EU Digital Product Passport: What Manufacturers Must Prepare Before the 2027 Deadline

What the Digital Product Passport Is and Is Not#

The EU Digital Product Passport is not a certificate or a declaration — it is a data record linked to a specific product or batch, accessible via a standardised data carrier such as a QR code, RFID tag, or NFC chip. The DPP must be readable by consumers, businesses in the value chain, repair operators, recyclers, and competent authorities. It is designed to make product information accessible throughout a product's lifecycle, including at end of life. The DPP does not replace existing conformity markings such as CE — it is an additional information obligation. The legal framework for the DPP sits primarily within the Ecodesign for Sustainable Products Regulation (ESPR), with delegated regulations specifying the requirements for each product category. Batteries fall under the EU Batteries Regulation rather than ESPR, with their own DPP requirements.

Which Products Come First: Batteries and Textiles#

Battery passports are required from February 2027 for EV batteries and stationary industrial batteries, and from August 2027 for portable batteries. The battery passport must contain: unique identifier, carbon footprint declaration and performance class, recycled content percentages, supply chain due diligence report, capacity and performance parameters, and end-of-life information. For textiles and apparel, a delegated regulation under ESPR is expected to set DPP requirements with application dates in the 2026-2028 range. Construction products, furniture, and several other categories will follow on a rolling timeline through 2030. AskBiz tracks which delegated regulations have been adopted and the implementation dates for each product category, so manufacturers are not surprised by approaching deadlines.

What Data the DPP Must Contain#

The precise data requirements vary by product category and will be specified in delegated regulations. However, the ESPR framework legislation identifies the categories of information that the DPP must cover: product identification and manufacturer details; substances of concern, including hazardous substances and materials that affect recyclability; information to enable disassembly, repair, and recycling; carbon footprint and environmental footprint data; recycled content; and product lifespan information. For a textile manufacturer, this means being able to provide fibre composition data, chemical treatment information, care instructions, and end-of-life guidance at the individual garment level. For a battery manufacturer, it means capturing cell chemistry, manufacturing location, and carbon footprint data at the batch or product level.

The Data Infrastructure Challenge#

The DPP creates a significant data management challenge for manufacturers. Product-level information must be collected from across the supply chain — not just from your own manufacturing operations but from component suppliers, raw material processors, and chemistry providers. This data must be stored in a system that can generate a unique identifier for each product or batch, link it to a persistent data record, and make that record accessible via a QR code or equivalent. The data record must remain accessible for the full product lifecycle, including after end of sale. For businesses with complex supply chains, particularly those relying on multiple tiers of suppliers in different countries, building this data collection capability will take years. Organisations that begin the process now will be significantly better positioned than those that wait for delegated regulation deadlines.

Implications for Non-EU Manufacturers Exporting to the EU#

Non-EU manufacturers — including UK businesses — placing products on the EU market must comply with DPP requirements for their product categories. The obligation falls on the manufacturer or, if the manufacturer is outside the EU, on the EU importer or authorised representative. This means UK manufacturers exporting to EU distributors must either have an EU authorised representative who manages DPP compliance on their behalf, or build their own DPP-compliant data systems for EU-bound products. Given that DPP data must cover the full supply chain including manufacturing inputs, UK manufacturers will need to collect data from their own suppliers — many of whom may be outside the EU — and integrate it into an EU-compliant passport format.

• The EU Digital Product Passport (DPP) is a product-specific data record that must be accessible via a physical data carrier — typically a QR code — for every product placed on the EU market.
• It captures materials, carbon footprint, recyclability, repairability, and hazardous substance information.
• Batteries are first (2027), followed by textiles and construction products.