Digital product passport: which products need one in the EU, and from when

A digital product passport is a set of data about one product, opened by scanning a code on the product, its packaging or its papers (Art. 2(28)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 28Click opens the article on EUR-Lex., Art. 10(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 10, paragraph 1Click opens the article on EUR-Lex.). The EU framework for it is Regulation (EU) 2024/1781Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationThe whole regulationClick opens the law on the EU Publications Office., the Ecodesign for Sustainable Products Regulation, or ESPR, in force since 18 July 2024 (Art. 80Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 80Click opens the article on EUR-Lex.). The same law bans the destruction of unsold clothes and shoes.

What applies now, and what waits

What a digital product passport is

The passport is a set of data specific to a product, reached through a data carrier, such as a QR code or a barcode, that links to a unique product identifier (Art. 2(28)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 28Click opens the article on EUR-Lex., Art. 2(29)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 29Click opens the article on EUR-Lex., Art. 2(30)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 30Click opens the article on EUR-Lex.). The carrier sits on the product, its packaging or the documents that come with it, as the delegated act sets (Art. 10(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 10, paragraph 1Click opens the article on EUR-Lex., point (b)). Scanning it opens the data each person may see: customers, repairers, recyclers, authorities and others have free access, each to their own part (Art. 11Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 11Click opens the article on EUR-Lex., point (b)). Personal data about a customer goes into it only with that customer’s explicit consent (Art. 10(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 10, paragraph 1Click opens the article on EUR-Lex., point (e)).

It exists so that everyone along the chain can find and understand the product information that concerns them, so authorities can check compliance, and so products can be traced (Art. 9(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 9, paragraph 3Click opens the article on EUR-Lex.). Each delegated act picks what goes in from this list (Annex III):

• the product information the act requires, such as performance, repair and end-of-life information, and the substances of concern in the product;
• the unique product identifier, the product’s Global Trade Identification Number, and its commodity code;
• compliance documents, such as the declaration of conformity, technical documentation or certificates, and the manuals, instructions, warnings and safety information other EU laws require;
• the manufacturer, the importer with its EORI number, and the EU-based operator responsible for the product under Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. or GPSR;
• the service provider that hosts the back-up copy.

The act also sets whether the passport is kept per model, per batch or per individual item, who may create or update it, and how long it stays available: at least the product’s expected lifetime (Art. 9(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 9, paragraph 2Click opens the article on EUR-Lex., points (d), (g) and (i)). It must stay online even if the business behind it goes insolvent or leaves the EU (Art. 11Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 11Click opens the article on EUR-Lex., point (e)). The business that created it stores it, or a digital product passport service provider does, and that provider may not sell or reuse the data beyond its service unless agreed (Art. 11Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 11Click opens the article on EUR-Lex., point (c), and its second paragraph).

How to create one, once your product group is covered. The data follows open, interoperable standards (Art. 10(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 10, paragraph 1Click opens the article on EUR-Lex., point (d)). The identifiers and carriers follow ISO/IEC 15459 (Annex III). Six harmonised standards for the passport itself, EN 18216 and EN 18219 to EN 18223, were published on 15 July 2026, and a passport that follows them is presumed to meet the essential requirements (Art. 41(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 41, paragraph 2Click opens the article on EUR-Lex.; Implementing Decision (EU) 2026/1736). The passport is registered in the EU registry, which returns a unique registration identifier (Art. 13(4)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 13, paragraph 4Click opens the article on EUR-Lex., Art. 13(5)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 13, paragraph 5Click opens the article on EUR-Lex.). Only a verified business may register one: a company proves who it is with a qualified electronic seal or an equivalent attestation under the EU’s eIDAS rules, and the verification lasts at most three years before it is repeated (Implementing Regulation (EU) 2026/1778, Art. 4(2) and 4(4)). A third party you authorise may register for you once it has passed verification itself, and you stay fully responsible (its Art. 19(4); Art. 8(2) for the passports of other EU laws).

When a product needs a passport

A product covered by an ESPR delegated act may be placed on the market only if it meets that act’s requirements (Art. 3(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 3, paragraph 1Click opens the article on EUR-Lex.). Those requirements always include a passport, with two exceptions: an act containing horizontal requirements, common to two or more product groups, need not require one, and an act may exempt its group (Art. 5(7)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 5, paragraph 7Click opens the article on EUR-Lex., Art. 7(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 7, paragraph 2Click opens the article on EUR-Lex., point (a) and last subparagraph, Art. 9(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 9, paragraph 1Click opens the article on EUR-Lex., Art. 9(4)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 9, paragraph 4Click opens the article on EUR-Lex.). The Commission may exempt a group where no technical specifications for the passport exist yet, or where another EU law already gives the same information digitally (Art. 9(4)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 9, paragraph 4Click opens the article on EUR-Lex.). The Commission’s working plan names the EU energy label database, EPREL, as such an alternative for energy-labelled products (COM(2025) 187, section 3.2).

Each act names its product group with commodity codes and gives businesses at least 18 months between its entry into force and its date of application, except in duly justified cases (Art. 8Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 8Click opens the article on EUR-Lex., point (a), Art. 4(4)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex.). The duty attaches when each unit is placed on the market, that is, first made available in the EU (Art. 2(40)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 40Click opens the article on EUR-Lex.).

On 5 October 2026 no delegated act setting ecodesign requirements for a product group had been adopted. What exists under the ESPR is this:

Implementing Regulation (EU) 2026/1778 was published on 17 July 2026 and enters into force on the twentieth day after (its Art. 24). The first delegated act could not enter into force before 19 July 2025 (Art. 4(7)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 4, paragraph 7Click opens the article on EUR-Lex.).

Which product groups are planned, and when

The ESPR told the Commission which groups to put first: iron and steel, aluminium, textiles (garments and footwear in particular), furniture including mattresses, tyres, detergents, paints, lubricants, chemicals, energy-related products, and ICT and other electronics (Art. 18(5)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 18, paragraph 5Click opens the article on EUR-Lex.). The first working plan, adopted on 16 April 2025, turned that into this list (COM(2025) 187, section 2.2.1):

These are dates of adoption, not of application. Each act then gives at least 18 months before it binds (Art. 4(4)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex.). The Commission’s own passport timeline puts the iron and steel act in the fourth quarter of 2026 and the textiles, aluminium and tyres acts in the third and fourth quarters of 2027.

The plan leaves out detergents, paints and lubricants. Footwear gets only a study, due by the end of 2027, and chemicals a scoping study (section 2.2.3). It also carries over sixteen energy-related products from the old ecodesign plan, among them household washing machines and dishwashers (2026), displays (2027), fridges and freezers (2028), and mobile phones, tablets and tumble dryers (end of 2030) (section 2.2.2). The Commission may also regulate a group that is not in the plan (Art. 5(6)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 5, paragraph 6Click opens the article on EUR-Lex.).

Which EU laws already require a passport

The ESPR is the framework, but other EU laws set passports of their own. The registry takes the passports of batteries under the Batteries Regulation, construction products under Regulation (EU) 2024/3110, toys under Regulation (EU) 2025/2509Regulation (EU) 2025/2509, Toy Safety RegulationThe whole regulationClick opens the law on the EU Publications Office., and detergents and surfactants under Regulation (EU) 2026/405, next to those of ESPR product groups (Implementing Regulation (EU) 2026/1778, Art. 1(1)).

• Batteries, from 18 February 2027. The battery passport guide covers it.
• Toys, from 1 August 2030. Before placing a toy on the market, its manufacturer creates a passport for the toy model stating that the toy’s compliance has been demonstrated (Art. 19(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 1Click opens the article on EUR-Lex., Art. 19(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 2Click opens the article on EUR-Lex., Art. 59Regulation (EU) 2025/2509, Toy Safety RegulationArticle 59Click opens the article on EUR-Lex.). Toys placed on the market under the old Toy Safety Directive before that date can still be sold (Art. 57(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 57, paragraph 1Click opens the article on EUR-Lex.). How the toy passport replaces the declaration of conformity is in CE marking; the rest of the toy rules are in CE marking for toys and the Toy Safety Regulation page.
• Detergents and end-user surfactants, from 23 September 2029. Before placing one on the market, its manufacturer creates a passport for that model, stating that its compliance has been demonstrated (Regulation (EU) 2026/405, Art. 21(1), 21(2)(a) and (b), Art. 37). Goods that meet the old Regulation (EC) No 648/2004 and were placed on the market before that date can still be sold; those placed in the following year can be sold until 23 September 2030 (its Art. 36).
• Construction products follow the dates of their own law.

How the battery passport works from 18 February 2027

From 18 February 2027 each LMT battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the market or put into service has an electronic record, the battery passport, opened through the QR code on the battery (Art. 77(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 1Click opens the article on EUR-Lex., Art. 77(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 3Click opens the article on EUR-Lex.). Which batteries count, who makes and keeps it, what it holds and who can open which part are in the battery passport guide; the rest of the battery rules, from registration to take-back, are in the EU Battery Regulation.

Who does what once a delegated act covers your product

The EU-based operator in the distance-selling row is the one the EU Responsible Person page covers.

What online marketplaces must do

For the ESPR, an online marketplace is a service that lets customers conclude distance contracts with businesses for products covered by a delegated act (Art. 2(54)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 54Click opens the article on EUR-Lex.). It gets the Digital Services Act duties on points of contact and on tracing the traders that sell through it (Art. 35(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 1Click opens the article on EUR-Lex.; Art. 11Regulation (EU) 2022/2065, Digital Services ActArticle 11Click opens the article on EUR-Lex., Art. 30Regulation (EU) 2022/2065, Digital Services ActArticle 30Click opens the article on EUR-Lex.). When a market surveillance authority asks, it cooperates with the action to end or limit the non-compliance of a product offered through it (Art. 35(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 1Click opens the article on EUR-Lex.).

National authorities can order a marketplace to act against the listings of a non-compliant product, including removing them; such listings count as illegal content under the Digital Services Act (Art. 35(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 2Click opens the article on EUR-Lex.). The marketplace keeps a single contact point for those authorities, which may be the one it already runs for GPSR (Art. 35(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 3Click opens the article on EUR-Lex., Art. 22(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 1Click opens the article on EUR-Lex.).

For your listings, this means two things. The business that placed the product on the market owes the marketplace a digital copy of the passport code, so the buyer can reach the passport without holding the product (Art. 10(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 10, paragraph 3Click opens the article on EUR-Lex.). And a listing for a covered product without its passport can be taken down on an authority’s order. What marketplaces ask for under GPSR today is in GPSR marketplace requirements.

What the ban on destroying unsold clothes and shoes covers

Since 19 July 2026, destroying the unsold consumer products listed in Annex VII is prohibited (Art. 25(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 1Click opens the article on EUR-Lex.). The list uses the EU’s combined nomenclature codes:

What counts. “Destruction” is intentionally damaging a product or discarding it as waste. Sending it on only to be prepared for reuse, refurbished or remanufactured is not destruction (Art. 2(34)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 34Click opens the article on EUR-Lex.). “Unsold” covers surplus stock, excess inventory, deadstock, and products a consumer returned under the right of withdrawal (Art. 2(37)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 37Click opens the article on EUR-Lex.). Only products primarily intended for consumers count as consumer products; components and intermediate products never do (Art. 2(36)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 36Click opens the article on EUR-Lex.).

Who is bound. Every business in the chain counts: manufacturer, importer, distributor, dealer, fulfilment service provider (Art. 2(46)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 46Click opens the article on EUR-Lex.). The ban does not apply to micro and small enterprises, and reaches medium-sized ones from 19 July 2030 (Art. 25(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 1Click opens the article on EUR-Lex.). The EU definition applies: a small enterprise employs fewer than 50 people and has an annual turnover or balance sheet total of no more than EUR 10 million; a medium-sized one employs fewer than 250 and has a turnover of no more than EUR 50 million or a balance sheet total of no more than EUR 43 million (Art. 2Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2Click opens the article on EUR-Lex.; Recommendation 2003/361/EC, Annex, Art. 2). The staff and money of partner and linked enterprises are added in, so a small company linked to a large one counts as large (its Annex, Art. 3 and 6). A business outside the ban may not destroy goods passed to it to get around the ban (Art. 25(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 2Click opens the article on EUR-Lex.). Every business, whatever its size, takes the measures that can reasonably be expected to avoid having to destroy unsold consumer products (Art. 23Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 23Click opens the article on EUR-Lex.).

When destruction stays allowed. Delegated Regulation (EU) 2026/296, which applies from 19 July 2026, lists the cases (its Art. 2 and 6):

The records are kept in electronic form and handed to the authorities within 30 days of a request (its Art. 3). You also give the waste treatment operator a statement naming the derogation you used (its Art. 4). “Cost-effective” has its own definition: repair costs no more than destroying the product and replacing it (its Art. 1).

The Commission may add other products to Annex VII by delegated act, and when it first picks candidates it is to consider electrical and electronic equipment in particular (Art. 25(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 3Click opens the article on EUR-Lex., Art. 18(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 18, paragraph 3Click opens the article on EUR-Lex.). The ban is separate from producer responsibility for textiles, which each EU country is setting up; that is in EPR in the EU.

What large businesses must publish about discarded stock

A business that discards unsold consumer products, itself or through someone else, publishes each year, on an easily accessible page of its website: the number and weight discarded per type of product, the reasons, the share sent to reuse, recycling, other recovery or disposal, and what it did and plans to do to prevent it (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex.). This covers every consumer product, not only clothes and shoes. It does not apply to micro and small enterprises, and reaches medium-sized ones from 19 July 2030 (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex.).

The first disclosure covers the first full financial year during which the Regulation is in force; for a business whose financial year is the calendar year, that is 2025 (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex., Art. 80Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 80Click opens the article on EUR-Lex.). A business bound to publish sustainability reporting in its management report may include the information there as well (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex.). Under the common format, its website may link to that report instead of repeating it, if the report gives the information in that format; this, like the format itself, covers each financial year from the first full one after 2 March 2027, so from 2028 for a calendar year (Implementing Regulation (EU) 2026/2, Art. 1 and 2(2)). On request, it proves where the discarded goods went within 30 days (Art. 24(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 2Click opens the article on EUR-Lex.).

Implementing Regulation (EU) 2026/2 fixes the format from 2 March 2027 (its Art. 7). It applies to products discarded in each financial year from the first full financial year after that date, and the disclosure is due within 12 months after the year ends (its Art. 1). Products are grouped by the first two digits of their combined nomenclature code, four digits for the products its Annex II lists (its Art. 3). The records behind it are kept for five years (its Art. 4). Donated products are not discarded and are not reported (its recital 3).

What happens if you do nothing

Each EU country sets the penalties for breaking the ESPR. They must be effective, proportionate and dissuasive, and must at least be able to impose fines and a time-limited exclusion from public procurement (Art. 74(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 74, paragraph 1Click opens the article on EUR-Lex., Art. 74(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 74, paragraph 3Click opens the article on EUR-Lex.).

Besides fines, the product itself can be stopped. A covered product without its passport may not be placed on the market (Art. 9(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 9, paragraph 1Click opens the article on EUR-Lex.). The ESPR does not say which procedure a missing passport falls under. Our reading: an authority may treat it as formal non-compliance, a missing administrative requirement, which it orders put right and, if it persists, restricts or prohibits the product or has it withdrawn or recalled (Art. 71(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 71, paragraph 1Click opens the article on EUR-Lex., point (h), Art. 71(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 71, paragraph 2Click opens the article on EUR-Lex.); or it may treat the product as presenting a risk and require corrective action after an evaluation (Art. 69Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 69Click opens the article on EUR-Lex., Art. 2(57)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 57Click opens the article on EUR-Lex.). A marketplace can be ordered to remove the listing (Art. 35(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 2Click opens the article on EUR-Lex.).

At the border, whoever releases a covered product for free circulation gives customs its unique registration identifier, from the moment the registry is operational (Art. 15(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 15, paragraph 1Click opens the article on EUR-Lex.). Once the registry is linked to the EU customs single window, customs release the product only after checking that identifier and the commodity code against the registry (Art. 15(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 15, paragraph 2Click opens the article on EUR-Lex.). That link is due within four years of the registry act entering into force on 6 August 2026, so by August 2030 on our count (Art. 15(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 15, paragraph 3Click opens the article on EUR-Lex.).

A consumer harmed by a product that breaks its ecodesign requirements can claim from the manufacturer; if the manufacturer is outside the EU, from the importer or the authorised representative; if the importer is outside the EU or there is no authorised representative, from the fulfilment service provider (Art. 76Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 76Click opens the article on EUR-Lex.).

What you can skip for now

What the law leaves open

• What goes into each passport. The ESPR lists what a passport may hold; each delegated act picks the data, the level (model, batch or item), who may see and change what, and how long it stays available (Art. 9(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 9, paragraph 2Click opens the article on EUR-Lex., Annex III). Until an act exists for your product group, nobody can tell you exactly what your passport will contain.
• Who may run a passport for you. The requirements to become a digital product passport service provider, and any certification scheme, come by a later delegated act (Art. 11Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 11Click opens the article on EUR-Lex., third paragraph). The Commission’s passport timeline puts it in 2027.
• Who may read a battery passport’s restricted parts. The act naming the persons with a legitimate interest is not adopted; the battery passport guide has its status.
• When the disclosure duty first bites. The ESPR counts from the first full financial year the Regulation is in force (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex.); the common format counts from the first full financial year after 2 March 2027 (Implementing Regulation (EU) 2026/2, Art. 1). The Commission reads the two together: the duty runs from the earlier date, the format from the later one (its recital 8).