Point your phone at a QR code on a product and get everything: materials, carbon footprint, repair instructions, end-of-life guidance and many other technical (and not so technical) data.
That is the EU Digital Product Passport. And from 2027, it is no longer optional.
The DPP requires structured, machine-readable product data maintained across the entire product lifecycle. For batteries, the State of Health must update dynamically as the product ages. For all categories, the information has to be aggregated from multiple sources: the manufacturer’s own ERP, PLM and quality management systems, plus data from first and second-tier suppliers. Getting all of that into a standardised, interoperable format is an integration project in its own right.
The DPP appears across multiple EU regulations, not just the ESPR (Ecodesign for Sustainable Products Regulation). The Battery Regulation (EU) 2023/1542 established the Battery Passport as the first mandatory DPP. The new Toy Safety Regulation (2025/2509) includes DPP obligations explicitly. The Critical Raw Materials Act requires a DPP for products containing permanent magnets above 0.2 kg. The Construction Products Regulation has its own phased DPP approach. The pattern is consistent: the DPP is becoming the standard transparency mechanism across EU product legislation.
The Battery Passport is the first hard deadline: mandatory from 18 February 2027 for EV, industrial and light transport batteries above 2 kWh, under the Battery Regulation.
Under the ESPR Working Plan 2025-2030, adopted in April 2025, the indicative timeline for delegated acts runs as follows:
Once the delegated act for a product category is published, manufacturers typically have 18 months before obligations become enforceable. Knowing where your products sit in this sequence determines how much preparation time you realistically have.
The ESPR and the other regulations that require a DPP apply to all products placed on the EU market, regardless of where the manufacturer is based. There are no geographic exceptions. When the manufacturer has no EU presence, compliance obligations transfer formally to the importer or to an EU Authorised Representative. In practice, however, neither importers nor ARs have access to the volume and granularity of product data that a DPP requires. Composition data, lifecycle information, substances of concern, supplier traceability: this information lives inside the manufacturer’s own systems. The DPP is a project the manufacturer has to drive from the inside.
Annex III of the ESPR explicitly allows delegated acts to incorporate information already required under other EU legislation, including elements of the CE marking technical documentation and the Declaration of Conformity. Manufacturers who have invested in building a complete, well-structured technical file are not starting the DPP journey from scratch.
At GetReady Compliance, we help manufacturers navigate the Digital Product Passport from both a regulatory and a technology perspective.
We support you with:
And thanks to our partnership with a specialised technology provider, we can also offer:
The integration layer is where most DPP projects stall. Our partner takes that on directly, so your compliance team does not have to.
Just fill out the form and start the conversation with our team!