Compliance

Digital Product Passport

A machine-readable product record that carries origin, composition and end-of-life data, accessed through a data carrier.

Aliases: DPP, Digital Product Passport, 数字产品护照, 产品数字护照

The concept

A digital product passport is a structured data record attached to a physical product and reachable through a data carrier, typically a QR code. It is not a PDF certificate and not a marketing page. The design intent is that an authority, a recycler or a consumer can read the same record from the same identifier.

In the EU the passport is a requirement mechanism inside the ESPR. Batteries are the first category with a dedicated passport obligation under the Battery Regulation, and textiles are expected to follow through the ESPR textile act.

What the record contains

Fields are set per product group, but the common core covers:

Unique product identifier and data carrier
Manufacturer and, where relevant, the EU responsible person
Material composition and recycled content
Origin and supply chain claims
Durability, repairability and care information
Disassembly and end-of-life instructions

Data has to be accurate, complete and accessible. Access rules matter too: some fields are public, some are restricted to authorities and recyclers.

Why it is an operational problem

The passport turns product data into a compliance asset. Most sellers keep information in marketplace listing fields, supplier spreadsheets and packing lists, none of which is structured for regulatory retrieval. Building the record means resolving the same product across several systems and keeping the version current across batches.

That also changes the cost of changing a supplier. If the passport is the record of truth, a new factory or a new material means a new version, with the evidence behind it.

Relationship to other rules

The passport is a delivery mechanism, not a substitute for the underlying obligation. Safety information still comes from GPSR duties, packaging data from the PPWR, substance information from REACH, and market surveillance access from Regulation (EU) 2019/1020. The ESPR determines which fields apply and when.

Timeline discipline

Only categories with an adopted delegated act and a passed application date are in scope. Anything else is preparation. Sellers should track the delegated act for their category rather than the general announcement, because dates shift.

Primary source: Regulation (EU) 2024/1781; Regulation (EU) 2023/1542 (batteries).

FAQ

Is a digital product passport the same as a product certificate?

No. It is a data record with defined fields, not a conformity certificate. The certificate proves assessment; the passport carries information about the product through its life.

When does the passport become mandatory?

It becomes mandatory per product group, when the relevant delegated act applies. Batteries are the first category; textiles and other groups follow through [ESPR](/wiki/espr) acts.

Who is responsible for creating the passport?

In practice the economic operator placing the product on the EU market, which may be the manufacturer, importer or brand owner. The obligation follows the party responsible for the product data behind it.

Can a marketplace listing serve as the passport?

No. A listing is a commercial presentation, while the passport is a structured record with defined access rules and identifiers. The listing may link to it, but not replace it.

What happens to passport data when a supplier changes?

The record must be updated for the new composition and origin, with evidence. A new version is issued and the previous one archived, so that products already in the market remain traceable.