ESPR Digital Product Passport requirements checklist for businesses

These obligations are already in force or have fixed dates, or they take months whatever your category's final rules say.

1. Mark “Confirm which law will set your product's passport” as done

   Confirm which law will set your product's passport

   ESPR covers almost all physical goods, but the passport for each product group comes from a specific act. Batteries, detergents, toys and construction products get theirs from their own regulations. Everything else waits for an ESPR delegated act. List your EU product groups and map each one to its legal source.

   Source: Regulation (EU) 2024/1781 (ESPR) · European Commission: Digital Product Passport

2. Mark “Look up your product group's current status and set a review date” as done

   Look up your product group's current status and set a review date

   The Working Plan years are indicative adoption dates, not compliance deadlines. As of October 2026 no ESPR delegated act sets DPP requirements for any product group. Iron and steel is planned for Q4 2026 and textiles for 2027. Check the status every quarter.

   Source: ESPR Working Plan 2025–2030, COM(2025) 187 · Commission: DPP for iron and steel

3. Mark “Batteries: be ready for the Battery Passport on 18 February 2027” as done

   Batteries: be ready for the Battery Passport on 18 February 2027

   Applies to: EV, LMT and industrial batteries over 2 kWh

   This is the first binding DPP date in EU law. Each battery needs a passport reachable through a QR code, and the passport must be registered in the EU DPP Registry. Registering requires verified economic operator status, so start the identity verification early.

   Source: Regulation (EU) 2023/1542 (Batteries), Art. 77 · Implementing Regulation (EU) 2026/1778 (DPP Registry)

4. Mark “Publish your annual disclosure of discarded unsold products” as done

   Publish your annual disclosure of discarded unsold products

   Applies to: Large companies now; medium-sized companies from 2030

   Companies that discard unsold consumer products of any kind must publish yearly, on their website, the number and weight discarded, the reasons and the prevention measures taken. The Commission's standard disclosure format applies from February 2027.

   Source: Regulation (EU) 2024/1781 (ESPR) · Commission: new rules on unsold clothes and shoes (9 Feb 2026)

5. Mark “Stop destroying unsold apparel, clothing accessories and footwear” as done

   Stop destroying unsold apparel, clothing accessories and footwear

   Applies to: Large companies since 19 July 2026; medium-sized from 19 July 2030

   Destruction is only allowed under the derogations in Delegated Regulation (EU) 2026/296, such as safety risks, damage or rejected donation offers. Keep the supporting evidence for five years.

   Source: Regulation (EU) 2024/1781 (ESPR) · Commission: new rules on unsold clothes and shoes (9 Feb 2026)

6. Mark “Name an internal owner and budget for DPP readiness” as done

   Name an internal owner and budget for DPP readiness

   Passports touch product, compliance, packaging, supply chain and IT. One accountable owner with a budget line avoids a scramble once your act is adopted.

   Source: European Commission: Digital Product Passport

7. Mark “Put unique identifiers in place” as done

   Put unique identifiers in place

   Passports hang off a unique product identifier (at model, batch or item level), plus identifiers for your company and your manufacturing facilities. Check that your GTINs, serial or batch numbering and supplier facility records can carry this.

   Source: Regulation (EU) 2024/1781 (ESPR) · Implementing Regulation (EU) 2026/1778 (DPP Registry)

8. Mark “Map where your product data lives and find the gaps” as done

   Map where your product data lives and find the gaps

   List what you already hold in your PIM, PLM or ERP systems and spreadsheets: composition, substances of concern, recycled content, durability, carbon footprint, manuals and compliance documents. Most brands find a large share of passport data isn't held anywhere yet.

   Source: Regulation (EU) 2024/1781 (ESPR)

9. Mark “Start supplier data requests” as done

   Start supplier data requests

   The hardest fields (material origin, recycled content, footprint data) sit with Tier 1 and Tier 2 suppliers. Add data clauses to supplier agreements now. Collecting this typically takes 12 months or more.

   Source: ESPR Working Plan 2025–2030, COM(2025) 187

Build the foundations now, in a way that can absorb your category's final rules.

1. Mark “Plan where the data carrier (QR code) will go” as done

   Plan where the data carrier (QR code) will go

   Decide whether the code goes on the product, its label or its packaging, and check that your print and labelling workflows can handle unique codes at scale. Your delegated act may specify the carrier type and position, so keep the design adjustable.

   Source: Regulation (EU) 2024/1781 (ESPR)

2. Mark “Make sure your systems can work at model, batch and item level” as done

   Make sure your systems can work at model, batch and item level

   Each act sets the granularity. Where several EU laws apply to the same product, it is registered at the most granular level any of them requires.

   Source: Implementing Regulation (EU) 2026/1778 (DPP Registry)

3. Mark “Plan who can see what” as done

   Plan who can see what

   Passport data is split between public information and restricted information for authorities, recyclers or repairers. Tag sensitive fields now so you can apply access rights later.

   Source: Regulation (EU) 2024/1781 (ESPR)

4. Mark “Digitise manuals, safety information and compliance documents” as done

   Digitise manuals, safety information and compliance documents

   User instructions, safety information and declarations of conformity are expected to be reachable through the passport. Mobile-friendly, multilingual formats are far easier to link than 200-page PDFs.

   Source: Regulation (EU) 2024/1781 (ESPR)

5. Mark “Choose how you will host and update passports” as done

   Choose how you will host and update passports

   Passports must stay available and up to date for the period set in your act, with a backup held by a DPP service provider. Shortlist platforms that support configurable fields, all three granularity levels and registry integration.

   Source: Regulation (EU) 2024/1781 (ESPR) · Implementing Regulation (EU) 2026/1778 (DPP Registry)

Don't lock these in until the act for your product group is adopted. Doing so risks rework.

1. Mark “The final mandatory data field list” as done

   The final mandatory data field list

   Fields are fixed per product group in its delegated act. Draft studies (such as the JRC's for steel) show the direction, but fields can still move between mandatory and voluntary.

   Source: Commission: DPP for iron and steel

2. Mark “Your application date” as done

   Your application date

   An act applies no earlier than 18 months after it enters into force, except in duly justified cases (ESPR Art. 4(4)). Don't treat Working Plan years as deadlines.

   Source: Regulation (EU) 2024/1781 (ESPR) · ESPR Working Plan 2025–2030, COM(2025) 187

3. Mark “Final passport layouts and printed label artwork” as done

   Final passport layouts and printed label artwork

   Data carrier and access-rights specifics depend on your act and on the harmonised standards. Prototype, but hold off on mass printing.

   Source: European Commission: Digital Product Passport