EU Digital Product Passport

What is actually
required.

Without the vendor fog. Including the parts nobody can implement yet.

The requirement

Three things, not one.

01

A unique identifier

Carried on the product, resolvable by anyone who reads it, and registered centrally so a machine can find where the data lives.

02

Structured data

Defined per product category — composition, footprint, repair, recycling, documents — held in a form a system can read, not a brochure.

03

Access by role

Consumers, authorities, repairers, recyclers and purchasers each see a defined part. The data itself stays decentralised.

What that takes to run →

Sequence

Batteries first, then the rest.

Each product category arrives on its own act and its own date.

CategoryWhenStatus
Batteries above the size threshold18 February 2027 Date fixed
Textiles & apparelExpected 2027 onward Act pending
FurnitureExpected 2027 onward Act pending
Electronics & ICTExpected 2028–2029 In preparation
Steel & industrial materialsSequenced with related rules In preparation

For anything shipped by sea, the binding date is months earlier than the one in the table. Why →

Unsettled

Three things nobody can do yet.

Any vendor telling you otherwise is selling a road that has not been built.

Register a battery passport

The registry is open, but battery registrations cannot yet complete — the underlying definitions are unpublished.

Know exactly who may read what

The detailed rules on legitimate-interest access are overdue. Everyone is implementing to the law as written.

Be a certified provider

No approval scheme for passport providers exists. Claims of being certified or approved today describe nothing.

Meanwhile

What is worth doing now.

The unsettled parts are days of work. The settled part takes months.

1
Find out what applies Resolve the data points for your category and date — not the generic list.
2
Ask your suppliers early Composition, test results and part numbers sit with them, and first requests take months.
3
Decide the carrier Printed code or cryptographic chip — it changes artwork, tooling and line process.
4
Run one batch end to end Registration and sealing can wait. Discovering your data gaps cannot.

Start where the delay actually is.