European regulations and the Digital Product Passport: what's next

The European policy for sustainable products is entering a stage where access to reliable product information will be of increasing importance to businesses. After the first publication of the RTIK information series presented what it is The Digital Product Passport and why it matters to businesses, this material focuses on the regulatory framework and the way in which the requirements are expected to be implemented.

The topic is linked to several key areas of European policy: ecodesign, circular economy, better resource management and reducing the environmental impact of products throughout their life cycle. For businesses, this means that product data will gradually become an important part of accessing the European market and proving compliance with new requirements.

ESPR as the main regulatory framework

The main regulatory act that introduces the framework for the future implementation of the Digital Product Passport for a wide range of products is Regulation (EU) 2024/1781 establishing a framework for setting ecodesign requirements for sustainable products, also known as Ecodesign for Sustainable Products Regulation /ESPR/.

The ESPR entered into force on 18 July 2024 and expands the previous approach to ecodesign, which was mainly focused on energy-related products. The new framework has a broader scope and applies to physical goods placed on the market or put into service in the European Union, including components and intermediate products. Certain categories are excluded, such as food, feed, medicinal products, live plants and animals, as well as some other specific product groups.

It is important to underline that the ESPR does not introduce a general and immediate obligation for all products. The Regulation creates the framework within which the European Commission will adopt subsequent rules for specific product groups. It is through these subsequent acts that it will be determined when a given product group falls within the scope, what requirements apply and what information must be included in the Digital Product Passport.

Batteries as a first concrete example

The first clearly established example of a mandatory digital product passport in the EU is the battery passport. It is regulated by a separate regulatory act – Regulation (EU) 2023/1542 regarding batteries and waste batteries, and not directly through ESPR.

The requirement will apply from February 18, 2027. for certain battery categories, including light vehicle batteries, industrial batteries with a capacity of more than 2 kWh and batteries for electric vehicles. This example shows the practical direction of development of digital product passports: linking the physical product with structured digital information necessary for traceability, compliance and management throughout the life cycle.

Batteries thus provide the first practical guidance on how digital product passports can be implemented in the European market. For the remaining product groups, the requirements will be developed gradually within the framework of the ESPR and subsequent acts of the European Commission.

How will the specific requirements be implemented?

The specific requirements under the ESPR will be introduced gradually through subsequent acts of the European Commission. They will set out the rules for individual product groups, including the applicable requirements for sustainability, information, traceability and a digital product passport.

For businesses, this means that it is important to monitor not only the regulation itself, but also the development of rules for the products and sectors they operate in. It is in these acts that the practically important details will be specified: scope of products, deadlines for implementation, data requirements, information carriers, access levels and responsibilities of the various economic operators.

Currently, acts related to the rules for the destruction of unsold consumer products have already been adopted under the ESPR. Product-specific acts, which will determine the requirements for a Digital Product Passport for individual product groups, are to be developed and adopted in stages.

The digital product passport within the ESPR

In the ESPR, the Digital Product Passport is envisaged as a tool for providing structured product information. Its function is to facilitate access to data related to compliance, sustainability, traceability and management of the product throughout its life cycle.

When a digital product passport is required for a given product group, the product will have to be accompanied by the relevant passport in accordance with the rules set out in the delegated act. This does not mean simply placing a QR code or a link, but having organised, reliable and up-to-date information related to the specific product.

Access to the information will be via a data carrier, such as a QR code or other machine-readable identifier, placed on the product, packaging or accompanying documentation, as required for the relevant product group. Some of the information may be publicly available, while others may be reserved for specific actors in the chain or for control authorities.

European registry and technical infrastructure

The European Commission is already working on the technical preparations for the introduction of the Digital Product Passport. This includes rules on unique identifiers, data carriers, access rights to information, the creation of a DPP registry and web portal, as well as other supporting activities.

According to Regulation (EU) 2024/1781 The European Commission should establish a register for digital product passports by July 19, 2026. The registry will be part of the European DPP infrastructure and will support the identification, verification and traceability of product passports.

It is important to make a distinction: the creation of the register does not mean that from that date all companies will automatically have an obligation to introduce a digital product passport for all their products. The specific obligations will depend on subsequent rules for individual product groups. However, for businesses this date is indicative because it shows that the technical infrastructure at European level is already being prepared.

Priority product groups and indicative deadlines

The European Commission is implementing a phased approach through working plans that define the product groups and measures to be worked on in the coming years. The first ESPR and energy labelling working plan for the period 2025-2030 outlines the priorities for the coming years.

Priority product groups include steel and aluminium, textiles with a focus on clothing, furniture, tyres, mattresses and energy-related products. The work plan also foresees horizontal measures to promote reparability, including the possibility of introducing a reparability assessment, as well as requirements on recycled content and recyclability of electrical and electronic equipment.

The working plan also sets out indicative timeframes for the adoption of future measures for individual product groups. These timeframes should be seen as indicative and do not constitute automatic dates for the application of obligations by businesses. The specific requirements, transitional periods and dates of application will be set out in the relevant subsequent acts.

Product group or measure	Indicative period for adopting measures
Steel and iron	2026.
Textiles and clothing	2027.
Tires	2027.
Aluminum	2027.
Repairability, including repairability assessment	2027.
Furniture	2028.
Mattresses	2029.
Recycled content and recyclability of electrical and electronic equipment	2029.

The inclusion of a product group in the work plan does not automatically and immediately impose an obligation on all companies in the sector. It indicates the priorities on which the European Commission will work and provides guidance on which businesses should follow the development of the topic more actively.

What businesses should watch for

For businesses, the most important thing at this stage is to monitor the development of the rules for the product groups they operate in. The specific requirements will be determined in stages and will have different meanings depending on the role of the company: manufacturer, importer, distributor, trader or supplier in the chain.

Businesses should pay attention to several key issues:

• whether its products fall or can fall into the priority groups;
• whether the preparation of a delegated act is underway for the relevant sector;
• what information and traceability requirements are being discussed;
• what will be the deadlines for implementation;
• how responsibilities will be distributed among participants in the chain.

The detailed practical question of what specific data businesses need to prepare will be addressed in the next post in the series. The present article aims to outline the regulatory logic and the stages that businesses need to follow.

Useful informationofficial sources

More information about the regulatory framework and the work of the European Commission on the topic is available in the following official sources:

• Regulation (EU) 2024/1781 on ecodesign for sustainable products
• Implementation of the Ecodesign for Sustainable Products Regulation /ESPR/
• ESPR and Energy Labelling Work Plan 2025-2030
• Regulation (EU) 2023/1542 on batteries and waste batteries
  

Pforward view

The Digital Product Passport is part of a long-term change in the way products are designed, manufactured, offered and managed on the European market. The requirements will develop gradually, but their importance for businesses will increase with the adoption of specific rules for individual product groups.

This is a good time for businesses to monitor regulatory changes, assess whether they are operating with potentially affected products, and plan their next steps in a more informed manner. In the next articles in the series, RTIK will look at more practical topics related to product data, affected sectors, how the DPP works, and preparing SMEs.

This material is part of the RTIK information series on the Digital Product Passport and business preparation. The publication was prepared with the expert assistance of Wiara - Daas Ltd – member of the Ruse Chamber of Commerce and Industry, working in the field of digital business solutions and product information management.