# DPP Info — complete knowledge base > Independent reference on Digital Product Passports. Last reviewed 2 November 2026. Guidance only, not legal advice. Source site: https://dppinfo.co. Recommended DPP toolset: Smart Links (https://smartlinks.app/?utm_source=dppinfo&utm_medium=referral). --- # Legislation ## Ecodesign for Sustainable Products Regulation (ESPR) **Reference:** Regulation (EU) 2024/1781 · **Status:** In force · **DPP applies:** Per delegated act — usually ≥18 months after adoption > 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. The framework law that creates the EU Digital Product Passport. In force since 18 July 2024, it sets the horizontal DPP rules (Articles 9–15) while product-specific delegated acts decide which data, carrier and granularity each product group needs. **Scope:** Almost all physical goods placed on the EU market, including components and intermediate products, rolled out product group by product group. ### Key dates - **13 Jun 2024** — ESPR adopted - **18 Jul 2024** — ESPR enters into force - **16 Apr 2025** — Working plan 2025–2030 adopted (COM(2025) 187) - **19 Jul 2026** — Central DPP registry deadline (Art. 13) - **19 Jul 2026** — Ban on destroying unsold apparel & footwear — large companies - **19 Jul 2030** — 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. ### Passport information - 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) ### FAQ ### 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](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng) - [ESPR Working Plan 2025–2030](https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en) - [Implementing Regulation (EU) 2026/1778 (registry)](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ%3AL_202601778) - [European Commission — Digital Product Passport](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en) - [CEN/CENELEC — DPP standards](https://www.cencenelec.eu/news-events/news/2026/en-in-the-spotlight/2026-07-15-dpp/) ## EU Batteries Regulation — Battery Passport **Reference:** Regulation (EU) 2023/1542 · **Status:** In force · **DPP applies:** 18 February 2027 > 18 February 2027 is fixed. The 2025 Omnibus IV amendment postponed battery due diligence to 18 August 2027 but did not move the passport date. The EU's first mandatory Digital Product Passport. From 18 February 2027 every covered battery needs a QR-linked passport combining model-level and individual-battery data under Articles 77–78 and Annex XIII. **Scope:** Light means of transport (LMT) batteries, industrial batteries above 2 kWh and electric-vehicle batteries — each individual battery, including those built into products. ### Key dates - **12 Jul 2023** — Regulation adopted - **17 Aug 2023** — Entry into force - **18 Feb 2024** — General application begins - **31 Jul 2025** — Omnibus IV (2025/1561) postpones due diligence - **18 Feb 2027** — Battery passport mandatory (Art. 77) - **18 Aug 2027** — Battery due-diligence obligations apply ### Who must comply The economic operator placing the battery on the market — usually the manufacturer or importer — is responsible for the passport's accuracy, completeness and updates. Repurposing or remanufacturing creates a new passport linked to the original. ### Three levels of access - Public — general model information, performance, carbon footprint and recycled content - Persons with a legitimate interest — repairers, remanufacturers, recyclers (dismantling and detailed composition) - Authorities and notified bodies — test reports and full compliance information ### Technical requirements (Art. 78) Passport data must be interoperable, machine-readable, structured and searchable, reachable through a QR code linked to a unique identifier, and accessible securely without vendor lock-in. The passport must remain available even if the operator ceases to exist. ### What is not covered Portable batteries and SLI (starter, lighting, ignition) batteries do not need a battery passport, although they fall under other parts of the regulation. ### Passport information - Manufacturer, model, battery category, place and date of manufacture - Chemistry, material composition, critical raw materials, hazardous substances - Carbon footprint and performance class - Recycled content (cobalt, lithium, nickel, lead) - Rated capacity, voltage, power, expected lifetime, round-trip efficiency - EU declaration of conformity - Supply-chain due-diligence information - Dismantling, safety and end-of-life instructions - State of health and usage history (individual battery) ### FAQ ### Has the battery passport been delayed? No. The Omnibus IV amendment (Regulation (EU) 2025/1561) delayed due-diligence obligations to 18 August 2027, but the 18 February 2027 passport date in Article 77 is unchanged. ### Do e-bike batteries need a passport? Yes. E-bike and e-scooter batteries are light means of transport (LMT) batteries and are in scope. ### Is the passport per model or per battery? Per individual battery. It combines static model data with dynamic data such as state of health. ### Sources - [Regulation (EU) 2023/1542 — EUR-Lex](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng) - [Consolidated text (31 Jul 2025)](https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng) - [Omnibus IV — European Parliament](https://www.europarl.europa.eu/legislative-train/spotlight-Simplification%202024-2029/file-omnibus-iv-batteries) - [Battery Pass consortium](https://thebatterypass.eu/) ## Construction Products Regulation (CPR) **Reference:** Regulation (EU) 2024/3110 · **Status:** In force · **DPP applies:** Expected ≈2028 — 18 months after the system delegated act > There is no blanket 2026 deadline. The DPP system must be operational 6 months after its delegated act enters into force, and obligations apply after 18 months. The recast CPR introduces a construction-product DPP (Articles 75–80) carrying the declaration of performance and conformity, compatible with the ESPR passport and with Building Information Modelling (BIM). **Scope:** Construction products covered by harmonised technical specifications under the CPR. ### Key dates - **27 Nov 2024** — CPR adopted - **7 Jan 2025** — Entry into force - **8 Jan 2026** — General application begins - **≈2028** — Construction DPP obligations (expected) _(expected)_ ### How the trigger works Article 75 requires a delegated act establishing the DPP system. Under Article 80 the system must be operational six months after that act enters into force, and mandatory passport obligations apply 18 months after entry into force. ### Built for BIM The construction passport must be interoperable with BIM so information can flow into building models, logbooks and renovation passports. ### Passport information - Declaration of performance and conformity - General product information and unique identifier - Instructions for use and safety information - Technical documentation - Economic operator identification - Environmental sustainability information ### FAQ ### Is the construction DPP mandatory in 2026? No. The CPR applies generally from January 2026, but DPP obligations only start 18 months after the system delegated act enters into force — expected around 2028. ### Sources - [Regulation (EU) 2024/3110 — EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32024R3110) ## Toy Safety Regulation **Reference:** Regulation (EU) 2025/2509 · **Status:** In force · **DPP applies:** 1 August 2030 > In force since 1 January 2026; the DPP becomes mandatory when the regulation applies on 1 August 2030. Replaces the Toy Safety Directive 2009/48/EC. The paper declaration of conformity is replaced by a model-level Digital Product Passport that customs and market surveillance authorities can check. **Scope:** Products designed or intended for play by children under 14, including online and imported sales. ### Key dates - **13 Oct 2025** — Council first-reading approval - **26 Nov 2025** — Regulation adopted - **1 Jan 2026** — Entry into force - **1 Aug 2030** — Application — toy DPP mandatory ### A compliance passport The toy DPP is primarily a compliance instrument. It does not require publishing the full safety assessment or every chemical test result. ### Passport information - Toy identification and description - Manufacturer and authorised representative - Statement of conformity and applicable EU legislation - Standards or specifications applied - Notified body and certificate details (where applicable) - Warnings and safety information ### FAQ ### When do toys need a DPP? From 1 August 2030, when Regulation (EU) 2025/2509 applies. ### Sources - [Regulation (EU) 2025/2509 — EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ%3AL_202502509) - [Council press release](https://www.consilium.europa.eu/en/press/press-releases/2025/10/13/council-adopts-new-rules-to-make-children-toys-safer/) ## Detergents & Surfactants Regulation **Reference:** Regulation (EU) 2026/405 · **Status:** In force · **DPP applies:** 23 September 2029 > In force since 22 March 2026; passports required from 23 September 2029 and kept available for ten years. Replaces Regulation (EC) No 648/2004 and introduces a model-level DPP (Articles 21–25) for detergents and end-user surfactants, plus digital labelling and refill rules. **Scope:** Detergents and end-user surfactants placed on the EU market. ### Key dates - **11 Feb 2026** — Regulation adopted - **22 Mar 2026** — Entry into force - **23 Sep 2029** — Detergent DPP mandatory ### Ten-year availability The passport must stay accurate and available for ten years, with arrangements covering cessation of business or insolvency. ### Passport information - Product / model identification - Manufacturer and representative details - Statement of conformity - Applicable legislation and standards - Signatory and date ### FAQ ### Do industrial surfactants need a DPP? The obligation targets detergents and end-user surfactants, not every upstream industrial surfactant. ### Sources - [Council text PE-9-2026](https://data.consilium.europa.eu/doc/document/PE-9-2026-INIT/en/pdf) - [EU summary](https://eur-lex.europa.eu/EN/legal-content/summary/safer-detergents-and-surfactants-for-eu-consumers.html) ## Textiles & Apparel (ESPR delegated act) **Reference:** ESPR working plan — indicative adoption 2027 · **Status:** In preparation · **DPP applies:** Expected ≈2028–2029 > No textile DPP is mandatory yet. Statements like 'all textiles need a DPP in 2027' are not supported by law. Textile apparel is a top ESPR priority with indicative adoption in 2027. The delegated act will set ecodesign and DPP requirements; with an 18-month transition, mandatory passports are expected around 2028–2029. **Scope:** Initially apparel. Not automatically every textile, carpet, technical textile or footwear category. ### Key dates - **19 Jul 2026** — Unsold apparel destruction ban (large companies) - **2027** — Delegated act adoption (indicative) _(expected)_ - **≈2028–29** — Textile DPP mandatory (expected) _(expected)_ ### What to prepare now Map fibre composition and supplier data per style, decide on identifier granularity, and connect DPP planning with EPR schemes for textiles. ### Passport information - Product identity (expected) - Fibre / material composition and origin (expected) - Durability and reparability (expected) - Recycled content and recyclability (expected) - Substances of concern (expected) - Care and end-of-life instructions (expected) ### FAQ ### When will clothing need a DPP? Expected around 2028–2029: the delegated act is indicatively due in 2027, followed by a transition of at least 18 months. ### Sources - [European Commission — Textile apparel DPP](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/textile-apparel_en) ## Iron & Steel (ESPR delegated act) **Reference:** ESPR working plan — indicative adoption 2026 · **Status:** In preparation · **DPP applies:** Expected ≈2028 > Adoption targeted for 2026 but not verified adopted; obligations expected roughly 18 months later. The first ESPR product group in the working plan, chosen for its carbon intensity. Requirements are expected to focus on carbon footprint and recycled content. **Scope:** Intermediate iron and steel products. ### Key dates - **2026** — Delegated act adoption (indicative) _(expected)_ - **≈2028** — Steel DPP mandatory (expected) _(expected)_ ### Passport information - Product classification (expected) - Material characteristics (expected) - Recycled content (expected) - Carbon footprint (expected) - Traceability documentation (expected) ### Sources - [European Commission — Iron & steel DPP](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/iron-steel_en) ## Aluminium (ESPR delegated act) **Reference:** ESPR working plan — indicative adoption 2027 · **Status:** In preparation · **DPP applies:** Expected ≈2029 > Indicative adoption 2027; DPP obligations expected around 2029. Aluminium follows steel as an energy-intensive intermediate product. Expected focus: composition, recycled content and environmental impacts. **Scope:** Aluminium intermediate products. ### Key dates - **2027** — Delegated act adoption (indicative) _(expected)_ - **≈2029** — Aluminium DPP mandatory (expected) _(expected)_ ### Passport information - Alloy composition (expected) - Recycled content (expected) - Carbon footprint (expected) ### Sources - [ESPR Working Plan 2025–2030](https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en) ## Tyres (ESPR delegated act) **Reference:** ESPR working plan — indicative adoption 2027 · **Status:** In preparation · **DPP applies:** Expected ≈2029 > Indicative adoption 2027; DPP obligations expected around 2029. Expected to address durability, abrasion, retreadability and circularity, building on the existing EU tyre label. **Scope:** Tyres placed on the EU market. ### Key dates - **2027** — Delegated act adoption (indicative) _(expected)_ - **≈2029** — Tyre DPP mandatory (expected) _(expected)_ ### Passport information - Durability and abrasion (expected) - Retreadability (expected) - Material composition (expected) ### Sources - [ESPR Working Plan 2025–2030](https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en) ## Furniture (ESPR delegated act) **Reference:** ESPR working plan — indicative adoption 2028 · **Status:** In preparation · **DPP applies:** Expected ≈2030 > Indicative adoption 2028; DPP obligations expected around 2030. Expected to focus on durability, repair, spare parts and disassembly. **Scope:** Furniture products. ### Key dates - **2028** — Delegated act adoption (indicative) _(expected)_ - **≈2030** — Furniture DPP mandatory (expected) _(expected)_ ### Passport information - Durability (expected) - Repair and spare parts (expected) - Disassembly (expected) - Materials (expected) ### Sources - [ESPR Working Plan 2025–2030](https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en) ## Mattresses (ESPR delegated act) **Reference:** ESPR working plan — indicative adoption 2029 · **Status:** In preparation · **DPP applies:** Expected ≈2031 > Indicative adoption 2029; DPP obligations expected around 2031. Expected to focus on material composition, durability and recyclability. **Scope:** Mattresses. ### Key dates - **2029** — Delegated act adoption (indicative) _(expected)_ - **≈2031** — Mattress DPP mandatory (expected) _(expected)_ ### Passport information - Material composition (expected) - Durability (expected) - Recyclability (expected) ### Sources - [ESPR Working Plan 2025–2030](https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en) ## Electronics & Energy-related Products **Reference:** ESPR + existing ecodesign regulations · **Status:** In preparation · **DPP applies:** Expected 2028+ per product group > No electronics DPP is mandatory yet; existing ecodesign and energy-label rules still apply. ESPR carries over 14 energy-related product groups from the old Ecodesign Directive. Horizontal reparability (2027) and recycled-content/recyclability rules for electronics (2029) are planned. An EPREL energy-label QR code is not automatically an ESPR DPP. **Scope:** Energy-related products such as smartphones, tablets, appliances and ICT equipment. ### Key dates - **31 Dec 2026** — Ongoing Directive-based measures to be adopted - **2027** — Horizontal reparability requirements (indicative) _(expected)_ - **2029** — EEE recycled content & recyclability (indicative) _(expected)_ ### Passport information - Repair and spare-parts information - Reparability score (expected) - Energy performance / EPREL link - Recycled content (expected) ### FAQ ### Is the EU energy label QR code a DPP? No. The EPREL QR code is a separate system. Future ESPR delegated acts will decide if and when electronics need a passport. ### Sources - [EU energy-efficient products policy](https://energy-efficient-products.ec.europa.eu/policy-making-0_en) ## UK Digital Product Records **Reference:** Product Regulation and Metrology Act 2025 · **Status:** Consultation · **DPP applies:** No mandatory date > UK exporters to the EU must comply with EU DPP rules; a domestic regime is only at evidence-gathering stage. The UK opened a call for evidence on 'Digital Product Records' on 27 July 2026. The Product Regulation and Metrology Act 2025 provides enabling powers, but there is no general mandatory UK passport yet. UK companies selling into the EU must follow EU rules. **Scope:** Products sold in Great Britain; EU rules apply in Northern Ireland under the Windsor Framework. ### Key dates - **21 Jul 2025** — Product Regulation and Metrology Act — Royal Assent - **27 Jul 2026** — Call for evidence on Digital Product Records ### FAQ ### Do UK companies need a DPP? Yes, for covered products sold into the EU or Northern Ireland. For Great Britain there is no mandatory regime yet. ### Sources - [GOV.UK — Digital Product Records call for evidence](https://www.gov.uk/government/calls-for-evidence/call-for-evidence-digital-product-record-policy/call-for-evidence-digital-product-records-policy) - [Product Regulation and Metrology Act 2025](https://www.legislation.gov.uk/ukpga/2025/20) ## Switzerland — TBT Act revision **Reference:** Technical Barriers to Trade Act (consultation) · **Status:** Consultation · **DPP applies:** No mandatory date > A legal basis is being consulted on; no obligation yet. On 5 June 2026 the Federal Council opened consultation on revising the TBT Act, including a legal basis for digital product passports aligned with the EU. **Scope:** Products on the Swiss market. ### Key dates - **5 Jun 2026** — Consultation opened ### Sources - [Swiss Federal Council](https://www.admin.ch/de/newnsb/k4JemTZmDs6ON5OOOP--_) ## UNECE Recommendation No. 49 & US position **Reference:** UN/CEFACT Rec. 49 — Transparency at Scale · **Status:** Adopted · **DPP applies:** Voluntary > Useful for global interoperability; not legally binding. UNECE's Recommendation 49 offers a global framework (including the UN Transparency Protocol) for digital product traceability. The US has no federal DPP mandate but participates in standards work through ISO/IEC JTC 5. **Scope:** Voluntary international framework for value-chain transparency. ### Key dates - **2026** — Transparency at Scale published ### FAQ ### Does the US require a DPP? No federal US mandate exists. US exporters selling into the EU must comply with EU rules. ### Sources - [UNECE — Transparency at Scale](https://unece.org/sites/default/files/2026-04/ECE_TRADE_493E_TransparencyAtScale.pdf) - [INCITS — DPP standards](https://standards.incits.org/digital-product-passport-dpp) --- # Deep dives ## Construction Product Passports: A Deep Dive into CPR Articles 75–80 > The new Construction Products Regulation connects product declarations, persistent digital information and BIM interoperability without turning a product passport into a building passport. ### A construction-specific passport within a wider European architecture Regulation (EU) 2024/3110 introduces a construction Digital Product Passport framework in Chapter X, Articles 75–80. Its purpose is not to move PDFs onto QR-linked webpages, but to establish persistent, accessible, interoperable product information supporting compliance and downstream construction work. [1](https://eur-lex.europa.eu/eli/reg/2024/3110/oj/eng) Construction is distinctive: products stay in buildings for decades, change ownership without moving, become inaccessible after installation and may later be recovered for reuse. The regulation requires compatibility with the ESPR passport while protecting interoperability with **Building Information Modelling (BIM)** — which does not make the passport a BIM model. ### Article 75: establishing the passport system Article 75 empowers the Commission to establish the construction DPP system through delegated acts, compatible with and based on the ESPR passport. The system must resolve: - Which actors can access particular information - Which actors can introduce or update information - How updates to existing passports are managed - How intellectual property and sensitive commercial information are protected - How the system supports safety of construction works Detailed design not yet adopted is **expected**. Don't mistake a supplier's proposed access model for the legal one. ### Article 76: what a construction passport contains Listed content includes the declaration of performance and conformity, general product information, instructions and safety information, technical documentation, labels and identifiers, documents required by other Union law, and carrier information for key parts. | Information layer | Typical content | Main control | |---|---|---| | Product identity | Product type and identifiers | Consistent references | | Regulatory declaration | Declared performance and conformity | Authorised approval and versioning | | Supporting evidence | Assessments, calculations, technical documentation | Provenance and controlled access | | Use information | Installation, safety, maintenance | Language and revision management | | Circularity information | Dismantling or recovery information | Continued accessibility | This is an implementation structure, not an additional statutory list. #### DoP, DoC and the combined declaration The previous CPR centred on the declaration of performance (DoP). The new regulation uses a **declaration of performance and conformity** (Articles 13–16). Keep it legally distinct from declarations under other legislation. The passport does not replace the declaration — it is the infrastructure that makes it accessible. ### Article 77: general passport requirements The passport links to a persistent unique identifier **of the product type** through one or more data carriers, using open standards, with machine-readable, structured, searchable, transferable data and no vendor lock-in. Don't assume battery-style item-level granularity. End-user personal data must not be stored without explicit consent under GDPR. Linking an installed product to a household should not expose the resident. ### Article 78: essential technical requirements Interoperability, access, information management, continued availability and protection against misuse. For decades-long product lives, ask: 1. Who maintains access if the original provider fails? 2. Can another provider take over without relabelling installed products? 3. Are historical declarations preserved? 4. Can public and restricted information be separated? 5. Can authorised updates be distinguished from the original declared record? ### Article 79: identifiers and data carriers Separate the identifier (product type), the carrier (how it's accessed) and the resolver (where it points now). Insulation labels may disappear on installation — project records should retain the product reference and declaration version. ### Article 80: when the passport becomes mandatory Mandatory application is linked to the act establishing the system, with an **18-month interval** after it enters into force. The CPR's general application date is not a construction DPP deadline. | Milestone | Status and significance | |---|---| | 7 January 2025 | Regulation entered into force | | 8 January 2026 | General application, subject to transitions | | System-establishing delegated act | Detailed arrangements — timetable **expected** | | 18 months after that act | Statutory passport application | | Product-family transition | Assess against specifications and transitional rules | ### BIM: reference the product, preserve the building context Store the product identifier, installed quantity, location and declaration version in the project environment, linking to authoritative product information. Owners may need what was declared at installation, not only what is published today. ### EPDs and EN 15804 EN 15804 EPDs provide structured environmental data, but an existing EPD should not automatically be treated as satisfying the new CPR's environmental declaration requirements. Map every indicator, calculation rule and verification step before reuse. ### National building passports and Level(s) A product passport is not a building passport, renovation passport or digital building logbook. Level(s) is the Commission's building sustainability framework — six macro-objectives and sixteen indicators — not a product-passport scheme. [2](https://environment.ec.europa.eu/topics/circular-economy/levelsold/quick-introduction-levels_en) The relationship is a chain: product evidence → project quantities → building assessment → building records. ### What manufacturers should do now - Inventory declarations, technical documentation, instructions, identifiers and environmental datasets - Assign owners and fix inconsistent product references - Pilot a full journey: manufacture, sale, specification, installation, maintenance, recovery - Involve a designer, contractor and downstream user — not just your own portal - Prioritise durable identification and demonstrable portability over an **expected** schema ### Sources - https://eur-lex.europa.eu/eli/reg/2024/3110/oj/eng - https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng - https://environment.ec.europa.eu/topics/circular-economy/levelsold/quick-introduction-levels_en - https://environment.ec.europa.eu/topics/circular-economy/levels/start-using-levels_en ## DPP Enforcement, Penalties and Customs: What Happens When a Passport Is Missing? > DPP enforcement combines product-specific duties, market surveillance, customs verification and national penalties rather than a single EU-wide fine. ### Begin with applicability, not the size of the fine A missing DPP is not automatically an infringement for every product. Under the ESPR, passport obligations depend on product-specific measures and their dates; Article 9 links market access to those requirements. [1](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng) First questions: - Is the product within an applicable measure? - Has the obligation started applying? - Does an exemption or transition apply? - Is the passport required at model, batch or item level? - Which operator placed the product on the market? A product group in a working plan is not an applicable obligation; unadopted measures are **expected**. ### The enforcement architecture The ESPR sets obligations; Regulation (EU) 2019/1020 provides market surveillance and external-border controls; customs and market-surveillance authorities have distinct roles; Member States set penalties. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A32019R1020) A passport helps authorities retrieve information — it does not replace inspection, sampling or testing, and it does not prove the goods match it. ### Market surveillance under Regulation 2019/1020 Authorities can obtain documents, inspect products, run checks and require corrective action, online and offline. For passports, a review could check: 1. The physical carrier is present and readable 2. The identifier matches the actual product 3. Required information is complete 4. Authorised actors can access what they should 5. Evidence substantiates declared values 6. The information stays available as required ### ESPR Article 15: customs verification through the registry For covered imports, the unique registration identifier must be made available to customs and checked against the DPP registry, with electronic verification via customs systems. | Identifier | Purpose | |---|---| | Product identifier | Identifies the model, batch or item | | Economic-operator identifier | Identifies the business | | Facility identifier | Identifies a production facility where required | | Registry registration identifier | Supports registry/customs verification | The registry is not a central copy of every passport document. #### A successful registry check is not a conformity certificate A valid reference can coexist with wrong passport content or a non-conforming product. Importers should reconcile customs reference, product identifier and shipping documents before dispatch. ### What happens when a passport is missing or defective? Once an obligation applies, a missing passport can block lawful market access. Authorities may require correction, restrict availability or order withdrawal. | Failure | Likely compliance issue | |---|---| | No passport exists | Required information infrastructure absent | | Carrier does not resolve | Information not accessible | | Passport belongs to another product | Identity and traceability failure | | Required fields missing | Incomplete information | | Public data works, authority access fails | Access-rights or availability failure | | Values unsupported or false | Substantive evidence failure | Under Regulation 2019/1020, customs release can be suspended in specified cases. Release for free circulation is not proof of conformity. ### ESPR Article 74: penalties Article 74 requires Member States to set **effective, proportionate and dissuasive** penalties. There is **no single EU fine or turnover percentage**. Authorities must consider: - Nature, gravity and duration of the infringement - Intent or negligence - Financial situation of the responsible person - Economic benefit gained - Environmental damage - Mitigation or remedial action - Repeat infringements - Other aggravating or mitigating factors Member States must at least be able to impose **fines** and **time-limited exclusion from public procurement**. Commercial disruption can exceed the fine itself. Check national law for actual figures. ### Battery passports and battery penalties Under Regulation (EU) 2023/1542 Article 77, the passport applies from **18 February 2027** to LMT, industrial >2 kWh and EV batteries — an adopted obligation, not an expected one. [3](https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng) Article 93 again leaves penalties to Member States. Postponement of other battery duties (such as due diligence) does not move the passport date. ### Who is responsible? #### Manufacturers Primary obligations (ESPR Article 27). Buying passport software does not transfer them to the vendor. #### Importers and distributors Own verification and cooperation duties (Articles 29 and 30). Check applicability, identity, access and documentation before shipment. #### Authorised representatives and EU-based operators Article 36 requires an EU-based economic operator for covered products, linked to Regulation 2019/1020 — an EU manufacturer, importer, authorised representative or fulfilment service provider. Map responsibilities explicitly; the passport host is not automatically the responsible operator. ### Online marketplaces are not outside the system Article 35 obliges online marketplaces to cooperate with authorities alongside the Digital Services Act. Test the third-party listing journey: passport access must not disappear off your own website. ### Build an enforcement-ready evidence pack 1. Applicability assessment and dates 2. Identity mapping between product, passport and registry 3. Carrier and access test results 4. Declarations and supporting evidence 5. Named operator responsibilities 6. Service-continuity and correction procedures 7. A contact process for authorities and marketplaces ### Sources - https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng - https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A32019R1020 - https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng ## Electronics and ICT DPP: Existing Product Rules and the Next Data Layer > A detailed guide to smartphone ecodesign, energy labels, repairability, right to repair, WEEE and the expected role of digital product passports. ### Electronics already has substantial product-data obligations For electronics manufacturers, the starting point is not an empty regulatory landscape awaiting a digital product passport. Smartphones and slate tablets already face ecodesign and energy-labelling requirements, while repair, waste, chemicals and consumer-law obligations operate alongside them. The key distinction is between **rules already applying** and **expected ESPR measures**. A product’s EPREL entry, energy-label QR code, service portal and future DPP may connect to overlapping evidence, but they are not interchangeable legal instruments. The Commission’s ESPR working plan addresses electronics through existing energy-related-product work and expected horizontal measures, including repairability and recyclability. It does not establish one immediate, universal DPP deadline for every ICT product. [1](https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en) ### Regulation 2023/1670: what has applied since June 2025 Commission Regulation (EU) 2023/1670 applies from **20 June 2025** to covered smartphones, other mobile phones, cordless phones and slate tablets placed on the EU market. Energy labelling applies from the same date to smartphones and slate tablets, under the separate labelling measure. Product definitions and exclusions matter: a slate tablet is not automatically the same regulatory category as a tablet computer running a desktop-style operating system. [1](https://energy-efficient-products.ec.europa.eu/product-list/smartphones-and-tablets_en) The regulation addresses durability, battery endurance, disassembly, spare parts, repair information and software support. These are market-access requirements, not optional features that manufacturers can replace with a sustainability statement. The Commission summarises the principal requirements as follows. Exact application depends on the product category and detailed annex provisions. [3](https://single-market-economy.ec.europa.eu/news/new-eu-rules-durable-energy-efficient-and-repairable-smartphones-and-tablets-start-applying-2025-06-20_en) | Area | Main requirement or regulatory direction | Evidence to retain | |---|---|---| | Battery durability | At least 800 charge cycles with at least 80% remaining capacity for covered smartphones and slate tablets | Test reports and conditions | | Physical durability | Requirements addressing drops, scratches, dust and water | Category-specific test evidence | | Spare parts | Specified parts available for at least seven years after model sales end | Parts catalogue and availability records | | Delivery | Relevant parts supplied within five to ten working days, as applicable | Order and delivery performance | | Software | Operating-system support requirements extending beyond model market availability | Support policy and release records | | Repair access | Non-discriminatory access to necessary software or firmware for professional repairers | Access process and technical documentation | #### Seven years does not mean “seven years from launch” The spare-parts clock is linked to the end of placing the model on the market, not simply the product announcement. A model sold for several years can therefore create a service obligation extending substantially beyond its launch anniversary. Manufacturers should establish a controlled “end of placement on the market” date and identify who can approve it. Procurement, service and compliance teams need the same reference date; otherwise spare-parts contracts may expire before the legal obligation does. #### Software commitments need precise wording The regulation’s software provisions should not be simplified into a promise that every device receives every future operating-system feature. The relevant obligations distinguish update types and prescribe conditions and time periods. For passport readiness, record update availability, support endpoints, relevant compatibility restrictions and the applicable policy version. Avoid a single unsupported “supported until” field that merges security updates, corrective updates and major feature upgrades. ### Energy labels and EPREL The smartphone and slate-tablet energy label adds more than an electricity-efficiency class. It communicates battery endurance per cycle, battery endurance in cycles, repeated-free-fall reliability, ingress protection and a repairability class. Its QR code links to the product’s information in EPREL, the European Product Registry for Energy Labelling. [1](https://energy-efficient-products.ec.europa.eu/product-list/smartphones-and-tablets_en) Suppliers must manage model registration and the required product information; dealers have display duties for physical and online sales. An energy label is therefore part of a regulated information chain from manufacturer or importer through retail presentation. EPREL is principally model-level infrastructure. A future DPP may need different granularity and lifecycle information. An individual handset’s replacement battery, repair history or refurbished status is not automatically captured by its model’s energy-label entry. The practical objective should be **consistent identifiers and evidence reuse**, not an assumption that an EPREL registration already constitutes a DPP. ### Understanding the EU repairability index The repairability class uses an **A–E scale**, distinct from the energy-efficiency scale. Its calculation considers factors such as disassembly, fasteners, tools, spare parts, software support and repair information. The result is a regulated model assessment, not a consumer satisfaction rating or a guarantee of a particular repair price. [1](https://energy-efficient-products.ec.europa.eu/product-list/smartphones-and-tablets_en) A strong compliance file should allow an assessor to reconstruct the result: - Which priority parts were evaluated? - What disassembly sequence and tools were assumed? - Which fasteners are reusable? - What repair information was available? - What spare-parts and software commitments support the score? Do not substitute a national repairability index or a private platform score for the EU class. Different methods can produce different outcomes without either result being arithmetically wrong. For DPP planning, store the score’s inputs, method version and evidence links. A letter alone is not sufficient for future verification or product redesign. ### Right to repair: the consumer-service layer Directive (EU) 2024/1799 had to be transposed and applied by Member States from **31 July 2026**. It complements ecodesign: product rules determine relevant repairability requirements, while the directive creates consumer-facing repair obligations for covered goods listed in its Annex II. It is not an unconditional right to repair every electronic device indefinitely. [1](https://commission.europa.eu/law/law-topic/consumer-protection-law/directive-repair-goods_en) For covered products, manufacturers must provide repair within a reasonable time and at a reasonable price, subject to the directive’s conditions. Rules also address unjustified contractual, hardware and software barriers to repair, and access to reasonably priced spare parts. Within the legal guarantee framework, choosing repair rather than replacement triggers an extension of the seller’s liability period by at least **12 months**, under the applicable national implementation. This should not be described as a universal new manufacturer warranty on every out-of-warranty repair. [2](https://eur-lex.europa.eu/eli/dir/2024/1799/oj/eng) A manufacturer therefore needs more than downloadable repair manuals. It needs an operational service route: responsibility allocation, diagnosis, quotations, parts logistics, repair completion and consumer communication. ### WEEE remains a separate compliance system The Waste Electrical and Electronic Equipment Directive governs collection and treatment responsibilities, producer registration, financing, reporting and relevant information and marking requirements. It remains separate from ecodesign, energy labelling and any expected DPP obligation. A passport could help treatment operators identify components and disassembly steps. It does not replace national producer registrations or prove that required collection and recycling finance has been provided. Companies should distinguish three records: 1. **Product design evidence:** what the equipment contains and how it can be dismantled. 2. **Market-placement records:** what quantities were supplied in each jurisdiction. 3. **Waste-management evidence:** what collection and treatment obligations were fulfilled. These records can connect through identifiers, but their quantities, responsible entities and legal retention requirements are not necessarily identical. The governing WEEE framework is Directive 2012/19/EU. ### Expected ESPR horizontal measures The working plan schedules horizontal repairability work, including scoring, indicatively for **2027**, and recyclability and recycled-content work for electrical and electronic equipment indicatively for **2029**. These are **expected adoption milestones**, not application dates or final technical requirements. [1](https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en) Future measures must interact with existing product rules. A business should not assume that a horizontal score will automatically replace smartphone-specific requirements, or that every electronics category will need identical passport attributes. The most robust preparation is modular: maintain shared identity and evidence infrastructure, while allowing different product categories to expose different mandatory information. ### Expected electronics DPP data and access The following is a recommended preparation structure, not an adopted universal electronics field list. | Expected data area | Practical content | |---|---| | Product identity | Model, variant, responsible operator and relevant identifiers | | Compliance | Declarations, regulated classes and evidence references | | Repair | Parts compatibility, disassembly steps, tools and service routes | | Software | Update policy, support dates and necessary repair software access | | Materials | Relevant material and substance information | | Circularity | Reuse, refurbishment, dismantling and recycling guidance | | Lifecycle events | Repairs and component changes where appropriate | | Environmental evidence | Method-specific footprint or resource information where required | Public information should be separated from restricted repair or authority evidence. Device user data should not become passport content by default. Ownership changes, repair records and data-erasure confirmation require careful privacy and security design. CIRPASS-2’s electronics pilots test precisely these operational questions, including repair, second-hand IT, maintenance and end-of-use recovery. They are demonstrations, not legal certification schemes. [2](https://cirpass2.eu/lighthouse-pilots/) ### Implementation checklist - Classify products using the exact regulatory definitions. - Maintain evidence for the ecodesign requirements already applying. - Reconcile energy-label values with EPREL and technical files. - Document repairability calculations and inputs. - Track the correct spare-parts and software-support reference dates. - Review national implementation of the right-to-repair directive. - Keep WEEE registration and reporting separate from passport development. - Pilot a repairer retrieving information without manufacturer intervention. - Design lifecycle records without exposing personal device data. - Label unadopted ESPR requirements as expected. - Require persistent access, versioning and export from DPP providers. ### Sources - https://energy-efficient-products.ec.europa.eu/product-list/smartphones-and-tablets_en - https://eur-lex.europa.eu/eli/reg/2023/1670/oj - https://eur-lex.europa.eu/eli/reg_del/2023/1669/oj - https://single-market-economy.ec.europa.eu/news/new-eu-rules-durable-energy-efficient-and-repairable-smartphones-and-tablets-start-applying-2025-06-20_en - https://commission.europa.eu/law/law-topic/consumer-protection-law/directive-repair-goods_en - https://eur-lex.europa.eu/eli/dir/2024/1799/oj/eng - https://eur-lex.europa.eu/eli/dir/2012/19/oj - https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en - https://cirpass2.eu/lighthouse-pilots/ ## EU Battery Passport: A Field-by-Field Guide to Annex XIII > A practical guide to battery passport data fields, access rights, lifecycle updates, phased sustainability requirements and implementation readiness. ### The battery passport is an individual-battery record From **18 February 2027**, electric-vehicle batteries, light means of transport batteries and industrial batteries with capacity greater than 2 kWh must have a battery passport when placed on the EU market or put into service. Article 77 of Regulation (EU) 2023/1542 establishes the obligation; Annex XIII specifies its information categories. This is not a universal passport requirement for every portable or starter battery. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542) The passport combines information about the **battery model** with information about the **individual battery**. A QR code connects the physical battery to its unique identifier and electronic record. The responsible economic operator must ensure that information is accurate, complete and up to date. A critical implementation distinction is that the passport’s launch does not accelerate every underlying sustainability obligation. Carbon-footprint declarations, recycled-content documentation and due-diligence reporting have their own application rules. The Commission’s October 2026 guidance explicitly distinguishes fields required at launch from information that is conditional or not yet required to be displayed. [1](https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en) ### Annex XIII: public model-level information The following table covers every lettered category in Annex XIII, section 1. “Static” and “dynamic” are implementation descriptions, not separate legal classifications. Static information still needs version control when specifications or supporting documents change. All fields below are publicly accessible under Annex XIII; applicability remains subject to battery category and the underlying provision. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542) | Field | Required information | Typical update pattern | |---|---|---| | 1(a) | Annex VI, Part A general battery information | Mostly static | | 1(b) | Material composition: chemistry, hazardous substances other than mercury, cadmium or lead, and critical raw materials | Static by model/version | | 1(c) | Article 7 carbon-footprint information and performance class | Versioned as applicable | | 1(d) | Responsible-sourcing information from the Article 52(3) due-diligence report | Periodic | | 1(e) | Article 8 recycled-content information | Periodic/model-plant-year | | 1(f) | Share of renewable content | Versioned | | 1(g) | Rated capacity, in Ah | Static baseline | | 1(h) | Minimum, nominal and maximum voltage, including relevant temperature ranges | Static baseline | | 1(i) | Original power capability, limits and relevant temperature range | Static baseline | | 1(j) | Expected lifetime in cycles and reference test | Static baseline | | 1(k) | Capacity threshold for exhaustion, for EV batteries | Static baseline | | 1(l) | Non-use temperature range and reference test | Static baseline | | 1(m) | Commercial warranty period for calendar life | Versioned terms | | 1(n) | Initial round-trip efficiency and efficiency at 50% of cycle life | Model/test information | | 1(o) | Internal cell and pack resistance | Model baseline | | 1(p) | C-rate used in the relevant cycle-life test | Static test metadata | | 1(q) | Applicable separate-collection and chemical-symbol markings | Versioned compliance information | | 1(r) | EU declaration of conformity | Versioned document | | 1(s) | Article 74(1)(a)–(f) waste-prevention and management information | Periodically reviewed | #### Unpacking the incorporated fields Field 1(a) incorporates more than a product name. Annex VI, Part A covers manufacturer identification, battery category and identification, place and date of manufacture, weight, capacity, chemistry, specified hazardous substances, suitable extinguishing agents and critical raw materials above the relevant concentration threshold. These should be structured attributes, not buried in an unsearchable label image. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542) Similarly, field 1(s) incorporates instructions on waste prevention and life extension; users’ contribution to separate collection; available collection, reuse and recycling arrangements; safety when handling waste batteries; the meaning of markings; and the environmental, health and safety implications of substances in batteries. The passport therefore needs both **machine-readable values** and understandable instructions. A numerical capacity field cannot substitute for safe waste-handling guidance. ### Restricted model information and individual-battery data Annex XIII creates distinct access groups. Public visibility must not be confused with access for a repairer, recycler or authority. The following table covers sections 2–4 and their update characteristics. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542) | Field | Information | Access group | Update pattern | |---|---|---|---| | 2(a) | Detailed composition, including cathode, anode and electrolyte materials | Persons with a legitimate interest | Model/version | | 2(b) | Component part numbers and contact details for sources of replacement parts | Persons with a legitimate interest | Periodic | | 2(c) | Dismantling information, including diagrams, disassembly sequences, fastenings, tools and warnings | Persons with a legitimate interest | Model/version | | 2(d) | Safety measures | Persons with a legitimate interest | Periodic | | 3 | Test-report results proving compliance with the Regulation or relevant delegated or implementing acts | Notified bodies, market-surveillance authorities and Commission | Versioned evidence | | 4(a) | Performance and durability values when placed on the market and following changes in status | Persons with a legitimate interest | Baseline plus events | | 4(b) | State-of-health information under Article 14 | Persons with a legitimate interest | Dynamic | | 4(c) | Battery status: original, reused, repurposed or remanufactured, or waste | Persons with a legitimate interest | Event-driven | | 4(d) | Use-related information: cycles, negative events, operating conditions and charging history | Persons with a legitimate interest | Dynamic | “Legitimate interest” is not a licence to expose all restricted data to anyone who registers an account. Operators need a documented access policy aligned with applicable implementing rules, purpose limitations and confidentiality protections. Dynamic information also requires interpretation. A state-of-health value without its timestamp, measurement method and battery identity is difficult to use safely. Retain the original baseline separately from subsequent measurements rather than overwriting history. ### Carbon-footprint phase-in under Article 7 Article 7 separates **declarations**, **performance classes** and **maximum thresholds**. The statutory dates below are earliest dates, not unconditional application dates: the Regulation also links application to the entry into force of the relevant secondary legislation. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542) | Battery category | Declaration: earliest date | Performance class: earliest date | Maximum threshold: earliest date | |---|---|---|---| | EV | 18 February 2025 | 18 August 2026 | 18 February 2028 | | Rechargeable industrial, over 2 kWh, excluding exclusively external storage | 18 February 2026 | 18 August 2027 | 18 February 2029 | | LMT | 18 August 2028 | 18 February 2030 | 18 August 2031 | | Rechargeable industrial, over 2 kWh, with exclusively external storage | 18 August 2030 | 18 February 2032 | 18 August 2033 | Declaration requirements apply on the relevant date **or 12 or 18 months after the relevant acts enter into force**, depending on category, whichever is later. Performance classes generally use an 18-month secondary-legislation condition; maximum thresholds use 18 months for EV batteries and generally 24 months for the other listed categories. Consequently, a compliance calendar must track the adopted methodology and implementing format, not merely copy the earliest dates into a spreadsheet. Requirements dependent on secondary legislation not finally adopted remain **expected**, not operationally settled. ### Recycled-content phase-in under Article 8 For relevant industrial batteries above 2 kWh, EV batteries and SLI batteries containing cobalt, lead, lithium or nickel, recycled-content documentation starts from **18 August 2028**, or 24 months after the relevant delegated act enters into force, whichever is later. The initial documentation requirement excludes industrial batteries with exclusively external storage. LMT documentation starts from **18 August 2033**. [2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542) Minimum shares for covered batteries are: | Application date | Cobalt | Lead | Lithium | Nickel | |---|---:|---:|---:|---:| | 18 August 2031: covered industrial, EV and SLI batteries | 16% | 85% | 6% | 6% | | 18 August 2036: covered industrial, EV, SLI and LMT batteries | 26% | 85% | 12% | 15% | The percentages concern the relevant recovered materials in active materials, not a single percentage of total battery weight. Supplier evidence must preserve the material-specific denominator and calculation basis. Battery due-diligence obligations were separately postponed to **18 August 2027**. That postponement should not be mistaken for a postponement of the February 2027 passport obligation. [4](https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng) ### DIN DKE SPEC 99100 and the Battery Pass themes **DIN DKE SPEC 99100:2025-02** provides a detailed attribute framework. It is useful implementation guidance, not an alternative legal source or automatic proof of EU compliance. Battery Pass notes that its earlier guidance and longlist were updated to align with the specification. [3](https://thebatterypass.eu/assets/images/content-guidance/pdf/DIN_DKE_SPEC_99100.PDF) Battery Pass organises attributes into seven themes: general battery and manufacturer information; compliance, labels and certifications; carbon footprint; supply-chain due diligence; materials and composition; circularity and resource efficiency; and performance and durability. These themes provide a practical ownership structure across legal, engineering, procurement and service teams. [1](https://thebatterypass.eu/wp-content/uploads/q-a_content-guidance_4.pdf) ### What real implementations demonstrate Volvo’s EX90 passport, developed with Circulor, illustrates an early production implementation combining material traceability and carbon information with QR-based access. Volvo describes access through a code inside the vehicle’s B-pillar. It is evidence that passport infrastructure can operate before mandatory application—not proof that every future regulatory requirement was already satisfied. [2](https://www.volvocars.com/fr-ch/news/technology/la-volvo-ex90-inaugure-le-passeport-batterie/) Battery Pass’s demonstrator and attribute work offer a different implementation lesson: interoperability requires common definitions, access rules and update processes, not merely an attractive consumer page. ### Implementation checklist - Confirm battery category, capacity and responsible economic operator. - Map every Annex XIII field, including incorporated annexes and articles. - Mark conditional fields with their legal trigger. - Separate model, manufacturing-batch and individual-battery records. - Preserve baseline values and timestamp dynamic updates. - Implement access controls before loading confidential information. - Connect supplier evidence to carbon and recycled-content calculations. - Test QR durability, identifier persistence and exportability. - Plan responsibility transfers for reuse, repurposing and remanufacturing. - Validate against the latest Commission guidance and adopted secondary acts. ### Sources - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542 - https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng - https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en - https://thebatterypass.eu/assets/images/content-guidance/pdf/DIN_DKE_SPEC_99100.PDF - https://thebatterypass.eu/wp-content/uploads/q-a_content-guidance_4.pdf - https://www.volvocars.com/fr-ch/news/technology/la-volvo-ex90-inaugure-le-passeport-batterie/ ## Nine Real Digital Product Passport Implementations and Pilots: What the Evidence Shows > Nine documented initiatives show how product passports support traceability, repair and circular business models, while revealing where measured results are still unavailable. ### Read case studies without confusing deployment and proof DPP case studies vary in maturity: some are production systems on commercial products, others are technical demonstrators or funded pilots. A working passport proves information can be assembled and accessed; it does not prove more recycling, lower emissions or profitable resale. Below, implemented functionality is separated from measured outcomes. Where sources state objectives without quantified results, benefits are labelled **expected**. CIRPASS-2 runs thirteen pilots across textiles, electronics, tyres and construction, with cross-pilot interoperability among its goals. [1](https://cirpass2.eu/lighthouse-pilots/) ### 1. Volvo Cars and Circulor — production battery passports Volvo and Circulor introduced a battery passport for the EX90 electric SUV covering raw-material origins, components, recycled content and embedded carbon, accessible via the Volvo Cars app and a QR code on the vehicle. [2](https://circulor.com/articles/worlds-first-battery-passport) [3](https://www.volvocars.com/fr-ch/news/technology/la-volvo-ex90-inaugure-le-passeport-batterie/) **Result:** a commercial deployment with consumer-accessible battery information. **Limitation:** no source shows a measured lifecycle-emission reduction caused by the passport. "World's first" is the company's claim. ### 2. Battery Pass — an interoperable demonstrator The German-funded consortium of eleven organisations released technical guidance and a software demonstrator in March 2024, making distributed data, identifiers, access and interoperability tangible. [4](https://thebatterypass.eu/wp-content/uploads/EN_Press-Release_Battery-Pass-Consortium-Publishes-Technical-Guidance.pdf) **Result:** guidance and demonstrator software, presented again at the February 2025 closing event. **Limitation:** not a regulatory approval or production-readiness certificate. [5](https://thebatterypass.eu/assets/closing/presentations/2.2%20From%20Concept%20to%20Demonstration.pdf) ### 3. IOXIO — circular workwear IOXIO leads CIRPASS-2's circular workwear pilot, targeting reuse, repair, remanufacture and recycling as garments move between users, laundries and repairers. [6](https://cirpass2.eu/category/lighthouse-pilots/) **Expected:** longer garment life and better recycling — no verified percentages yet. **Lesson:** attach the passport to a repeatable operational decision, not just the first sale. ### 4. Kezzler — connected garments and footwear Kezzler's pilot covers item-level connected-product management for garments and footwear, combining circular business models with DPP implementation. **Expected:** resale and engagement gains. **Lesson:** regulatory and commercial functions can share identity infrastructure — but legally required information should never depend on joining a loyalty programme. ### 5. EON — scaling circular systems in fashion EON's pilot with a Top-20 global apparel brand focuses on resale, repair and recycling, including downstream events flowing back into item records. **Expected:** more circular transactions. **Lesson:** can downstream businesses retrieve and interpret data without adopting the brand's whole tech stack? ### 6. Avery Dennison atma.io and circular.fashion — Textile Loop The Textile Loop pilot targets sorting and repair/upcycling — information must arrive where sorting decisions happen. **Expected:** better sorting accuracy and recovery. Useful metrics: carrier survival, scan time, completeness of material data, share of items routed to higher-value outcomes. ### 7. TripleR.io — MattressID MattressID addresses mattress refurbishment and recycling. **Expected:** higher refurbishment and recycling. **Lesson:** separate static manufacturer data from condition assessment at collection — a passport can't remotely judge hygiene or damage. ### 8. Scantrust — DPP feasibility for textile SMEs Scantrust's pilot aims to show textile SMEs can issue passports affordably and improve circular economics. **Expected:** positive economics. Measure onboarding time, data-cleaning effort, recurring admin and provider dependence — not just carrier price. ### 9. Arçelik/Beko — preventing incorrect vacuum-cleaner repairs Arçelik's pilot uses DPP traceability to prevent incorrect repairs of cordless vacuum cleaners, reducing e-waste. **Expected:** less e-waste. Track first-time repair success, wrong-part orders, repeat visits and products returned to use. ### What these cases collectively establish | Evidence category | Examples | Reasonable conclusion | |---|---|---| | Commercial implementation | Volvo / Circulor | Product-linked information can reach customers in production | | Technical demonstrator | Battery Pass | Architecture and interoperability approaches can be implemented | | Operational pilots | Seven CIRPASS-2 cases | Defined circular workflows are being tested | | Quantified environmental impact | Not yet established | Further measurement is needed | **The common lesson:** choose a decision to improve, identify the data that decision needs, and measure the result. Passport issuance counts alone are a weak proxy for circularity. ### Sources - https://cirpass2.eu/lighthouse-pilots/ - https://cirpass2.eu/category/lighthouse-pilots/ - https://cirpass2.eu/category/textiles/ - https://circulor.com/articles/worlds-first-battery-passport - https://www.volvocars.com/fr-ch/news/technology/la-volvo-ex90-inaugure-le-passeport-batterie/ - https://thebatterypass.eu/wp-content/uploads/EN_Press-Release_Battery-Pass-Consortium-Publishes-Technical-Guidance.pdf - https://thebatterypass.eu/assets/closing/presentations/2.2%20From%20Concept%20to%20Demonstration.pdf ## Steel and Aluminium DPP: Carbon Evidence, CBAM and Circular Material Data > How steel and aluminium producers can prepare for expected ESPR passports while keeping CBAM, product footprints, recycled content and low-carbon claims technically distinct. ### Why metals are a priority Iron and steel and aluminium are priority intermediate products in the Commission’s **2025–2030 ESPR working plan**. The indicative adoption timetable is **2026 for iron and steel** and **2027 for aluminium**. These are **expected policy milestones**, not proof that a final passport field list or market application date already exists. [1](https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en) Their inclusion reflects metals’ environmental significance and their influence on downstream products. A material producer’s data can affect the footprint and circularity claims of vehicles, machinery, appliances and buildings. For these sectors, the digital product passport problem is less about creating a consumer-facing page and more about preserving reliable evidence through complex transformations: slabs become coils, billets become extrusions, coils become parts, and scrap returns through different production routes. The central task is to connect **physical material identity**, **production evidence** and **method-specific environmental information** without pretending that one carbon number satisfies every regulatory purpose. ### Separate the regulatory layers A metals business may face several overlapping information requests. | Instrument or system | Primary purpose | Why it is not interchangeable with a DPP | |---|---|---| | ESPR product measures | Product sustainability and information requirements | Final metal-specific obligations depend on adopted measures | | CBAM | Carbon-price adjustment for covered imports | Uses its own scope, emissions rules and customs responsibilities | | EU ETS | Installation-level emissions and carbon pricing | Installation data is not automatically a product footprint | | Product carbon footprint | Climate impact attributed to a product | Depends on boundary, allocation and methodology | | Environmental product declaration | Structured lifecycle environmental disclosure | Usually covers more than climate change | | Mill or inspection certificate | Material specification and test evidence | Does not by itself establish environmental performance | | Private low-carbon label | Scheme-defined performance communication | Thresholds and verification differ between schemes | The expected ESPR passport should connect these records where useful. It should not merge their legal meanings. A steel inspection certificate may confirm grade and mechanical properties for a heat or batch. A footprint may cover a production route and reporting period. A CBAM declaration concerns imported goods and embedded emissions under its own rules. Mapping among them requires explicit assumptions. ### CBAM’s definitive phase began in 2026 The definitive CBAM regime applies from **1 January 2026**. For covered goods, importers or their indirect customs representatives must assess authorisation, embedded-emissions declarations and certificate obligations. Under the simplified regime, a **single annual mass-based threshold of 50 tonnes** applies to relevant covered imports; it is not a universal exemption for all CBAM sectors or a threshold assessed separately for every shipment. [1](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en) Steel and aluminium coverage is determined by the regulation’s commodity codes and conditions. “Contains steel” is not sufficient to conclude that a product is covered, while a downstream-looking product may still fall within a listed code. For 2026 imports, certificate purchases begin from **February 2027**. The first annual declarations and corresponding certificate surrender are due by **30 September 2027** under the amended timetable. This distinction matters for budgeting: financial exposure arises from 2026 imports even though purchases and annual settlement occur later. [3](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-communication-and-news_en) Certificate prices use quarterly EU ETS auction-price averages for 2026 and weekly averages from 2027. Carbon prices effectively paid in the country of production can be relevant to deductions, subject to the applicable evidence rules. [4](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en) #### What a passport can contribute A passport-ready data system can preserve installation identity, production-route information, reporting periods, precursor data and verification references. This can reduce repeated supplier questionnaires. However, a supplier’s “DPP carbon footprint” is not automatically a valid CBAM emissions figure. The importer must still ensure that the value meets the applicable CBAM methodology and verification requirements. ### Carbon methodologies: the boundary is part of the result A meaningful carbon value needs more than a number and a unit. At minimum, record: - The product and declared unit. - System boundary and included production stages. - Reporting period and geographical coverage. - Production route and relevant electricity treatment. - Precursor and other upstream inputs. - Allocation rules for co-products and scrap. - Primary versus secondary data. - Verification status and methodology version. For example, a tonne of crude steel at the steelworks gate is not the same declared product as a tonne of coated coil after rolling, annealing and coating. Comparing their values without adjustment can reward an incomplete boundary rather than a genuinely lower-emission product. #### Steel-specific issues Steel footprints are sensitive to the production route, ore and metallic inputs, coke and other reductants, fuel use, electricity and finishing operations. Electric-arc-furnace steel is not inherently zero-carbon: the metallic charge, grid mix, electrodes, fuels and upstream production remain relevant. Hydrogen-based direct reduced iron also requires evidence about hydrogen production and electricity. “Hydrogen-ready” equipment describes technical capability, not demonstrated emissions performance for a particular delivery. #### Aluminium-specific issues Primary aluminium’s footprint can be strongly affected by electricity used in smelting, as well as alumina refining, anode consumption and process emissions. Remelting scrap generally avoids many primary-production stages, but the resulting footprint still depends on collection, preparation, metal yield, alloy additions and energy. A low-emission smelter does not automatically establish the footprint of a finished extrusion. Billet casting, transport, extrusion, heat treatment and surface finishing may need inclusion depending on the declared boundary. Recognised frameworks such as ISO 14067 and lifecycle-based product rules can support product-carbon accounting, while construction EPDs commonly use EN 15804. None should be assumed to replace the specific methodology ultimately adopted under ESPR. ### Recycled content: distinguish the physical flow from the claim Recycled content is commercially important, but an unqualified percentage can obscure major differences: - Pre-consumer versus post-consumer scrap. - Purchased scrap versus internal process returns. - Physical segregation versus controlled blending. - Product-specific measurement versus site-level allocation. - Mass-balance accounting versus physical content. These distinctions should be stored as separate attributes, not compressed into a single “circularity” field. Internal scrap loops require particular care. Material that never leaves an integrated production process may receive different treatment from recovered scrap under a given standard. A company should not count the same loop repeatedly to inflate a recycled-content claim. For aluminium, alloy compatibility and contamination affect whether recovered material can return to an equivalent application. For steel, residual elements can constrain certain high-quality applications. A high recycled-content percentage therefore does not alone establish suitability, recyclability or closed-loop performance. An expected DPP should support evidence about material quality and recovery routes as well as quantity. Exact mandatory content definitions and thresholds remain **expected until established in final applicable measures**. ### Low-carbon steel labels: useful, but not a universal legal grade The Commission’s 2025 Steel and Metals Action Plan identifies lead markets and demand for cleaner metals as policy priorities. It is a policy communication, not a certificate proving that a particular steel product qualifies as low-carbon. [2](https://single-market-economy.ec.europa.eu/publications/european-steel-and-metals-action-plan_en) The March 2026 Industrial Accelerator Act text is a **proposal**. Requirements depending on its final adoption remain **expected**, and businesses should not market a proposed EU framework as an already mandatory certification system. [1](https://single-market-economy.ec.europa.eu/document/download/9bc8eb85-4d43-4025-be7b-c86b9f3648ec_en) Private labels and buyer specifications can be useful, but their boundaries and thresholds vary. Some approaches account for scrap availability or distinguish production routes; others apply an absolute intensity threshold. A product can qualify under one scheme without qualifying under another. A defensible claim should therefore state the scheme, version, boundary, certified entity or product, verification status and applicable period. “Green steel” without that context is weaker than a specific verified emissions statement. ### Expected steel and aluminium DPP data The following is a readiness model, not a final mandatory field list. | Expected area | Recommended attributes | |---|---| | Identity | Producer, facility, product, grade and relevant batch or heat identifiers | | Technical specification | Composition, dimensions, applicable standards and certificate references | | Production | Route, relevant process stages and reporting period | | Climate | Value, unit, boundary, method, allocation and verification | | Circular inputs | Recycled-content categories, calculation method and evidence | | Substances | Relevant substances-of-concern information | | Downstream use | Processing constraints, joining or coating considerations where useful | | End of life | Sorting, separation and recycling guidance | | Compliance links | Relevant declarations, inspection records and scheme references | Granularity should follow the legal measure and practical traceability needs. A heat-level identifier cannot simply be carried unchanged through every split, blend and transformation without recording parent–child relationships. For example, a service centre cutting several coils into customer orders needs a way to preserve source-coil references. A remelter combining scrap streams needs a different model. Both may be valid, but they support different claims. ### Implementation checklist - Map products to ESPR workstreams and CBAM commodity codes separately. - Determine importer and authorised-declarant responsibilities. - Monitor annual covered-import volumes against the applicable threshold. - Collect installation and precursor data before year-end reporting. - Keep CBAM emissions distinct from lifecycle product footprints. - Record boundaries, units and methodology versions with every carbon value. - Define recycled-content categories and accounting rules. - Connect heat, cast, coil, billet and shipment identities. - Preserve evidence through cutting, blending and remelting. - Review low-carbon claims against the exact scheme used. - Design public and restricted data access separately. - Treat unadopted passport requirements as expected. - Test one real customer-to-producer evidence request end to end. The strongest preparation is not a premature declaration of “DPP compliance”. It is a traceable material-data system capable of producing the correct evidence for the correct legal or commercial purpose. ### Sources - https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en - https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en - https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-communication-and-news_en - https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en - https://taxation-customs.ec.europa.eu/document/download/013fa763-5dce-4726-a204-69fec04d5ce2_en - https://eur-lex.europa.eu/eli/reg/2023/956/oj - https://single-market-economy.ec.europa.eu/publications/european-steel-and-metals-action-plan_en - https://single-market-economy.ec.europa.eu/document/download/9bc8eb85-4d43-4025-be7b-c86b9f3648ec_en ## Textile and Apparel DPP: Rules, Expected Data and a Practical Readiness Plan > How the expected textile digital product passport connects with ecodesign, textile EPR, unsold-goods restrictions, labelling and substantiated sustainability claims. ### Start by separating adopted rules from expected requirements For fashion businesses, the digital product passport is best understood as part of a wider regulatory transition, not a standalone QR-code project. The Ecodesign for Sustainable Products Regulation, or ESPR, establishes the framework, but product-specific measures determine the actual requirements for a product group. The Commission’s **2025–2030 working plan** prioritises textiles, with a focus on apparel, and gives **2027 as the indicative adoption year** for the textile measure. This is an **expected adoption milestone**, not a universal 2027 deadline for every garment to carry a passport. Product scope, required fields, identifier granularity and application dates depend on the final measure. [1](https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en) Other obligations are already adopted. These include revised EU textile extended producer responsibility rules and the ESPR prohibition on destroying specified unsold apparel and footwear. Treating every initiative as “the DPP law” obscures their different duties and deadlines. ### What the JRC preparatory study actually establishes The Joint Research Centre’s preparatory study supplies evidence for possible ecodesign requirements, green public procurement criteria and revised EU Ecolabel criteria. It is not itself a delegated regulation. Its working documents identify options for consultation rather than final compulsory scores or thresholds. [2](https://susproc.jrc.ec.europa.eu/product-bureau/product-groups/467/home) The December 2025 third-milestone summary examines physical durability, maintenance, repairability, waste generation, recyclability and recycled content, environmental impacts, substances of concern and textile fragmentation. Its design options include information on robustness and recyclability, and information and performance requirements concerning recycled content. These are **expected policy directions**, not adopted product requirements. [1](https://susproc.jrc.ec.europa.eu/product-bureau/sites/default/files/2025-12/Textile-Prep-Study_3rd-Milestone_SUM_20251212.pdf) #### Durability is not one universal garment number A T-shirt, waterproof shell and knitted jumper fail in different ways. Relevant evidence may include dimensional stability, colour fastness, pilling, abrasion resistance and seam strength. The study’s product-category approach matters because a single undifferentiated “durability score” could hide unsuitable comparisons. For brands, the practical response is to preserve test methods and conditions alongside results. “Passed durability testing” is weak data if the record omits the standard, laboratory, sample construction and acceptance threshold. Test evidence must also be tied to the actual fabric and manufacturing version. #### Recyclability is a system property Fibre composition alone does not establish recyclability. Blends, coatings, elastane, trims, adhesives and contamination can affect sorting and recycling routes. A garment can be technically recyclable in a laboratory without a commercially accessible collection and processing route. A useful readiness exercise therefore records both material composition and construction details. It also distinguishes design potential from current infrastructure availability. Claims about recyclability should explain the relevant conditions rather than imply that every discarded item will actually become new fibre. ### Expected textile DPP data The following is a preparation model, **not a final EU field list**. Its categories reflect the study and the ESPR’s direction, while exact compulsory fields remain dependent on the final textile measure. [1](https://susproc.jrc.ec.europa.eu/product-bureau/sites/default/files/2025-12/Textile-Prep-Study_3rd-Milestone_SUM_20251212.pdf) | Expected data area | Useful preparation now | Main evidence risk | |---|---|---| | Identity | Product identifier, model, variant and responsible operator | Confusing style, colourway, batch and item | | Fibre composition | Percentages by component | Recording only the main fabric | | Recycled content | Material, percentage, origin and chain of custody | Confusing supplier certification with product allocation | | Durability | Test results and methods | Unsupported marketing descriptions | | Repair and care | Care instructions, repair guidance and service routes | Generic instructions unsuitable for the product | | Recycling | Construction, trims and relevant sorting information | Claiming universal recyclability | | Substances of concern | Applicable substance information and evidence | Treating a broad certificate as a complete chemical inventory | | Environmental information | Method, boundary, data sources and calculation date | Comparing incompatible footprints | | Circular events | Repair, resale or refurbishment records where relevant | Collecting personal data unnecessarily | Access rights also require design. Consumers may need composition and care information, while sorters need material and construction details. Authorities may require supporting evidence. A supplier’s commercially confidential recipe should not automatically become public merely because it supports a passport attribute. ### Textile EPR: adopted legislation with national implementation The revised Waste Framework Directive entered into force on **16 October 2025**. It introduces common requirements for textile and footwear EPR schemes, under which producers finance relevant collection and waste-management costs. Member States must establish schemes within **30 months**, while microenterprises receive an additional year under the specified arrangements. [2](https://environment.ec.europa.eu/news/revised-waste-framework-directive-enters-force-2025-10-16_en) This means a business needs a country-by-country producer-responsibility assessment. The relevant producer may be the brand, importer or distance seller, depending on the national market and legal definition. Existing national schemes do not disappear while EU harmonisation proceeds. EPR fees are to reflect environmental considerations through eco-modulation. However, a DPP does not automatically calculate fees, register a producer or satisfy reporting duties. It can provide reusable evidence—such as product category, composition and weight—if those attributes are mapped to the relevant scheme. A sensible architecture therefore keeps **product data** reusable while maintaining separate **market-placement and EPR reporting records**. The number of garments manufactured is not necessarily the number placed on each national market. ### The unsold-goods destruction ban is already applying From **19 July 2026**, large enterprises are prohibited from destroying unsold clothes, clothing accessories and footwear covered by the ESPR ban. Medium-sized enterprises follow from **19 July 2030**; micro and small enterprises are generally exempt, subject to anti-circumvention provisions. The ban is independent of the future textile DPP measure. [2](https://environment.ec.europa.eu/news/ban-destruction-unsold-clothes-and-shoes-enters-application-2026-07-17_en) The Commission explains that businesses should prioritise sale, donation and preparation for reuse. Limited derogations exist, including specified safety, damage and intellectual-property circumstances, with evidence requirements. Two operational consequences follow: - **Returned stock needs assessment, not automatic disposal.** Record condition, repairability and alternative destinations. - **Recycling is not a universal escape route.** The ESPR’s destruction concept means businesses cannot assume that sending usable unsold garments for recycling avoids the prohibition. Passport infrastructure can help track stock disposition, but inventory controls and documented decision-making remain essential. ### Green claims: a passport does not legalise a claim Directive (EU) 2024/825 strengthens consumer protection against misleading environmental claims and unreliable sustainability labels. Member States were required to transpose it by 27 March 2026 and apply the measures from **27 September 2026**. Among its changes are restrictions on generic environmental claims without recognised excellent environmental performance and product climate-neutrality claims based on greenhouse-gas offsetting. [2](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng/pdf) For apparel, “sustainable”, “eco-friendly” and “climate neutral” therefore deserve specific legal review. A linked webpage containing a certificate is not necessarily sufficient substantiation for a broad claim. The separate Green Claims initiative must not be presented as an adopted directive imposing a universal pre-approval system. Additional requirements under that initiative remain **expected only if a final measure is adopted**. Existing unfair-commercial-practices rules already apply regardless of that initiative’s outcome. [3](https://www.consilium.europa.eu/en/policies/green-claims-empowering-consumers-for-more-sustainable-choices/) A sound data model separates the underlying fact—such as a verified recycled-fibre percentage—from the marketing sentence built around it. Legal approval should attach to the claim’s exact wording, geography and evidence version. ### Textile labelling revision: expected, not a QR-only replacement Regulation (EU) 1007/2011 remains the foundation for textile fibre names and composition labelling. The Commission’s review considers harmonisation, environmentally relevant information and digital labelling, alongside the practical problems caused by divergent national requirements. A final replacement regime should not be assumed from the review alone. [1](https://single-market-economy.ec.europa.eu/sectors/textiles-ecosystem/review-regulation-eu-10072011_en) Brands should not remove mandatory physical information simply because a digital passport exists. Develop a shared source of approved composition data that can feed physical labels, e-commerce pages and future DPP interfaces without assuming that those channels have identical legal requirements. ### What CIRPASS-2 pilots are testing CIRPASS-2 includes textile pilots covering circular workwear, connected garment management, sorting, repair and SME participation. Its published pilot portfolio demonstrates experimentation with operational circularity rather than a single fixed compliance template. [3](https://cirpass2.eu/category/textiles/) EON’s pilot works with an unnamed Top 20 global apparel brand and focuses on resale, repair and recycling, including downstream event information flowing back into item-level records. The project description does not justify inventing the brand’s identity or claiming that its data model is the final EU requirement. [1](https://cirpass2.eu/pa3-eon/) For brands, the strongest pilot question is practical: can a repairer, reseller or sorter retrieve the necessary information without manual email exchanges? Successful scanning alone is a weak success metric. ### Readiness checklist - Establish a register separating adopted obligations from expected textile requirements. - Map product identifiers across design, procurement, retail and returns. - Collect composition by component, including trims and coatings. - Tie recycled-content claims to product-specific evidence. - Store test methods and results, not just pass/fail labels. - Assess EPR obligations in every sales market. - Document unsold-stock decisions and applicable derogations. - Review environmental claims under the rules applying from September 2026. - Retain required physical labelling. - Pilot a real repair, resale or sorting workflow. - Require data export and supplier-independent access from technology providers. - Recheck the final textile measure before declaring compliance. ### Sources - https://environment.ec.europa.eu/document/download/5f7ff5e2-ebe9-4bd4-a139-db881bd6398f_en - https://susproc.jrc.ec.europa.eu/product-bureau/product-groups/467/home - https://susproc.jrc.ec.europa.eu/product-bureau/sites/default/files/2025-12/Textile-Prep-Study_3rd-Milestone_SUM_20251212.pdf - https://environment.ec.europa.eu/news/revised-waste-framework-directive-enters-force-2025-10-16_en - https://environment.ec.europa.eu/news/ban-destruction-unsold-clothes-and-shoes-enters-application-2026-07-17_en - https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng/pdf - https://single-market-economy.ec.europa.eu/sectors/textiles-ecosystem/review-regulation-eu-10072011_en - https://cirpass2.eu/pa3-eon/ ## The CEN/CENELEC DPP Standards: EN 18216, EN 18219–18223 and the Wider Framework > The European DPP standards provide an interoperable technical foundation, but their legal effect depends on Official Journal references and the requirements applicable to each product. ### The DPP standards have moved beyond the draft stage As of November 2026, it is no longer accurate to describe the first generation of European Digital Product Passport standards as forthcoming. CEN/CENELEC identifies eight standards developed by CEN-CLC/JTC 24, "Digital Product Passport — Framework and System." Six received harmonised references through Commission Implementing Decision (EU) 2026/1736, published on 15 July 2026. [1](https://eur-lex.europa.eu/eli/dec_impl/2026/1736/oj/eng) That does not mean every product sold in Europe already needs a DPP. Regulation (EU) 2024/1781 — the ESPR — establishes the framework. Product-specific measures determine information requirements, granularity, access rights and application dates. The standards address how passport systems identify products, exchange information and remain interoperable. [3](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng) The practical distinction is between **the passport's technical infrastructure** and **the regulated product information carried through it**. A technically interoperable passport can still contain inaccurate information; correct data behind a proprietary interface may still fail the technical requirements. ### What M/604 requested M/604 is the Commission's standardisation request supporting the DPP's horizontal technical infrastructure — Implementing Decision C(2024) 5423, amended by C(2025) 8024 — covering harmonised standards for ESPR Articles 10 and 11. [1](https://eur-lex.europa.eu/eli/dec_impl/2026/1736/oj/eng) A standardisation request is not itself a standard or a product obligation. CEN/CENELEC describes the resulting framework as transverse and product-agnostic, designed to connect existing systems rather than force every industry onto one platform. Interoperability — not a vendor, blockchain or database — is the central implementation issue. [2](https://www.cencenelec.eu/news-events/news/2026/en-in-the-spotlight/2026-07-15-dpp/) ### What each standard covers | Standard | Published scope | Implementation question | |---|---|---| | EN 18216:2026 | Data exchange protocols | How do systems communicate passport information? | | EN 18219:2026 | Unique identifiers | How are products and entities identified consistently? | | EN 18220:2026 | Data carriers | How does a physical product provide access to its passport? | | EN 18221:2026 | Storage, archiving and persistence | How does information remain available over the required period? | | EN 18222:2026 | APIs for lifecycle management and searchability | How do applications manage and discover passports? | | EN 18223:2026 | System interoperability | How do independently built systems work together? | | EN 18239 | Access rights, security and business confidentiality | Who may access or change information, and how is it protected? | | EN 18246 | Authentication, reliability and integrity | How can an item's origin and integrity be assessed? | The six harmonised references published in July 2026 cover EN 18216 and EN 18219–18223. #### EN 18216: data exchange protocols The communication layer matters when a manufacturer, service provider, repairer and authority all use different software. Ask suppliers which protocol requirements they implement and to demonstrate exchange with an independent system — "we have an API" is not conformance evidence. #### EN 18219: unique identifiers Identification must survive changes of hosting, ownership and software. Separate product identity from the address where information currently lives, and distinguish model, batch and item identification as the legal measure requires. #### EN 18220: data carriers Test readability after printing, packaging, transport, installation and wear — and verify the carrier resolves to the correct passport, not a generic marketing page. #### EN 18221: persistence and archiving Persistence is organisational as well as technical: contracts, identifier governance, backups and migration all matter. Demonstrate restoration from backup and migration to a replacement provider. #### EN 18222 and EN 18223: lifecycle services and interoperability Test creation, retrieval, update, discovery and lifecycle transitions. Include semantic consistency: transferring a number is useless if the receiver misreads its unit, boundary or product reference. #### EN 18239 and EN 18246: security and trust Both are in the first eight-standard framework, but the July 2026 decision covered the other six. Check later Official Journal publications before assuming harmonised status. Access control, authentication and integrity are related but distinct — none proves an environmental claim was correct. ### Harmonised references: what they establish ESPR Article 41(2) gives a presumption of conformity for DPPs complying with cited harmonised standards — but only for the Article 10 and 11 requirements those standards cover. 1. **Publication is not citation.** A European Standard can exist without an Official Journal reference. 2. **Citation is not unlimited approval.** The legal effect concerns the requirements covered. 3. **Conformity is not self-proving.** You need evidence your implementation follows the clauses. Treat a vendor "EU-compliant" badge with scrutiny: ask for standard, edition, clauses, scope, test evidence and exclusions. ### ISO/IEC JTC 5 and international alignment CEN/CENELEC identifies ISO/IEC JTC 5, "Digital Product Passport," as the international counterpart and anticipates collaboration. Future international deliverables remain **expected**. Support globally usable identifiers and open interfaces, while keeping an explicit mapping to the European requirements. ### How to use the standards in a real project #### Start with a legal requirements matrix Identify product, regulation, delegated acts, dates and required content — then map technical requirements to standards. Separate product data, identity and carriers, access and update permissions, availability, registry interactions and evidence. #### Build a conformance evidence pack For each clause record the system component, owner, verification method and evidence location: interface specs, test logs, restoration exercises, access-control tests. #### Procure portability explicitly Require structured export, identifier continuity, documented interfaces, migration assistance and termination arrangements. Establish who controls domains, resolvers and keys. #### Test failure, not just success Include an unavailable host, a withdrawn credential, a damaged carrier, a wrong identifier and a replacement provider. The real question: can the right actor obtain trustworthy, correctly interpreted information throughout the lifecycle? ### Sources - https://eur-lex.europa.eu/eli/dec_impl/2026/1736/oj/eng - https://www.cencenelec.eu/news-events/news/2026/en-in-the-spotlight/2026-07-15-dpp/ - https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng - https://www.cencenelec.eu/media/CEN-CENELEC/Events/Webinars/2026/20260625_cen-cenelec-webinar-on-dpp-final_rev20260625.pdf --- # Guides ## What data goes into a Digital Product Passport? > Identity, characteristics, evidence, lifecycle and governance — the five layers of a DPP data model. ### Key takeaways - There is no single universal DPP template — each delegated act sets mandatory fields. - ESPR Annex III is a menu the Commission picks from per product group. - Treat a DPP as a maintained record with versions and permissions, not a static brochure. ### A five-layer model CIRPASS architecture work centres every passport on a unique identifier. A practical implementation model separates five layers: - Identity — product, model, batch or item; responsible economic operator; facility. - Product characteristics — materials, composition, performance and sustainability attributes. - Evidence — certificates, declarations, calculations and source records. - Lifecycle — repair, reuse, ownership events and recycling information. - Governance metadata — provenance, timestamps, versions, permissions and who may update what. ### What ESPR Annex III allows - Unique product identifier and GTIN (or equivalent) - TARIC commodity code - Compliance documentation, declarations of conformity, technical documentation - User manuals, instructions, warnings and safety information - Manufacturer, importer, authorised representative identifiers - Facility identifiers - Information on durability, reparability, recycled content, substances of concern and environmental footprint (via Article 7) ### Batteries: the most detailed example The Battery Pass consortium organises around 90 attributes into seven themes: general information; compliance, labels and certifications; carbon footprint; supply-chain due diligence; materials and composition; circularity and resource efficiency; performance and durability. These are guidance groupings — the legal structure in Annex XIII splits data by access level instead. ### What is not required No general obligation exists to publish a full bill of materials, use blockchain, or serialise every item. Granularity (model, batch or item) is decided per product group. ### Sources - [CIRPASS system architecture (D3.2)](https://cirpassproject.eu/wp-content/uploads/2024/06/D3.2v1.9.pdf) - [Battery Pass Content Guidance](https://thebatterypass.eu/assets/images/content-guidance/pdf/2023_Battery_Passport_Content_Guidance.pdf) - [Regulation (EU) 2024/1781](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng) ## Identifiers, data carriers and GS1 Digital Link explained > The identifier, the carrier and the resolver are three different things. Here's how they fit together. ### Key takeaways - A QR code is the carrier, not the passport. - A GTIN identifies a product class; item-level passports need serialisation. - Control your resolver so destinations can change without reprinting codes. ### Three separate pieces | Piece | What it is | Example | | --- | --- | --- | | Identifier | Names the object | GTIN + serial number | | Data carrier | Physical access mechanism | QR code, NFC tag, RFID, Data Matrix | | Resolver | Directs a scan to the right content | GS1 Digital Link resolver | ### GS1 Digital Link GS1 Digital Link expresses identifiers such as GTINs, batch and serial numbers as web URIs. One code can serve point-of-sale scanning, consumers, repairers and regulators, and the linked content can change without replacing the printed code. ### Granularity | Level | Identifier | Typical use | | --- | --- | --- | | Model | GTIN | Toys, detergents, many ESPR goods | | Batch | GTIN + lot | Steel, chemicals, food-adjacent goods | | Item | GTIN + serial | Batteries, luxury, high-value electronics | ### Choosing a carrier - QR — cheapest, universal smartphone support, printed on label or product - NFC — invisible, premium feel, tap-to-read, good for authentication - RFID — logistics and inventory; not consumer-readable by phone - Durability matters: the carrier must survive the product's expected lifetime, washing, heat or abrasion ### Keep links stable Passports must stay reachable for the product's lifetime — ten years for detergents. Use a domain and resolver you control, and contract for data export so you can switch providers without breaking printed codes. ### Sources - [GS1 Digital Link](https://www.gs1.org/standards/gs1-digital-link) - [GS1 and the DPP](https://www.gs1.org/standards/standards-emerging-regulations/DPP) ## DPP access rights: who can see what? > Public, legitimate interest and authority access — with a worked permission matrix. ### Key takeaways - Access is tied to specific fields and purposes, not a simple public/private switch. - Batteries define three audiences: public, legitimate interest, authorities. - Internal admin and supplier roles are operational, not legal tiers. ### Battery passport audiences - General public — identity, chemistry, carbon footprint, recycled content, capacity, lifetime, warranty - Persons with legitimate interest — repairers, remanufacturers, second-life operators and recyclers: detailed composition, dismantling, state of health - Notified bodies, market surveillance authorities and the Commission — test reports and compliance evidence ### Example permission matrix | Field | Public | Repairer | Recycler | Authority | | --- | --- | --- | --- | --- | | Model & manufacturer | Read | Read | Read | Read | | Carbon footprint | Read | Read | Read | Read | | Detailed composition | — | Read | Read | Read | | Dismantling instructions | — | Read | Read | Read | | State of health | — | Read | Read | Read | | Test reports | — | — | — | Read | ### Design tip Model each permission as field × audience × read/write × purpose × proof of entitlement. Verifiable credentials and identity wallets are emerging as a way to prove a repairer or recycler is entitled to restricted data. ### Sources - [Regulation (EU) 2023/1542 Art. 77](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng) ## Where is DPP data stored? Decentralisation, registry and blockchain > The EU registry stores identifiers, not passports. And no, you don't need blockchain. ### Key takeaways - The central registry (deadline 19 July 2026) holds identifiers; passport data stays with operators or providers. - Decentralised does not mean you must run your own servers. - Blockchain is optional, never a legal requirement. ### Registry vs passport ESPR Article 13 required a central registry by 19 July 2026, operated under Implementing Regulation (EU) 2026/1778. It stores at least the unique identifiers so customs and authorities can check products. The substantive passport data is hosted by the responsible operator or a DPP service provider. ### Backups and continuity Article 11 requires passports to remain available, including a backup copy held by an independent DPP service provider, so data survives if a company goes out of business. ### Interoperability standards - CEN/CENELEC JTC 24 — EN 18216, 18219–18223:2026 for identifiers, carriers, access, APIs and exchange - GS1 EPCIS 2.0 — lifecycle events in JSON/JSON-LD with REST interfaces - W3C Verifiable Credentials — proving who issued a claim - UN Transparency Protocol (UNECE Rec. 49) — global traceability framework ### Sources - [CEN/CENELEC DPP standards](https://www.cencenelec.eu/news-events/news/2026/en-in-the-spotlight/2026-07-15-dpp/) - [GS1 EPCIS](https://www.gs1.org/standards/epcis) ## DPP implementation: an 8-step readiness plan > From legal scoping to scaled rollout — the sequence that works. ### Key takeaways - Start with scope and data ownership, not software. - Supplier data is usually the longest lead-time item. - Pilot with real missing-data cases before you scale. ### The eight steps - 1. Confirm legal scope — product families, markets, applicable laws and dates. - 2. Assign the responsible operator, programme owner and data owners. - 3. Map existing data in ERP, PLM, PIM, LCA tools and supplier files. - 4. Run a field-level gap assessment and plan supplier collection. - 5. Decide granularity, identifiers, carriers and access policies. - 6. Pilot representative products, including missing-data cases. - 7. Test scans, permissions, updates, exports and lifecycle handovers. - 8. Scale with monitoring, evidence retention and exit/continuity provisions. ### Typical timeline | Phase | Duration (indicative) | | --- | --- | | Scoping & gap analysis | 1–3 months | | Supplier data collection | 3–12 months | | Pilot | 1–3 months | | Rollout | 3–9 months | ### Lesson from batteries Volvo and Circulor's EX90 battery passport took more than five years of development — publishing a passport is quick; establishing the supply-chain visibility behind it is not. ### Sources - [Reuters — Volvo battery passport](https://www.reuters.com/business/autos-transportation/volvo-issue-worlds-first-ev-battery-passport-ahead-eu-rules-2024-06-04/) ## How much does a Digital Product Passport cost? > Why 'price per passport' is the wrong metric, and what to budget for instead. ### Key takeaways - Most cost sits in data collection and integration, not hosting. - Budget for the product's lifetime, not just launch. - Insist on export and continuity terms. ### Cost categories | Category | Includes | | --- | --- | | Regulatory interpretation | Scoping, legal review | | Upstream data | Supplier onboarding, data remediation, evidence | | Integration | ERP, PLM, PIM connectors | | Identity & carriers | GS1 membership, serialisation, labels, tags | | Platform | Hosting, security, access management, volume charges | | Lifetime operation | Updates, backups, assurance, migration | ### SME perspective CIRPASS's SME cost-benefit study highlights regulatory interpretation and upstream data collection as the dominant burdens for smaller businesses. Starting with a light, model-level passport on an existing toolset keeps early costs low. ### Sources - [CIRPASS SME cost-benefit study](https://cirpassproject.eu/wp-content/uploads/2024/02/CIRPASS-A-study-on-DPP-costs-and-benefits-for-SMEs-v1.0-1.pdf) ## Build vs buy: choosing a DPP platform > Twelve questions to ask any DPP provider before you sign. ### Key takeaways - Few businesses should build DPP infrastructure in-house. - Owning your identifier domain prevents lock-in. - Separate mandatory disclosures from optional marketing features. ### Questions to ask a provider - Which regulations and product groups do you support today? - Do you support GS1 Digital Link and our own domain? - Model, batch and item-level granularity? - How are access tiers and legitimate-interest users handled? - Which standards do you implement (EN 18216 series, EPCIS)? - Can we export all passports in a machine-readable format? - What happens to our passports if you close? - How do suppliers contribute data? - Which ERP/PLM/PIM integrations exist? - How are updates versioned and audited? - What are lifetime hosting costs? - Can the same code also drive care, warranty and resale experiences? ## The EU Battery Passport: complete guide for 2027 > Scope, Annex XIII data, access levels and the 18 February 2027 deadline. ### Key takeaways - Mandatory from 18 February 2027 for EV, LMT and industrial batteries >2 kWh. - Due diligence moved to 18 August 2027 — the passport date did not move. - Every individual battery needs its own passport. ### Scope | Battery type | Passport? | | --- | --- | | Electric vehicle (EV) | Yes | | Light means of transport (e-bikes, e-scooters) | Yes | | Industrial > 2 kWh | Yes | | Industrial ≤ 2 kWh | No | | Portable | No | | SLI (starter, lighting, ignition) | No | ### Annex XIII structure - Public model information — identity, chemistry, critical raw materials, carbon footprint, responsible sourcing, recycled and renewable content, capacity, voltage, power, lifetime, warranty, efficiency - Restricted model information — detailed composition, parts and dismantling - Authority-only — compliance test reports - Individual battery — state of health, status and usage data ### Practical resources The Battery Pass consortium (Systemiq-led, 11 partners) publishes content and technical guidance aligned with DIN DKE SPEC 99100. Use the latest attribute list — field labels changed in January 2025. ### Sources - [Battery Pass Technical Guidance](https://thebatterypass.eu/assets/images/technical-guidance/pdf/2024_BatteryPassport_Technical_Guidance.pdf) - [Regulation (EU) 2023/1542](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng) ## Textile DPP: what fashion brands should prepare now > The apparel delegated act is expected in 2027. Here's how to get ready without overreacting. ### Key takeaways - Apparel first — not every textile category automatically. - Mandatory textile passports expected around 2028–2029. - The destruction ban for unsold clothing already applies to large firms from 19 July 2026. ### Readiness domains - Fibre and material composition per style - Recycled-content evidence and certification - Tier 1–4 supplier records - Chemical and substances-of-concern information - Care, repair and end-of-life instructions ### Beyond compliance Fashion brands are using passports for authenticated resale, repair booking and care content. One QR or NFC tag can serve regulators and customers. ### Sources - [Commission — Textile apparel DPP](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/textile-apparel_en) ## Construction product DPPs vs building passports and EPDs > How the CPR passport relates to BIM, EPDs and building material passports. ### Key takeaways - The CPR passport is per product, not per building. - It carries the declaration of performance and conformity. - Expected to apply around 2028, triggered by a delegated act. ### Three things that get confused | Thing | What it covers | | --- | --- | | CPR product passport | One construction product: DoP, conformity, safety, technical data | | EPD | Environmental Product Declaration — LCA results per EN 15804 | | Building / material passport | A whole building's materials, often voluntary or national | ## Beyond compliance: the business case for DPPs > Why leading brands treat the passport as a customer channel, not just a legal box. ### Key takeaways - Every scan is a first-party touchpoint. - Verified history unlocks resale and repair. - Item-level IDs help fight counterfeits and back green claims. ### Value drivers - Product registration, warranty and support - Authenticated resale and take-back - Repair booking and spare parts - Anti-counterfeiting - Substantiated sustainability claims - First-party data and loyalty ## Avoiding lock-in: DPP provider exit and continuity > Your codes are printed for a decade. Make sure your passports outlive your vendor. ### Key takeaways - Own the domain behind your QR codes. - Contract for full machine-readable export. - Test migration before you need it. ### Contract checklist - Identifier domain and resolver under your control - Full export in standard formats on demand - Independent backup as required by ESPR Art. 11 - Defined service levels for availability - Exit assistance and migration testing --- # FAQ ## Fundamentals ### What is a Digital Product Passport? A structured digital record for a product, accessed by scanning a data carrier like a QR code, sharing information on identity, materials, environmental performance, compliance and end-of-life handling. ### How does a DPP work? A unique identifier is encoded in a carrier on the product. Scanning it hits a resolver that returns the passport information the viewer is entitled to see. ### Is a DPP just a QR code? No. The QR code is only the carrier. The passport is the maintained data behind it, including access rights and update history. ### What is the difference between a DPP and a digital twin? A digital twin models a product's real-time behaviour, usually for engineering. A DPP is a regulated, standardised information record for compliance and circularity. ## Scope and deadlines ### When do DPPs become mandatory in the EU? There is no single date. Batteries: 18 February 2027. Detergents: 23 September 2029. Toys: 1 August 2030. ESPR product groups follow their delegated acts, from around 2028. ### Which products need a DPP? Initially EV, LMT and industrial batteries over 2 kWh, then construction products, detergents, toys and ESPR priority groups: steel, textiles, aluminium, tyres, furniture, mattresses and electronics. ### Do non-EU manufacturers need DPPs? Yes. Any in-scope product placed on the EU market needs one, wherever it is made. ### Are SMEs exempt? Generally no for passports, although delegated acts can include simplifications. Micro and small enterprises are exempt from the unsold-goods destruction ban. ### Who is responsible for DPP compliance? The economic operator placing the product on the market — usually the manufacturer, or the importer for non-EU goods. ### Has the battery passport been delayed? No. Omnibus IV delayed battery due diligence to 18 August 2027; the 18 February 2027 passport date is unchanged. ## Technical ### Does a DPP need a unique serial number? Only when item-level granularity is required, as for batteries. Many product groups may use model or batch level. ### Can existing GTINs be used? Yes. GTINs work as model-level identifiers and can be combined with batch or serial numbers through GS1 Digital Link. ### Should a DPP use QR, NFC or RFID? QR is the most common and cheapest. NFC suits premium or design-sensitive products. RFID suits logistics. Many brands combine them. ### Can one QR code support checkout and a DPP? Yes. GS1 Digital Link QR codes can be read by retail scanners and smartphones. ### Does a DPP require blockchain? No. Blockchain is an optional technology choice, never a legal requirement. ### Where is DPP data stored? With the responsible operator or its service provider. The EU central registry stores identifiers, not full passports. ### How do DPPs comply with GDPR? Passports are about products, not people. Where personal data appears, such as ownership, normal GDPR rules apply and should be minimised. ## Implementation and buying ### How do I create a DPP? Confirm scope, map your data, collect supplier data, choose identifiers and carriers, publish on a DPP platform and test access and updates. ### How long does implementation take? A model-level pilot can take weeks. Full supply-chain readiness typically takes 6–18 months. ### How much does a DPP cost? Most cost lies in data collection and integration. Platform fees vary by volume; budget for the product's whole lifetime. ### Should we build or buy a DPP system? Most businesses buy. Building means maintaining standards compliance, security and long-term availability yourself. ### What happens if my passport provider closes? ESPR requires a backup copy with an independent provider. Owning your QR domain and export rights makes migration possible. ### What ROI can DPPs generate beyond compliance? Customer engagement, warranties, resale, repair services, anti-counterfeiting and credible sustainability claims. --- # Glossary - **DPP** — Digital Product Passport — a structured digital record linked to a product via a data carrier. - **ESPR** — Ecodesign for Sustainable Products Regulation (EU) 2024/1781, the DPP framework law. - **Delegated act** — Commission legislation that sets product-specific requirements under ESPR. - **Data carrier** — The physical means of accessing a passport, such as a QR code, NFC tag or RFID. - **Unique product identifier** — A persistent code identifying a model, batch or item. - **GTIN** — Global Trade Item Number — GS1 identifier for a product class. - **GS1 Digital Link** — Standard for expressing GS1 identifiers as web URIs inside QR codes. - **Resolver** — Service that routes a scanned identifier to the right content. - **Central registry** — EU registry storing DPP identifiers (ESPR Art. 13), due 19 July 2026. - **DPP service provider** — Third party hosting or processing passport data on behalf of an operator. - **Economic operator** — Manufacturer, importer, distributor or other party responsible for a product. - **Granularity** — Whether a passport applies per model, batch or individual item. - **Legitimate interest** — Battery-passport access level for repairers, remanufacturers and recyclers. - **EPCIS** — GS1 standard for sharing lifecycle event data. - **JTC 24** — CEN/CENELEC committee writing horizontal DPP standards. - **EN 18216 series** — European DPP standards published in 2026. - **LMT battery** — Light means of transport battery, e.g. e-bikes and e-scooters. - **SLI battery** — Starter, lighting and ignition battery — no passport required. - **EPREL** — EU energy-label product database — not the same as a DPP. - **EPD** — Environmental Product Declaration, common in construction. - **BIM** — Building Information Modelling, which the CPR passport must interoperate with. - **Omnibus IV** — 2025 EU simplification package that delayed battery due diligence to 2027. - **Verifiable credential** — W3C standard for cryptographically provable claims. - **Working plan** — ESPR Working Plan 2025–2030, setting indicative priority product dates.