Digital product passports – an overview

Many products sold within the EU will soon require a so-called digital product passport. The upcoming requirements mean that products must have some form of data carrier that accompanies them throughout their entire lifecycle. The aim is to increase transparency and ensure traceability throughout the value chain by providing information on material composition and how products can be used, recycled, and disposed of safely. The rules are intended to make it easier for consumers and businesses to make informed choices and to support regulatory oversight by authorities. However, how this will work in practice and the content of the digital product passport may vary across different product categories.

The requirements for digital product passports are introduced through several EU legal frameworks that together cover the majority of goods manufactured and sold within the EU. The most comprehensive is Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products (the “Ecodesign Regulation”). In addition to the product groups regulated by the Ecodesign Regulation, batteries are also subject to requirements for specific battery passports under the new Battery Regulation. Furthermore, requirements for digital product passports will also be introduced for construction products through the revision of the Construction Products Regulation.

The primary responsibility for creating and providing digital product passports lies with the manufacturer. However, this responsibility may transfer to importers and distributors if they place products on the market under their own name or trademark, modify products in a way that affects compliance with relevant requirements, or (for batteries) modify the product’s purpose. In other cases, importers and distributors must ensure that the product is linked to a digital product passport before it is placed on the market or made available on the market. For batteries, specific rules also apply regarding, inter alia, repurposing or remanufacturing. In such cases, responsibility for the battery passports transfers to the economic operator who subsequently places the battery on the market or puts it into service, and that operator must create a new battery passport linked to the original battery’s battery passport.

It is the Commission that, through delegated acts, decides which product groups will be subject to the requirement for digital product passports under the Ecodesign Regulation. As part of this work, the Commission shall adopt a working plan specifying which products are to be subject to ecodesign requirements. The plan shall cover a period of at least three years and be updated regularly.

In April 2025, the working plan for 2025–2030 was adopted. The plan includes a list of the products that will be prioritized for the establishment of ecodesign requirements, along with the estimated timelines for these. According to the plan, the Commission will adopt delegated acts in the coming years for four final products (textiles/clothing, furniture, tires, and mattresses), two intermediate products (iron and steel, and aluminum), and two horizontal ecodesign requirements (repairability, and recycled content and recyclability of electrical and electronic equipment). The horizontal requirements do not primarily regulate a specific product but rather a certain characteristic common to a wide range of products. The acts are scheduled to be adopted successively during the period 2026–2029. As a general rule, the date of application of a delegated act – when the requirements begin to apply – may not fall earlier than 18 months from the entry into force of the delegated act, which allows some time for adaptation for the stakeholders affected by the requirements regarding, among other things, digital product passports.

The content of the digital product passports will be defined in more detail for each product type through the aforementioned delegated acts, but may, for example, include information on the product’s technical performance, materials and origin, repair and recycling potential, and environmental impact.

The Commission will continuously expand the number of product groups covered, which is why it is important to monitor developments even if the company’s products are not included in the first priority groups. However, certain products are completely exempt from the Ecodesign Regulation and thus also from any future requirements for digital product passports, including food and feed, pharmaceuticals, and live plants and animals.

Battery passports under the Battery Regulation will become mandatory as of February 18, 2027. This applies to light means of transport batteries, industrial batteries with a capacity greater than 2 kWh and all electric vehicle batteries – regardless of capacity – that are placed on the market or put into service. Battery passports must contain comprehensive information about the battery, material composition – including its chemistry – capacity, performance, and durability, carbon footprint, information on the responsible sourcing of raw materials, and instructions for safe handling of waste batteries.

In addition, the revised Construction Products Regulation introduces requirements for digital product passports for construction products. The requirements are effective from January 8, 2026, and, among other things, grant the Commission the authority to adopt delegated acts to supplement the regulation by, for example, establishing a system for digital product passports. The mandate is valid for a period of five years starting January 7, 2025, and means that the Commission will specify in the coming years what will apply regarding digital product passports for various product categories. The digital product passports must include, among other things, a declaration of performance and conformity, general product information, instructions for use and safety information, as well as technical documentation. Work is ongoing, and the system has not yet been established. Once such a delegated act has entered into force, manufacturers will also have 18 months in these cases to make such a digital product passport available in the system.

In summary, requirements for digital product passports will be phased in over the coming years, and such passports will become mandatory for a wide range of products supplied within the EU. Since the requirement for battery passports takes effect as early as February 2027, preparations – for companies that manufacture or sell batteries in the relevant categories – should already be underway. Other product groups will be regulated through upcoming delegated acts, and more detailed product-specific requirements will be introduced gradually. It is therefore important to ensure now that suppliers can provide the necessary information to comply with the new requirements, and that this is reflected in supplier agreements. This is particularly relevant for entities operating, or intending to operate, within any of the focus areas already identified – but adequate preparations should be in place for all product groups not explicitly exempted.

If you have questions about how the new requirements affect your business and what needs to be done to ensure compliance, please feel free to contact us.