Digital Product Passport (DPP): When Is It Mandatory? All Deadlines 2026–2030

PIM

The Digital Product Passport (DPP) is a standardized dataset that consolidates all relevant information about a product across its entire lifecycle — from raw material extraction to recycling. The EU is phasing in the DPP product group by product group: the battery passport becomes mandatory on 18 February 2027, iron and steel are expected to follow from around 2028, textiles from late 2028/2029 — see the full timeline below. The infrastructure is already in place: the central EU DPP Registry went live in July 2026. Anyone selling products in the EU should prepare now.

What Is the Digital Product Passport? Definition and Fundamentals

The Digital Product Passport is an electronic dataset accessible via a QR code or RFID chip on the product. It makes information about a product’s origin, composition, repairability, and recyclability transparent for all participants in the value chain — from manufacturers and retailers to consumers and recycling companies.

The legal basis is the EU Ecodesign for Sustainable Products Regulation (ESPR), which entered into force on July 18, 2024. It replaces the former Ecodesign Directive and extends its scope to virtually all physical products on the EU single market.

Timeline: When Will the Digital Product Passport Become Mandatory?

Quick answer: The first binding deadline is 18 February 2027, when EV, LMT, and industrial batteries above 2 kWh will require a battery passport. All other product groups follow in stages until around 2030. The central EU DPP Registry has been live since July 2026, including a testing environment for technical integration.

A note for your planning: the Commission’s ESPR working plan (April 2025) sets an indicative order — dates can shift by a few months. A deadline only becomes binding with the respective delegated act, and there are usually at least 18 months between the act and the obligation. That lead time is your window for data preparation.

Practical assessment from apollon: Companies currently manufacturing or importing products in the batteries, steel, or textiles categories should start preparations now. Experience from PIM implementation projects shows: structuring and preparing product data typically takes 6 to 12 months — depending on data availability and product complexity.

What Data Does the Digital Product Passport Contain?

The DPP consolidates a wide range of product information that is often distributed across different systems or not captured digitally at all. Specific data requirements vary by product category but typically cover the following areas:

Product Identification and Manufacturer Details

• Unique Product Identifier
• Manufacturer, brand, model name
• Production location and date
• GTIN/EAN, article number
• Declarations of conformity and certifications

Composition and Materials

• Material composition (including recycled content)
• Chemicals and hazardous substances used (SCIP database relevant)
• Raw material origin (supply chain transparency)
• Weight and dimensions

Sustainability and Environmental Impact

• Carbon footprint
• Energy efficiency class
• Water consumption in production
• Environmental labels and sustainability certifications

Repairability and End-of-Life

• Repairability index
• Spare parts availability (duration and price)
• Disassembly instructions
• Recyclability and disposal instructions

Key point: Much of this data already exists within companies — but distributed across ERP systems, Excel spreadsheets, PDF data sheets, and email inboxes. The Digital Product Passport requires this data to be structured, machine-readable, and centrally available. This is precisely where a PIM system becomes the central tool.

Why the DPP Is Nearly Impossible Without a PIM System

A Product Information Management (PIM) system is the technical infrastructure companies need for the Digital Product Passport. The reason: the DPP demands exactly what a PIM system delivers — the central, structured management of all product-related data across the entire lifecycle.

apollon practical experience: From over 25 years of PIM project experience, we know that companies already using a PIM system can typically implement the DPP within 3 to 6 months. Companies without PIM need 12 to 18 months instead, because the data foundation must be built first.

DPP Implementation in 5 Steps: How to Prepare

Implementing the Digital Product Passport is not a pure IT project — it requires collaboration between product management, procurement, quality assurance, sustainability, and IT. Here is a proven roadmap:

Step 1: Product Data Inventory (Month 1–2)

Identify which DPP-relevant data already exists, where it is stored, and what gaps remain. Create a mapping between the DPP data requirements of your product category and your current data inventory.

• Inventory of all data sources (ERP, PLM, Excel, suppliers)
• Gap analysis: Which DPP fields are missing?
• Data quality assessment: Is existing data current and complete?

Step 2: Define Data Model and Governance (Month 2–3)

Define a data model that reflects the DPP requirements of your product category. Establish responsibilities: Who maintains which data? What quality standards apply?

Step 3: Implement or Extend PIM System (Month 3–6)

Implement a PIM system as the central data hub or extend your existing PIM with DPP-relevant attributes. Integrate ERP, PLM, and supplier portals as data sources.

Step 4: Consolidate and Enrich Data (Month 4–8)

Migrate existing data into the PIM system, fill data gaps, and validate data quality. Sustainability data (carbon footprint, material composition) in particular often requires coordination with suppliers.

Step 5: Configure and Test DPP Output (Month 6–10)

Configure automatic export of DPP data in the required format. Generate QR codes or data carriers for your products. Test the entire process from data capture to the finished Digital Product Passport.

Which Industries Are Affected First?

The ESPR regulation will ultimately affect nearly all physical products on the EU single market. The first product categories with specific DPP requirements are:

Batteries and Accumulators (from February 2027)

The EU Battery Regulation (2023/1542) requires the battery passport from 18 February 2027 for EV batteries, LMT batteries, and industrial batteries above 2 kWh (Art. 77). Data to be captured includes: capacity, performance, lifespan, composition, carbon footprint, recycled content, and collection instructions.

Textiles and Apparel (delegated act expected 2027, obligation ~late 2028/2029)

Under the EU working plan, the delegated act for textiles is expected in 2027, with the obligation following around late 2028/2029. The DPP is intended to make material composition, fiber origin, labor conditions in the supply chain, care instructions, and recyclability transparent. For an industry reliant on global supply chains, this represents a significant data effort.

Tyres (delegated act expected 2027, obligation ~2029)

For tyres, material composition, rolling resistance, durability, and recyclability will be central DPP requirements. The DPP makes lifecycle and recycling information transparent along the supply chain.

Three product areas now have their own DPP rules outside the ESPR: construction products get their passport via the new Construction Products Regulation (EU) 2024/3110 (phased in from around 2028 as harmonised technical specifications are adopted), toys via the new Toy Safety Regulation (EU) 2025/2509 (applicable from 1 August 2030), and detergents via Regulation (EU) 2026/405 (from 23 September 2029). And within the ESPR itself, iron and steel — not textiles — will be first in line: the delegated act is expected in Q4 2026.

Digital Product Passport and PIM: The Technical Connection

The technical architecture for the DPP is built on three pillars that a modern PIM system can cover:

1. Central Data Platform

The PIM system serves as the single source of truth for all DPP-relevant data. It integrates information from ERP (bills of materials, suppliers), PLM (product development), quality management (certificates, test results), and sustainability systems (CO2 data, LCA results).

2. Data Quality Management

The DPP requires complete and accurate data. PIM systems offer validation rules, mandatory field checks, and workflow-based approval processes that ensure only verified data flows into the DPP.

3. Automated Output Channels

The DPP is just one of many output channels a PIM system serves. The same product data flows simultaneously into webshops, marketplaces, print catalogs, and the Digital Product Passport — without duplicate data maintenance.

DPP Requirements Compared: What Different PIM Vendors Offer

Not every PIM system is equally well prepared for the Digital Product Passport. The most important criteria when selecting:

The available systems fall into two broad categories. Open-source PIM platforms offer flexibility and active communities, but typically require in-house development capacity to tailor them to specific DPP requirements. All-in-one suites combining PIM, DAM, and CMS cover a wide functional scope in a single platform, which suits companies with complex data models and dedicated IT teams — smaller organizations often find the customization and operational effort challenging.

Our recommendation: apollon OMN. apollon OMN combines PIM, DAM, and print publishing in one integrated platform — a clear advantage when you need to implement the DPP alongside existing product communication channels. Structured product data and the supporting documents (certificates, repair instructions, test reports) live in the same system and are delivered through the same machine-readable output. That tight coupling of data point and evidence document is exactly what the DPP demands.

Costs and Effort: What DPP Implementation Realistically Means

The cost of DPP implementation varies significantly depending on the starting point. A realistic estimate based on experience from PIM projects:

Important: These are not pure DPP costs. The investment in a PIM system pays off across all product communication channels — the DPP is just one additional output channel.

Common Mistakes in DPP Preparation

From consulting practice, typical mistakes that companies make when preparing for the Digital Product Passport can be identified:

• Starting too late: Many companies wait until the specific requirements for their product category are finalized. But building the data foundation takes months — and the basic requirements are already known.
• Thinking only about compliance: The DPP is a regulatory obligation, but also an opportunity. Transparency about materials and sustainability is increasingly becoming a purchasing argument — especially in B2B.
• Forgetting suppliers: A significant portion of DPP data comes from suppliers. Without early involvement of the supply chain, critical data points will be missing.
• Treating Excel as a solution: For 10 products, Excel may work. For 1,000 or 10,000 products with 50+ DPP attributes each, a PIM system is essential.
• Treating the DPP as an IT project: The DPP is a cross-functional project that must bring together product management, procurement, quality, sustainability, and IT.

FAQ: Frequently Asked Questions About the Digital Product Passport

Is the Digital Product Passport already mandatory?

The ESPR has been in force since July 2024, and the central EU DPP Registry went live in July 2026 — but the first binding product deadline is 18 February 2027, when EV, LMT, and industrial batteries above 2 kWh will require a battery passport. Iron and steel are expected to follow from around 2028 (delegated act expected Q4 2026), textiles from late 2028/2029. Construction products, detergents (from 23 September 2029), and toys (from 1 August 2030) have their own DPP rules.

Which companies are affected by the DPP?

In principle, all companies that place physical products on the EU single market — manufacturers, importers, and retailers. The obligation applies regardless of company size, although implementation is staggered by product category.

How much does Digital Product Passport implementation cost?

Costs depend on the starting point. Companies with an existing PIM system can expect EUR 15,000–50,000 for the DPP extension. Without PIM, the investment is EUR 100,000–300,000, as the data infrastructure must be built first. For a detailed breakdown of what drives PIM project costs — and why the license is the smallest part — see our article on PIM costs and pricing.

Do I need a PIM system for the DPP?

Technically not required — but practically yes. The DPP demands structured, machine-readable, versioned product data. Beyond a three-digit product count, this is hardly manageable without a PIM system. Moreover, you use the PIM simultaneously for all other product communication channels.

How does the DPP differ from the existing EU energy label?

The energy label covers only energy efficiency. The DPP is significantly more comprehensive: it contains information about material composition, repairability, recyclability, carbon footprint, and the entire supply chain. Existing energy label data will be integrated into the DPP.

What penalties apply for non-compliance?

The ESPR provides that EU member states shall determine sanctions. In line with existing EU product regulations, fines, sales bans, and product recalls are possible. The exact amount of penalties will be regulated in national implementation laws.

Can I use the DPP for marketing purposes?

Yes — and you should. Transparency about sustainability, materials, and origin is increasingly becoming a competitive advantage. Companies that proactively use the DPP to make their sustainability efforts visible can differentiate themselves positively from competitors.

When does the DPP apply to construction products?

The new EU Construction Products Regulation (EU) 2024/3110 entered into force on 7 January 2025 and has applied in essence since 8 January 2026. The Digital Product Passport for construction products will be phased in: it becomes mandatory for a product family once the harmonised technical specifications under the new regulation are in place — expected from around 2028 for the first product groups. Manufacturers of concrete, steel, windows, or insulation materials should start structuring their product data now.

Conclusion: Embrace the Digital Product Passport as an Opportunity

The Digital Product Passport is more than a regulatory compliance exercise. It forces companies to structure, centralize, and make their product data machine-readable — an investment that generates value far beyond compliance.

Companies that act now gain a dual advantage: they meet upcoming EU requirements on time and simultaneously build the data infrastructure for better product communication across all channels — from webshops and print catalogs to the Digital Product Passport.

Next step: Take stock of your current product data landscape. Where does the data reside? Which DPP-relevant attributes are missing? If you need support with planning, speak with our PIM experts — we bring over 25 years of experience in helping mid-market companies structure their product data.

Last updated: 13 August 2026