In short
- ●ESPR does not make passports mandatory on its own. Each product group becomes subject to a DPP only when its delegated act applies, normally with at least an 18-month transition.
- Status
- In force
- DPP applies
- Per delegated act — usually ≥18 months after adoption
- Scope
- Almost all physical goods placed on the EU market, including components and intermediate products, rolled out product group by product group.
Key dates
ESPR adopted
ESPR enters into force
Working plan 2025–2030 adopted (COM(2025) 187)
Central DPP registry deadline (Art. 13)
Ban on destroying unsold apparel & footwear — large companies
Destruction ban extends to medium-sized companies
Articles 9–15 at a glance
- Art. 9 — Products covered by a delegated act may only be placed on the market with the required passport. The act sets data, carrier, granularity (model, batch or item), access rights and availability period.
- Art. 10 — Persistent unique product identifier, physical data carrier, open standards, machine-readable and transferable data, differentiated access.
- Art. 11 — Interoperability, secure storage, authentication, integrity, privacy and continued availability, including backup by DPP service providers.
- Art. 12 — Rules for product, operator and facility identifiers.
- Art. 13 — Commission central registry storing at least the unique identifiers.
- Art. 14 — Public web portal to search and compare passport information.
- Art. 15 — Customs checks against the registry for imported products.
Decentralised by design
The central registry holds identifiers, not the passports themselves. Passport data stays in systems run by the responsible economic operator or a DPP service provider acting on its behalf. Implementing Regulation (EU) 2026/1778 of 16 July 2026 sets the registry's operating arrangements.
Annex III is a menu, not a template
Annex III lists the information a delegated act can require — product and GTIN identification, commodity codes, compliance documentation, manuals and safety information, operator and facility identifiers. Each delegated act picks what applies. There is no general obligation to publish a full bill of materials, use blockchain, or serialise every item.
Standards: CEN/CENELEC JTC 24
Under standardisation request M/604 (C(2024) 5423), JTC 24 delivered a first series of eight European DPP standards in July 2026. Implementing Decision (EU) 2026/1736 references EN 18216, 18219, 18220, 18221, 18222 and 18223:2026, giving a presumption of conformity with Articles 10–11. These standards cover identifiers, carriers, access rights, APIs and data exchange — not sector data content.
DPP service providers
Article 11 empowers a delegated act on requirements for third-party DPP service providers and a possible certification scheme. This act was not verified as adopted; treat any claimed 'EU DPP licence' with caution until it is.
Information the passport contains
- Unique product identifier (model, batch or item)
- GTIN or equivalent and commodity (TARIC) code
- Manufacturer, importer and operator identifiers
- Facility identifiers
- Compliance documentation and declaration of conformity
- User manuals, instructions, warnings and safety information
- Durability, reparability and recycled content (where required)
- Substances of concern (where required)
- Environmental footprint (where required)
Questions
When does ESPR make DPPs mandatory?
Only when a product-specific delegated act applies. Acts normally apply at least 18 months after entry into force, so the earliest ESPR passports (iron and steel) are expected around 2028.
Does ESPR apply to non-EU manufacturers?
Yes. It covers products placed on the EU market regardless of where they are made.
What is excluded from ESPR?
Food, feed, medicinal products, veterinary medicines, living plants, animals and micro-organisms, and certain vehicle aspects already regulated elsewhere.
Sources
- Regulation (EU) 2024/1781 — EUR-Lex
- ESPR Working Plan 2025–2030
- Implementing Regulation (EU) 2026/1778 (registry)
- European Commission — Digital Product Passport
- CEN/CENELEC — DPP standards
Last reviewed 2 November 2026. Guidance only — not legal advice.
Dates marked "expected" depend on acts not yet adopted. Reviewed 2 November 2026.
← All legislation