All you need to know about CE Marking
What’s New with the EU Digital Product Passport: What Manufacturers Need to Know
Point your phone at a QR code on a product and pull up EVERYTHING there is to know about it.
A consumer shopping for shoes could do this before buying.
A mechanic receiving a battery at his workshop could do it too, and get the technical information he needs.
This is basically what the EU Digital Product Passport is designed to make possible: a digital record attached to every physical product sold in Europe, accessible to whoever needs it, with the level of detail that is actually useful to them.
The DPP can be accessed in different ways, from a QR code to an NFC chip or RFID tag. The information it contains can range from basic product identification and sustainability data all the way to detailed technical documentation, substances of concern, and end-of-life instructions. And not everyone sees the same thing: a consumer, an importer, and a market surveillance authority each access a different version of the passport, calibrated to what they actually need.
That is the basics of the DPP but…
…much of the DPP still remains to be defined. Here is everything you need to know today.
The EU Digital Product Passport (DPP) is a regulatory obligation in the making, anchored in the Ecodesign for Sustainable Products Regulation (ESPR), which entered into force in July 2024.
In March 2026, the Joint Research Centre of the European Commission published the first official methodology for defining DPP data requirements under the ESPR. It is the most concrete document published to date on how this system will actually be implemented. The question every manufacturer exporting to Europe needs to answer is straightforward: what does this mean for me, and when?
The timeline: batteries first, then everything else
The DPP rolls out by product category through specific delegated acts.
The first mandatory DPP is the Battery Passport, which applies from February 2027 under the Battery Regulation (EU) 2023/1542.
It covers EV, industrial, and light transport batteries with a capacity above 2 kWh. This is not an ESPR obligation but a separate piece of legislation, and it is the clearest proof of concept for how the DPP system will work in practice across all other categories.
Under the ESPR framework, indicative timelines for delegated acts cover iron and steel from 2026, textiles, tyres and aluminium from 2027, furniture from 2028, and ICT products and mattresses from 2029. These are dates for the adoption of delegated acts, not automatic compliance deadlines. Once a delegated act is adopted, manufacturers typically have a transition period before obligations become enforceable.
Non-EU manufacturers are not exempt
The ESPR applies to all products placed on the European market, regardless of where the manufacturer is based. There are no geographic carve-outs. A company based in the US, Japan, or anywhere else that sells products in the EU falls within scope if its product category is covered by a relevant delegated act.
When the manufacturer is not established in the EU, the compliance obligations under the ESPR, including those related to the DPP, transfer to the importer or can be partially delegated to an EU Authorised Representative.
In practice, however, neither importers nor ARs typically have access to the volume and granularity of product data that a DPP requires.
Composition data, lifecycle information, substances of concern, repair instructions: this information lives inside the manufacturer’s own systems. Which means that regardless of how responsibilities are formally allocated…
…the DPP is ultimately a project that the manufacturer has to drive from the inside.
From a technical standpoint, implementing a DPP means integrating an external service provider with the manufacturer’s internal databases. For most industrial companies this is not a single database: it is a combination of ERP systems such as SAP, product lifecycle management platforms, quality management systems, and supplier data repositories, often built at different times and not designed to talk to each other. Getting structured, machine-readable, up-to-date product data out of that environment and into a standardised DPP format is an integration project in its own right, with a complexity that most compliance timelines do not account for.
This allocation of responsibility mirrors the structure already in place under CE marking legislation. What is new is the scope of the obligation. The DPP requires not just that a product complies, but that structured, accessible, machine-readable evidence of that compliance is attached to the product and maintained throughout its lifecycle.
What CE marking documentation has to do with the DPP
One of the most practically relevant findings in the JRC report is that the DPP does not start from zero. Annex III of the ESPR explicitly allows delegated acts to require that information already mandated under other EU legislation, including elements of the technical documentation and declarations of conformity, be made available through the DPP.
This means that a well-structured CE marking technical file is a direct input to DPP readiness.
The product description, the list of applicable directives and standards, the risk assessment, the Declaration of Conformity: all of these are categories of information that the DPP framework is designed to incorporate, not duplicate.
Manufacturers who have invested in building a rigorous, complete CE marking technical file are not starting the DPP journey from scratch. Those who have delayed or cut corners on their technical documentation will find that the DPP obligation makes those gaps harder to ignore.
The criticalities the JRC acknowledges openly
This is where the JRC report offers something that almost no other source on the DPP provides: an honest assessment of what is not yet resolved.
The methodology has not been tested across multiple product groups. It is explicitly described as a first-time design. Its robustness and adaptability to different sectors will only become clear as it is applied in future preparatory studies.
Key technical standards were not available at the time of drafting. The CEN/CENELEC standards developed by Joint Technical Committee 24, which form the technical foundation for DPP interoperability, were not yet published when the JRC wrote this methodology. Assumptions about vocabularies, data structures, and interoperability may need revision once that work is complete.
IT architecture, system governance, and enforcement are out of scope. The document deliberately does not address how the DPP system will be architected, how data hosting will work, or how enforcement will operate in practice. These are not minor details.
Scalability and cross-sector interoperability remain partially unresolved. Pilot implementations have been sector-specific and limited in scale. How the system will function across dozens of product categories simultaneously is a question the JRC itself flags as open.
Tiered access rights are defined in principle but not yet in practice. The ESPR establishes that different actors will have different levels of access to DPP data. Drawing from the Battery Passport as a reference model, the framework envisions four tiers:
- public access to basic non-confidential information,
- broader access for end users and professional users,
- technical and operational data for economic operators in the value chain such as repairers and recyclers,
- and full access for market surveillance authorities and the Commission.
The ESPR does not prescribe how these tiers will be implemented technically. That definition is left to each product-group delegated act and to standardisation work still underway. For manufacturers, this means the contractual and data governance implications of the DPP are not yet fully predictable.
What manufacturers should do now
Three concrete steps are worth taking regardless of product category or compliance timeline.
The first is to identify whether your products fall within the initial priority categories of the ESPR Working Plan, and at what indicative timeline. Not all product groups are in scope at the same time, and understanding where your products sit in the rollout sequence determines how much preparation time you realistically have.
The second is to assess the current state of your technical documentation. The DPP will require structured, machine-readable product data maintained across the product lifecycle. Companies that already manage their compliance documentation in an organised, traceable way have a genuine head start.
The third is to clarify the chain of responsibility for your products in the EU market. Whether compliance obligations sit with your EU importer, with an Authorised Representative, or directly with your organisation affects both the structure of your compliance programme and the contractual relationships you need to have in place.
The DPP as a marketing channel
Compliance obligations aside, the DPP opens a channel that did not exist before. The public access tier of the passport, accessible to any consumer who scans the QR code on the product, is a page controlled by the manufacturer. Within the limits of what the regulation permits in the public tier, that page can carry far more than dry technical data.
Origin story, materials sourcing, sustainability credentials, repair and care instructions, brand values: all of this can be part of what the consumer sees.
For manufacturers who think beyond the compliance checkbox, the DPP is a direct, persistent touchpoint with the end user that travels with the product throughout its entire life. A marketing channel built into the product itself.
At GetReady Compliance, we are actively investigating technology-based solutions to make EU product compliance more manageable for our clients, including tools designed to support the transition toward DPP-ready documentation. If you want to understand how to prepare, get in touch.