The digital product passport (DPP) is a set of data about one product, stored online by the business responsible for it and accessed by scanning a code on the product, its packaging or its papers. It is not a certificate and not a document. It is a web record with different access rights for consumers, businesses and authorities. It exists only for product groups named in EU law, and it applies to those products however they are sold, in bulk or in single parcels. For those products it is a condition for placing them on the market, and it will become a condition for release for free circulation once customs are connected to the EU registry.
The passport has three parts. A data carrier, such as a QR code, on the product. A unique product identifier, a string of characters that the code links to. And the data, kept by the business responsible for the passport or by a service provider, with a back-up copy held by an independent provider so that the passport survives the business's insolvency.
The data are set product group by product group. Annex III of the Ecodesign Regulation (Regulation (EU) 2024/1781) lists what a delegated act may require: the product identifier, the GTIN, the commodity code, the declaration of conformity, technical documentation, manuals and safety information, the manufacturer and the importer with its EORI number, identifiers for other operators and for production sites, and the service provider. Who may read which data is set in the delegated act for each product group: consumers, repairers, recyclers, market surveillance authorities and customs each have their own access rights.
The legal framework is above-mentioned Regulation (EU) 2024/1781 on ecodesign (ESPR), Articles 9 to 15. The laws on batteries, toys, detergents and construction products follow the same model, with differences in who creates the passport and whether customs check it.
The Commission runs a registry that stores the product identifier, the commodity code and a reference to where the passport is kept, not the passport data itself. The implementing act on the registry, Regulation (EU) 2026/1778, entered into force on 6 August 2026. The operator that the relevant law names registers the passport, after identity verification, and receives a registration identifier.
Customs will have two tasks under Article 15 ESPR, which the toys and detergents regulations repeat. From the moment the registry is operational, the person declaring the goods for release for free circulation gives customs the registration identifier. Once the registry is connected to the EU Customs Single Window, customs release the product only after an automatic check that the identifier and the commodity code match the registry. The connection must work by August 2030; the Commission's own estimate is around 2029. Customs see a match, not the passport, but may query passport data for risk analysis. Release is not proof of compliance. No customs check is provided for batteries or construction products.
Three things follow for practitioners. The registration identifier will have to be given to customs with the declaration; which data element and in what form is not yet laid down. The registry refuses a commodity code outside the range set for the product group, so the code must be settled before registration, not only before declaration. Who creates the passport differs by law: the ESPR gives it to the operator placing the product on the market; the toys and detergents regulations give it to the manufacturer. Registration in the EU registry is done by the operator the relevant law names. Under the toys regulation, creating the passport means assuming responsibility for the toy's compliance.
The two measures have different scopes. Product identifiers, required in declarations from 1 November 2026, apply to goods sold in distance sales, whatever the product. The passport applies to products in the groups EU law names, whatever the sales channel: a container of toys to a wholesaler needs one as much as a single toy ordered online. A toy sold online in 2030 will need both; a pallet of toys to a retailer, the passport only; a pair of shoes sold online, the identifiers only.
The two also work differently. The identifiers are the seller's and the manufacturer's own codes, declared as supporting documents so that customs can recognise the same product in later parcels. The passport is a data record created under EU rules, and its registration identifier will be verified automatically against a central EU registry. The GTIN declared today as the standardised identifier may be one of the data elements a passport holds. The identifiers are the bridge; the passport is where they lead.
|
Product |
Passport from |
Customs check from |
|
Electric vehicle, e-bike and industrial batteries above 2 kWh |
18 February 2027 |
None provided in law |
|
Detergents and surfactants |
23 September 2029 |
23 September 2029 or when the registry link works, whichever is later |
|
Toys |
1 August 2030 |
1 August 2030 or when the registry link works, whichever is later |
|
Iron and steel |
Mid-2028 at the earliest; delegated act planned for late 2026 |
When the registry link works |
|
Textiles, tyres, aluminium |
Late 2028 at the earliest |
When the registry link works |
|
Furniture, mattresses |
2030 and later |
When the registry link works |
|
Construction products |
18 months after a delegated act still to be adopted |
None provided in law |
The ecodesign dates come from the Commission's working plan of April 2025 and are indicative. As a rule, a delegated act applies no earlier than 18 months after it enters into force. Energy-labelled appliances will mostly not get a passport, according to the Commission's working plan, because the EPREL database already holds their data.
Preparation now means three things. Importers of batteries, toys and detergents should find out who in their supply chain will create the passport and who will register it. Customs representatives should expect a new data requirement and follow how it is defined. Everyone declaring distance sales should treat the product identifiers required from 1 November 2026 as the first step towards the same product data.
The ESPR, the registry act and the four product laws are adopted. No ecodesign delegated act has yet been adopted; the first, on iron and steel, is planned for the fourth quarter of 2026. According to a draft that leaked in September 2026, the European Product Act would make the passport the rule for all products under harmonised EU law and add a per-item market surveillance fee collected by customs. The proposal was postponed from 6 October 2026 to later in the year and was not adopted. This entry reflects the position as at 20 October 2026.
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