Digital Product Passport (DPP): When Is It Mandatory? Deadlines and Requirements

The Digital Product Passport makes required product information available digitally. There is no single start date for every product. The battery passport applies to specified battery categories from 18 February 2027. Other product groups follow their applicable EU rules. Years in the ESPR working plan refer to the planned adoption of legal acts, not automatically the start of a DPP obligation.

Sources reviewed: 9 November 2026. This apollon article explains the linked EU legislation and Commission information for product data preparation. Your obligations depend on product category, market role and applicable legal acts. A PIM system can support the data work; using one does not by itself establish product compliance.

Timeline · Data requirements · Preparation · FAQ

DPP timeline: distinguish binding dates from planning years

18 February 2027 is a statutory date for the battery passport. It covers LMT batteries, electric vehicle batteries and industrial batteries with a capacity greater than 2 kWh placed on the market or put into service from that date. The 2 kWh threshold applies only to industrial batteries. Source: Article 77 of the Batteries Regulation.

Sources: ESPR working plan 2025–2030, Construction Products Regulation, Detergents Regulation, Toy Safety Regulation. The Commission’s DPP portal also provides an explicitly indicative implementation timeline.

The ESPR generally allows at least 18 months between a delegated act entering into force and its application, with justified exceptions. Keep three dates separate in your project plan: planned adoption, actual entry into force and binding application. An entry in a working plan is not a legal act. Source: ESPR, Article 4(4).

What is the Digital Product Passport?

A DPP connects a product to digitally available information. A data carrier, such as a QR code, leads to that information. Depending on the rules, the passport may relate to a model, batch or individual item. It is not necessarily a single PDF or a complete collection of company data open to everyone.

The ESPR, Regulation 2024/1781, establishes a framework for ecodesign and information requirements for many physical products. Product-specific acts determine matters including data scope, carriers, access, updates and availability. Batteries and other sectors have separate legal bases. This distinction determines which requirements you need to assess.

Why is the DPP being introduced, and who is affected?

The DPP is intended to make relevant information usable across the value chain, including for purchasing, maintenance, repair, reuse, recycling and market surveillance. Actual information requirements depend on the product rules. The ESPR entering into force does not itself mean that every product already needs a passport.

Start with your portfolio and role. A manufacturer placing a new product on the market has different tasks from a distributor reselling a product already made available. Imports, own-brand products or modifications may create additional obligations. Suppliers may need to provide data even when they do not create the finished product’s passport. Document responsibilities against the applicable regulation.

An absent or incorrect passport, where required, is a product compliance issue. Measures and penalties depend on applicable EU legislation and national rules. Buying software does not replace technical assessment or required evidence.

EU DPP Registry: what has been available since July 2026

The Commission confirmed that the DPP Registry became operational on 20 July 2026, together with a testing environment. The Registry stores unique identifiers and associated registration data. Complete product information remains decentralised with the responsible operator or its service provider. Registration is available through a user interface or API; technical documentation and support are accessible through the Commission portal. Source: Registry launch announcement.

A project therefore needs to distinguish at least three tasks: maintain accurate product information, provide the passport with appropriate access controls and register the required data. A registration identifier is not proof of compliance. ESPR Article 13(5) makes this explicit. A successful test request likewise does not demonstrate that every product datum is correct and complete.

What data does the DPP contain?

There is no universal list of 50, 80 or 100 mandatory fields for every product. Under the ESPR, specific requirements are defined by product group. Use the following areas to structure a data inventory, rather than treating them as a finished legal checklist.

For each data point, record its legal source, applicability, internal source, owner, unit or format, approval status, access level and update trigger. A missing value, an inapplicable requirement and an unverified value are different states. Keeping them separate makes gaps actionable.

Access levels also belong in the data model. Public information must not be confused with confidential compositions or test documentation restricted to authorities. Who may access which information depends on the applicable rules. For the battery-specific structure, see our battery passport guide.

DPP and PIM: what product data management can contribute

A PIM system can consolidate product attributes, relationships and languages, support validation rules and deliver approved data through interfaces. A DAM system can manage related documents and media. These capabilities support preparation when the data model, rules, interfaces and responsibilities have been configured.

The legal requirements do not prescribe that particular software category. ERP, PLM, specialist systems and a passport service can also perform parts of the process. A PIM does not automatically calculate a substantiated carbon footprint, measure battery health or confirm compliance. Those data and decisions need suitable sources and accountable specialists.

Pilot example, not an additional legal requirement: A supplier corrects a material value. Check whether the responsible team can associate the evidence, identify affected products, approve the change and update the correct passport version. Also verify that an unauthorised user still cannot retrieve the confidential source data.

Prepare for the Digital Product Passport in five steps

1. Establish product category, role and legal position

Map products to the applicable rules. Record market role, passport level, binding date and unresolved details. Where product-specific rules are still being developed, separate confirmed requirements from assumptions that will need review.

2. Inventory data and evidence

Locate information in ERP, PLM, PIM, DAM, specialist systems and supplier records. Assess quality, missing values and evidence. A product data sheet does not mean sustainability values already exist; measurement or calculation may be a separate task.

3. Define the data model and ownership

Agree authoritative sources, identifiers, units, approvals and change processes. Establish delivery formats with partners. Central access can help without requiring every specialist or usage datum to move into one database.

4. Test delivery and registration

Test the route from approved source data through the passport to the data carrier and required registration. Include access controls, error handling, recovery and long-term availability. Use official technical resources and the testing environment relevant to your product group.

5. Accept the pilot and organise operations

Select representative products and test complete workflows, including corrections, supplier changes and expiring documents. Record remaining gaps. Then plan rollout, training and operations. A general three-, six- or twelve-month estimate is not reliable without assessing data and integration work.

Evaluate software and costs realistically

Compare proposals against the same tasks: data model, existing interfaces, document relationships, access, updates and passport delivery. Ask which capabilities are standard, configuration, add-ons or external services. The label “DPP-ready” does not establish the assessed scope or acceptance criteria.

apollon offers OMN PIM and DAM for product information and associated documents. A DPP project needs explicit agreement on sources, modules, passport service, registration and handovers. Our product data preparation page describes this contribution; it does not promise a complete regulatory solution.

A budget should cover data collection and cleansing, specialist evidence, configuration, interfaces, passport service and registration, testing, training and ongoing maintenance. Existing systems may reduce work but need assessment. Compare total costs for the same scope. This article does not offer an evidenced universal price range for a compliant DPP project.

Frequently asked questions about the Digital Product Passport

When does the Digital Product Passport become mandatory?

It depends on product category and legislation. The battery passport starts for the specified categories on 18 February 2027. ESPR product groups depend on their respective acts and application dates. The timeline above separates fixed dates from planning years.

Is a PIM system mandatory?

No. You need an appropriate process and technical solution for the applicable requirements. PIM and DAM can help maintain product information and documents. They do not automatically replace passport delivery, Registry integration, specialist evidence or access management.

What format must the DPP use?

The ESPR requires open standards and interoperable data that are, as appropriate, machine-readable, structured and searchable. Check implementation against applicable standards and product rules. An arbitrary JSON or XML export is not proof of compliance. See ESPR Articles 10 and 11.

Does the obligation apply to existing products?

Check placing on the market, possible putting into service and the relevant transitional provisions. Warehouse stock, products already placed on the market and materially modified products are not equivalent. A single yes or no across all DPP rules would be misleading.

Does the DPP replace the EU energy label?

Introducing a DPP does not automatically remove existing labelling or information obligations. Check their interaction for the specific product group. Energy labels, product information and passports may fulfil different, connected purposes.

When does the DPP apply to construction products?

The Construction Products Regulation’s general application from 8 January 2026 is not a universal passport start date. Article 75 provides for an act establishing the passport system; Article 80 links the obligation to 18 months after that act enters into force. Product scope and transitions also need review. This does not establish a general “from 2028” deadline.

Can I also use the information in product communication?

Approved, evidenced product information can support shops, sales and service. Respect purpose, access rights and confidentiality. A regulatory disclosure does not automatically substantiate every environmental or advertising claim.

Start with a reliable data inventory

Begin with a defined product group, applicable requirements and a traceable data inventory. This identifies specialist questions, necessary interfaces and realistic pilot tasks. It also shows what existing systems can do and where additions are needed.

Prepare product data for the DPP

Bring sample products, existing evidence and an overview of your systems. Together, we can assess how OMN can support data maintenance and document relationships, and which additional services the project needs.

Contact apollon