, keep it current throughout the product’s life and control who can see it. For complex products containing thousands of components from several tiers of suppliers, Digital Product Passport compliance may require a major overhaul of product data management.
The registry going live does not mean every product sold in Europe suddenly needs a passport. Product-specific obligations will be introduced gradually. The first firm deadline, covering certain batteries, arrives on 18 February 2027.
What is an EU Digital Product Passport?
A Digital Product Passport, or DPP, is a structured digital record containing information about a product’s identity, materials, origin, environmental performance, repair and eventual recycling.
It is one of the central instruments of the EU’s Ecodesign for Sustainable Products Regulation, or ESPR. The system is intended to make product information available throughout the value chain so that goods can be maintained, repaired, reused and recycled more effectively.
The European Commission’s registry will not hold every material declaration, repair instruction or sustainability calculation. It acts as a central index, storing unique product identifiers and prescribed registration data. The full passport follows a decentralised model and remains under the responsibility of the economic operator placing the product on the EU market.
That company may host the information itself or use a specialist DPP service provider. Either way, it must register the passport and keep the underlying data available.
A QR code pointing to an attractive product page is not enough. The passport must use structured, machine-readable and interoperable data linked to the physical product through a unique identifier. Access must also be maintained for the period set by the applicable product legislation.
The European Commission has created a free semantic repository containing common data models, definitions and vocabulary. Six harmonised standards covering identifiers, data carriers, interoperability, application programming interfaces, data exchange and storage were published alongside the registry’s launch. Two further standards are expected to follow.
Not every user will see the same information. Consumers might receive data about materials, maintenance and recycling, while public authorities, customs officials, repairers and supply-chain partners may be granted access to other records. Access rights will be defined in the legislation governing each product group.
What information must a Digital Product Passport contain?
There is no universal list of fields for every product. The Ecodesign for Sustainable Products Regulation establishes the framework, while product-specific delegated acts will determine the requirements for iron, steel, textiles, furniture and other goods.
Depending on the product group, a Digital Product Passport may include:
- A unique product, batch or item identifier
- Manufacturer and responsible economic operator details
- Manufacturing location and date
- Materials, components and substances of concern
- Product weight and technical characteristics
- Carbon or wider environmental footprint information
- Recycled material content
- Durability and performance data
- Repair, maintenance and disassembly instructions
- Spare-parts information
- Guidance for reuse, remanufacturing and recycling
- Declarations of conformity and supporting documentation
- Information about safe handling and disposal
The required level of identification may also vary. Some passports could apply to an entire product model, others to a production batch and others to an individual item.
Maintaining one passport for a washing-machine model is a different technical exercise from creating and updating a separate record for every electric vehicle battery leaving a factory. Companies may need to generate identifiers and passports at industrial scale while preserving the link between each physical product and its digital record.
Battery passports provide the first compliance test
From 18 February 2027, battery passports will be mandatory for electric vehicle batteries, light means of transport batteries and industrial batteries with a capacity greater than 2 kilowatt-hours placed on the EU market. Light means of transport include products such as electric bicycles, scooters and mopeds.
The obligation falls on the economic operator placing the finished battery on the market, rather than suppliers of individual cells, modules or materials. Each battery passport must be linked to the physical battery through a QR code and carry a unique identifier.
The European Commission’s latest guidance identifies more than 60 possible battery data points, although not every field applies to every battery category or from the first implementation date.
Mandatory information from February 2027 includes the manufacturer’s identity and contact point, battery category, model or serial identification, manufacturing location and date, weight, capacity and chemistry. Passports must also identify hazardous substances and critical raw materials above the prescribed threshold.
Technical data extends to voltage, power capability, expected lifetime, energy efficiency, internal resistance and applicable warranty information. Battery passports must provide the EU declaration of conformity, waste-management information, detailed composition, spare-parts sources, dismantling instructions, safety measures and relevant test reports.
Some information will change during the battery’s working life. Dynamic fields include capacity and power fade, internal resistance and indicators used to determine the battery’s state of health. The passport becomes a continuing technical record rather than a label created once at the factory.
Other anticipated fields will be phased in later. The Commission’s August 2026 guidance says carbon-footprint declarations and labels will not yet have to be displayed in February 2027 because their formats still require an implementing act. Responsible-sourcing information becomes applicable from August 2027, while recycled-content data will follow the timetable and secondary rules attached to the EU Battery Regulation.
Manufacturers must prepare for both the initial battery passport requirements and later additions. Their systems will need to accommodate changing data requirements without rebuilding every passport from scratch.
Which products will need an EU Digital Product Passport?
Batteries are the first regulated implementation. The European Commission plans to adopt product-specific Digital Product Passport rules for iron and steel in late 2026, followed by textiles, aluminium and tyres in 2027. Furniture is scheduled for 2028, with mattresses and further recycled-content requirements following in 2029.
These dates refer to the expected adoption of product-specific rules, not necessarily the date on which passports become compulsory. Under the Ecodesign for Sustainable Products Regulation, economic operators receive a transition period of at least 18 months after the relevant delegated act is adopted.
The EU registry is also designed to support product passports introduced through other legislation, including rules governing construction products, toys, detergents and surfactants. Requirements for construction materials are currently expected in 2027.
Information and communications technology products and other energy-related goods also feature in the Commission’s working plan, although their exact data requirements and implementation deadlines have not yet been finalised.
Digital Product Passport data is scattered across the business
Most manufacturers already possess some of the information they will need. It rarely sits in one place.
Technical specifications may reside in product lifecycle management software. Supplier declarations arrive as spreadsheets or PDF documents. Environmental data sits with the sustainability team. Repair manuals are held by after-sales operations, while compliance certificates may be managed by legal or quality departments.
Some of the most demanding information lies outside the company altogether. Battery makers and vehicle manufacturers, for example, may need evidence from cell producers, refiners, recyclers and mining companies. Suppliers must share enough information to support the passport without exposing confidential contracts, formulations or prices.
A manufacturer could build a polished passport interface and still fail because its underlying information is incomplete, inconsistent or impossible to verify. If a supplier changes a component, material source or production site, affected records may also need updating.
Companies need to establish who owns every required data field, where its supporting evidence comes from, how often it changes and who has authority to correct it. They must also ensure that passports remain available if an external service provider fails or a commercial relationship ends. Outsourcing the technical platform does not transfer the economic operator’s regulatory obligations.
Which companies offer Digital Product Passport software?
A growing group of technology companies offers software for collecting supply-chain data, assigning product identifiers and publishing Digital Product Passports.
Siemens offers its DPP4.0 platform, initially focused on batteries. It uses the Asset Administration Shell, an industrial data structure designed to exchange product information between different systems.
UK-based Circulor specialises in battery-material traceability. Its platform collects information covering material origin, emissions, recycled content and due diligence. Volvo Cars uses Circulor technology for the battery passport associated with the EX90 electric vehicle.
Norwegian company Kezzler provides product identification, traceability and passport-management technology. Its system includes data-completeness checks, approval workflows, integrations with existing business systems and support for GS1 identification standards.
Netherlands-based Circularise collects data across multiple supplier tiers while allowing companies to apply different access permissions to commercially sensitive information. It has worked with materials company Teijin on using Digital Product Passports to trace recycled content.
Berlin-based Minespider offers product passports with separate public, private and supply-chain data layers. Its work focuses particularly on batteries, minerals and industrial supply chains.
These platforms address different parts of the compliance problem. Some concentrate on identifiers and passport publication; others specialise in tracing raw materials, calculating environmental information or exchanging confidential supplier data. Companies will still need to check whether a provider supports the standards and product-specific legislation that applies to them.
No platform can produce reliable compliance records from missing or poorly governed data.
How can companies prepare for Digital Product Passport compliance?
Companies can begin by mapping available product information against the confirmed or likely requirements for their product category.
Businesses can then identify data gaps, rank suppliers by data risk and decide which internal system will act as the authoritative source for each field. They also need to test whether identifiers remain connected to the correct products through manufacturing, sale, repair, reuse and recycling.
The Commission has opened a testing environment alongside the live Digital Product Passport Registry. It allows companies to practise organisational enrolment, passport registration and management without affecting live records.
Europe’s Digital Product Passport will make product information more visible outside the factory. Before that can happen, manufacturers must connect data that has long been divided between engineering, procurement, sustainability, compliance and after-sales systems.
The QR code is the easy part.