Digital Product Passport: Which Products Are Affected?

The principle: almost all physical products on the EU market

The Digital Product Passport (DPP) is not a niche instrument for individual industries. The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) is built as a horizontal framework: the DPP scope covers almost all physical products on the single market, with the exception of a few clearly named categories such as food, feed, medicinal products and living organisms. Whether and when a specific product group actually receives DPP requirements is set out through the relevant delegated act of the European Commission, the legal instrument that specifies concrete requirements per product group. Adoption plus a transition period, which as a rule is around 18 months, gives the DPP deadline. This period can be shorter or longer depending on the act.

In parallel with the ESPR, further sectoral regulations use the DPP as a shared data infrastructure, each with its own purpose such as product safety, conformity or labelling. The most advanced is the EU Battery Regulation (Regulation (EU) 2023/1542), with a firmly anchored battery passport from 18 February 2027 for EV, industrial (>2 kWh) and LMT batteries. Alongside it, the PPWR, the Construction Products Regulation (CPR), the Toy Safety Regulation and the Detergents Regulation move in the same direction with their own digital information requirements; these are not always the same obligation mechanism as the ESPR DPP or the battery passport. For you, this means it is not only about the ESPR waves, but about which legal framework applies to your product category and whether it comes from the ESPR working plan or from a standalone sectoral regulation.

This principle is the most important point for your planning. The typical reaction inside companies is: "Our products are not on the first list, so this does not concern us." That reading falls short. The ESPR Working Plan, the European Commission's work programme for 2025 to 2030, prioritises product categories over time. Anyone not in the first ESPR wave in 2027 can follow in a later wave or fall under a sectoral regulation once the relevant act takes effect.

For you, this means the question is rarely "Am I affected?" but more often "Under which regulation and from when?". A structured answer on the timeline is given by the deadline deep dive in Digital Product Passport 2027.

Key takeaway: The ESPR framework is horizontal in design. Whether and when a product receives DPP requirements is decided by the delegated act or the sectoral regulation for the category.

Where the DPP obligation comes from: ESPR and sectoral regulations

Anyone wanting to understand which products a Digital Product Passport applies to has to read two parallel sets of rules. They interlock and together create the scope.

ESPR as the horizontal framework

The ESPR is the central act. It has been in force since July 2024 and replaces the old Ecodesign Directive of 2009. What is new is that the ESPR goes far beyond energy-using products and addresses all physical products on the single market. It anchors the DPP as a structural instrument but deliberately defines no concrete product lists. The detail comes through delegated acts, which the Commission issues according to a published work programme.

The logic behind this is pragmatic. A single law for all products would be politically unworkable and technically overloaded. Instead, the Commission prioritises individual categories through the ESPR working plan according to circular-economy and regulatory urgency. Each category gets its own act with specific data points, performance requirements and a transition period that as a rule is around 18 months, but can be shorter or longer depending on the act.

The regulatory framework and the mechanics of the ESPR are explained in detail in the ESPR Ecodesign Regulation.

Sectoral regulations with their own DPP rules

In parallel with the ESPR there is a growing number of sectoral regulations that set their own digital information or DPP-type requirements independently of the ESPR working plan, or that use DPP-like structures for safety, conformity and labelling. Five are currently particularly relevant:

The Battery Regulation (Regulation (EU) 2023/1542) defines the battery passport with a fixed deadline of 18 February 2027 for EV, industrial (>2 kWh) and LMT batteries. It is the prototype that many follow-on sectors take their lead from. Details in the overview on the Digital Battery Passport.

The Packaging and Packaging Waste Regulation (PPWR) points towards digital labelling and DPP-like data structures for packaging, strengthening the trend towards structured packaging data. The detailed requirements and timing are still to be confirmed, and this is not simply the same obligation mechanism as the ESPR DPP.

The Construction Products Regulation (CPR) is the actual framework for construction products and cement, not the ESPR. It moves towards harmonised, digital product information, for example on building materials, Environmental Product Declarations (EPD), pollutant content, reusability and dismantlability. DPP-like requirements are expected around 2029/2030, subject to the implementing rules.

The Toy Safety Regulation is expected to introduce a DPP-type requirement for toys from around August 2030, applying directly rather than via a separate delegated act and subject to the final rules. The purpose lies in product safety, proof of conformity and ingredients.

The Detergents Regulation is expected to introduce a DPP-type requirement for detergents and comparable cleaning products from around September 2029, likewise applying directly and subject to the final rules. The focus is on labelling, ingredients and safety.

Further sectoral DPP rules are in preparation, for example for mobility, chemicals and medical devices. The ESPR working plan and sectoral acts are not competing but cumulative: a product can fall under both and must meet both sets of requirements.

Key takeaway: The ESPR sets the horizontal framework; sectoral regulations may add their own digital information timelines, data points or DPP-type requirements. Check both sides at the same time.

Product categories and expected DPP-related timing at a glance

The following table shows the current status by product category, sorted by expected timing. Important: for the ESPR-prioritised categories these are indicative adoption windows, not confirmed DPP obligation dates. The actual obligation for a category only arises once its delegated act is adopted, plus the transition period. These best-case timings are drawn from the European Commission's ESPR Working Plan and can move back rather than forward. The sectoral regulations (batteries, PPWR, CPR, toys, detergents) follow their own timelines, some with fixed dates such as the battery passport and others still to be confirmed.

The table is not exhaustive. The European Commission updates the working plan every three years, and more often if needed. New categories can be added and existing ones prioritised earlier. Anyone who checks their range today only against the first wave will have to follow up in 2028 or 2029.

Four industries are particularly early on the current roadmap: batteries (fixed deadline 2027), with textiles, electronics and furniture in indicative working-plan windows between roughly 2027 and 2029. Anyone producing there has a realistic window for a structured implementation, provided you start capturing data today.

Key takeaway: The DPP obligation comes from two sources: the prioritised ESPR working plan and sectoral regulations with their own purpose (safety, conformity, labelling). Whether a product is affected, and when, is decided by the relevant act.

Industry by industry: which products are specifically affected

The categories in the ESPR working plan are broadly defined. Only a look into the specific product group shows which concrete products in your portfolio fall under the DPP obligation. The following sections provide an entry point per industry.

Batteries

The Battery Regulation distinguishes five battery categories. Three of them are subject to a battery passport from 18 February 2027. One caveat: result data such as the carbon footprint, recycled content and due-diligence information become mandatory only when the specific requirement applies, not automatically from 18 February 2027.

EV batteries (batteries for electric vehicles, classes M, N, O) are subject to a passport across the board, regardless of capacity or chemistry.

Industrial batteries above 2 kWh cover stationary storage systems, UPS systems, batteries in intralogistics, forklift batteries, rail applications and comparable uses. The 2 kWh threshold is sharply defined and refers to the rated capacity.

LMT batteries (Light Means of Transport) cover e-bikes, pedelecs, e-scooters, e-mopeds and comparable light vehicles. Device batteries (smartphone batteries, household appliances) and classic SLI starter batteries are excluded. Anyone who manufactures, imports or integrates batteries for use in the EU is regulatorily responsible. More on this on the industry page for battery and energy-storage manufacturers.

Textiles and fashion

Textiles are the first ESPR wave, with the delegated act in preparation. The focus is on apparel: outerwear, underwear, children's clothing. Alongside this, footwear, accessories (bags, belts, scarves), home textiles (bed linen, towels, curtains) and technical textiles are covered in principle by the horizontal framework, but some become concrete only in later delegated acts. So far, only very specific uses such as medical textiles are excluded, as these fall under their own regulation.

A particular point: for unsold textiles and footwear, the destruction ban for large companies additionally applies from 19 July 2026 (Article 25 ESPR). This means that goods that have not been sold may not simply be destroyed. Here a DPP-capable data layer can become a central documentation instrument for reuse, refurbishment or recycling of this stock. For the industry context and concrete data requirements, see the textile and fashion industry.

Electrical and electronic products

ESPR wave 1 covers electronics and ICT in a broad definition: computers, laptops, smartphones, tablets, displays, servers, network hardware, large household appliances such as fridges, washing machines, dryers, dishwashers and cookers, plus external power supplies, power tools and professional audio-video equipment. The data model builds on existing ecodesign requirements and adds repairability, energy consumption, material composition and end-of-life information. For manufacturers this means the existing energy-label data are part of the DPP but are expanded significantly. Details under electrical and electronics industry.

Furniture

On the current roadmap the furniture industry sits indicatively in ESPR wave 2, with a working-plan window around 2028/2029; the binding date depends on the delegated act. The scope covers residential furniture (sofas, chairs, tables, cabinets, beds), office furniture (workstations, office chairs, conference furniture), garden furniture, mattresses (already included in wave 1) and contract furniture for hospitality, catering and public buildings. Particularly relevant: the product lifecycle in the furniture industry is often very long, and resale and refurbishment play a growing role. A DPP can document materials, origin, care and repairability over the relevant lifecycle, depending on the delegated act and use case. Industry-specific data points and use cases under furniture industry.

Construction and construction products

Construction products do not fall under the ESPR, but directly under the Construction Products Regulation (CPR) with its own DPP framework. DPP-like requirements are expected around 2029/2030, subject to the implementing rules. This affects cement, precast concrete elements, insulation materials, roofing materials, construction chemicals, windows, doors, sanitary ceramics and metal-construction components. The data requirements cover Environmental Product Declarations (EPD), pollutant content, reusability and dismantlability. Typical for the industry: DPP data are passed on via general contractors and developers to end users and authorities, which requires structured B2B data flows. More on the construction industry.

Tyres, mechanical engineering, toys, detergents

Tyres are placed indicatively in ESPR wave 2 (around 2028) on the current roadmap. The DPP adds data points on material origin, mileage and recyclability to the existing tyre-labelling regulation.

Machinery and equipment fall into ESPR waves 1 and 2 via components such as electric motors, pumps, fans and drive systems, and as a complete machine via sectoral rules (Machinery Regulation). Scoping is therefore worthwhile at component level. More on mechanical and plant engineering.

Toys are expected to require a DPP-type passport from around August 2030, though not via the ESPR but directly via the Toy Safety Regulation, applying directly rather than via a separate delegated act and subject to the final rules. The DPP structures proof of conformity, safety data, ingredients and origin. Packaging for toys sits in parallel under the PPWR with DPP-like requirements whose timing is subject to PPWR implementation. Background on the toy industry.

Detergents and cleaning products are expected to require a DPP-type passport via the Detergents Regulation from around September 2029, likewise applying directly and subject to the final rules. The focus is on labelling, ingredients and safety. The Detergents Regulation is a good example of how a sectoral regulation integrates the DPP as a data infrastructure without coming from the ESPR working plan.

Food, outdoor, aerospace

Food and feed are explicitly excluded from the ESPR but fall under the Food Information Regulation (FIC) and related acts. Digital labelling instruments (smart labels) are emerging there in parallel, taking on DPP-like functions without formally qualifying as a DPP. Context under food industry.

Outdoor and leisure products (camping equipment, sports equipment, bicycles) sit in wave 3 or later waves from 2030, with overlaps to textiles (outdoor clothing) and electronics (e-bikes). Entry point via the outdoor and leisure industry.

Aerospace products do not fall directly under the ESPR, but sectoral proof obligations already apply to individual components (light metals, composites) and are developing towards a DPP. Monitored via the aerospace industry.

Key takeaway: Industry scoping happens at product-category level, not at industry level. Machine builders fall into wave 1 via components, and furniture makers with electrical parts into two waves at once.

Which products are not affected for now

In Article 1(2), the ESPR names a clear catalogue of products excluded from the scope. This list is short and unambiguous:

Food under Regulation (EC) No 178/2002, including beverages and food supplements. Labelling runs via the FIC, not via the DPP.

Feed under Regulation (EC) No 178/2002.

Medicinal products for human use under Directive 2001/83/EC, including vaccines. Product information runs via medicines legislation (EMA processes).

Veterinary medicinal products under Regulation (EU) 2019/6.

Living animals and plants.

Products of human origin (blood, tissue, cells).

Products derived directly from plants, animals or micro-organisms that are intended for human reproduction.

All other physical products fall in principle within the scope of the ESPR. Concrete DPP requirements only arise with the relevant delegated act or a sectoral regulation (as with toys, detergents or construction products). Anyone who checks their range and finds that it appears neither on the current ESPR working plan nor in a sectoral regulation is not permanently exempt. It only means the specific act is not yet in place.

In addition, individual products or product groups can be excluded through special provisions, for example for military goods, historic vehicles or products from very small batch production. These exceptions are narrowly defined and must be checked case by case against the specific act.

Key takeaway: The exemption catalogue is closed and narrow. Anyone not covered by the exemptions should monitor the development of future delegated acts and sectoral regulations. For many product groups, further requirements are to be expected.

How to assess your range in 15 minutes

The following guide gives you a structured scoping framework to clarify, in about 15 minutes, which of your products are subject to a DPP and from when.

1. List product groups by trade classification. Use the CN codes (Combined Nomenclature) or your internal product-group scheme. The aim is a clear list of all product categories you place on the EU market. Not at SKU level, but at category level.
2. Assign each category to a legal framework. Check against the table above or directly against the Commission's ESPR working plan. Result: for each category, an entry stating "ESPR wave 1 / 2 / 3, sectoral regulation, later, or exempt".
3. Check for sectoral overlaps. Do your products also fall under the Battery Regulation, the Construction Products Regulation, the PPWR or another sectoral regulation? If so, the earlier deadline applies and the sectoral data requirements accumulate with the ESPR framework.
4. Clarify your role in the market. Are you a manufacturer, importer, authorised representative or distributor? The DPP obligation sits regulatorily with whoever places the product on the market. As a distributor you are not primarily responsible, but you become co-responsible if you list products without a valid DPP from the relevant deadline. The role determines the specific supply obligations.
5. Assess the time you need. For each DPP-relevant category, plan for 6 to 12 months of implementation time plus 3 to 6 months to gather data from the supply chain. Subtract that from the deadline and you have the latest sensible starting point for implementation.

The result of the scoping is a matrix of product category, legal framework (ESPR wave or sectoral regulation), deadline and starting point. That is the basis for internal prioritisation, for briefing IT and compliance, and for the exchange with platform providers. Anyone going into those conversations without this matrix can neither judge their own urgency nor ask the right questions.

For a structured self-assessment with concrete questions on data maturity, use the DPP Readiness Check.

Key takeaway: Scoping produces a matrix of product category, legal framework, deadline and starting point. Without this matrix, every platform or budget discussion stays vague.

What "affected" means in practice

The question of which products need a Digital Product Passport has a second dimension: who exactly is responsible? The ESPR and the Battery Regulation recognise four roles that trigger different obligations.

Manufacturers usually carry primary responsibility. Depending on the product and the relevant act, whoever manufactures a product in the EU and places it on the market typically has to create and provide the DPP, register it where the act requires and keep it up to date where the act calls for dynamic data or updates. This applies regardless of whether the sale is to end customers, business customers or within a group.

Importers usually take on manufacturer-type obligations when a product is imported into the EU from a third country. In that case they typically carry responsibility comparable to an EU manufacturer, depending on the act, including providing the DPP in line with EU law.

Authorised representatives are appointed by non-EU manufacturers to take on regulatory responsibility within the EU. Typical for groups with production outside the EU and distribution through European subsidiaries.

Distributors are usually not primarily responsible but carry role-specific checking and listing obligations. Where products without a valid DPP are listed from the relevant deadline, distributors and platforms can share responsibility. This affects bricks-and-mortar retail as much as online platforms. In practice, Amazon, Zalando, Mercateo and others will block listings before an authority even checks.

A common misconception in mid-sized companies is: "We are only a small supplier, this does not concern us." That is not true. The DPP obligation has no revenue or headcount threshold. It applies when a covered product is placed on the market, regardless of company size. Relief exists only in very narrow cases (small quantities, specific exemptions in individual acts).

What many underestimate: depending on the product category, the DPP may be implemented at model, batch or individual-item level. Batteries are required at individual-item level; textiles may often be modelled at model level; and furniture with a long service life can benefit from individual-item passports, depending on the delegated act and use case, because repair, maintenance history and resale can be mapped through them. Anyone who reduces the DPP to an extended product page misses this granularity and the regulatory requirements for audit-proof records and alignment with the European DPP infrastructure, including a registry link where provided.

Where the relevant act requires lifecycle data or updates, the DPP does not end with the sale. Depending on the product group, it can accompany the product through use, maintenance, repair, resale and recycling. That is exactly what structurally distinguishes it from classic product-data systems such as a PIM or an ESG report, which end at publication.

Key takeaway: Four roles, no SME allowance. The role decides the obligation, not the size of the company.

Which products need a DPP: in numbers

Key takeaway: Three dates frame the scoping discussion: the EU DPP registry, expected to roll out in phases from 2026 and holding high-level metadata and identifiers while the full DPP data stays decentralised; 18 February 2027 (battery passport); and roughly 18 months of transition after each delegated act (variable by act).

Implementation with Narravero

Narravero operates an end-to-end DPP platform that helps translate clarified regulatory requirements into operational DPP implementation and strategic product-data use cases. More than 200 corporate customers across 12 industries use the platform, among them battery manufacturers, textile companies, furniture makers and electronics brands. The platform processes around 300 million platform interactions per month, EU-hosted and designed for GDPR-compliant processing.

On the scoping question, customers benefit from the platform's cross-industry practical experience. Data models and interfaces follow the work of CEN-CENELEC JTC 24 and GS1, and the platform roadmap follows the ESPR working plan and sectoral regulations.

A typical entry point is the DPP readiness analysis. We check with you which product categories of your range specifically fall under the ESPR waves or sectoral regulations, which data points are required in regulatory terms, where they sit today (ERP, PIM, supplier) and what is missing. The result is a concrete scoping and data plan with a timeline, matched to your deadlines.

If you are working on your DPP roadmap, the fastest next step is the free DPP Readiness Check. In a few minutes you get a structured assessment of which product categories are affected, which data points become relevant and where you should start.

Go to the DPP Readiness Check → Book a demo →

Key takeaway: A platform proven in production covers sectoral and horizontal requirements from a single infrastructure. Industry pages and the readiness check are the fastest entry points.

Frequently asked questions on the DPP scope

Which products need a Digital Product Passport?

In principle, the ESPR is designed as a horizontal framework for almost all physical products on the EU single market. Whether and when a specific product group needs a Digital Product Passport follows from the respective delegated acts or sectoral regulations. Batteries are subject to a fixed obligation from 18 February 2027. For the ESPR groups, the timings are indicative working-plan windows, for example textiles and electronics around 2027/2028 and furniture around 2028/2029; the actual obligation only arises once each delegated act is adopted, plus its transition period. Sectoral rules follow their own timing as DPP-type or digital-labelling requirements: packaging under the PPWR, detergents around September 2029, toys around August 2030 and construction products under the CPR around 2029/2030, each subject to the final or implementing rules. All of these dates are estimates and can shift.

Does the DPP also apply to B2B products?

Yes. The regulation does not distinguish by sales channel. Industrial products, components, semi-finished goods and professional equipment can fall under DPP or DPP-type obligations, provided the product category is regulated by the relevant delegated act or sectoral rule. The only condition is being placed on the EU market.

Are services affected?

No. The DPP applies exclusively to physical products. Services, software (as a pure product without hardware) and digital goods are not covered. As soon as software is embedded in hardware, the overall product falls under the relevant product category.

Does the DPP apply to used products?

The DPP obligation applies when a product is first placed on the market. Used products sold before the relevant deadline are not retroactively subject to a passport. Refurbishment and remanufacturing can, however, count as newly placing a product on the market, with a corresponding obligation for the refurbisher. The precise boundary is set by the delegated acts per category.

What applies to importers from third countries?

Importers usually take on manufacturer-type obligations within the EU. Anyone importing into the EU from China, Turkey, the USA or other third countries typically carries responsibility for the DPP, depending on the act. This usually includes creating it, registration with the EU DPP infrastructure where required and keeping it up to date where the act calls for dynamic data.

Are small quantities and one-off items affected?

In principle yes, although individual acts can define thresholds or relief for small quantities. Craft businesses and manufactories should check their categories specifically against the relevant delegated act. There is no blanket exemption for small producers.

Can products fall under several regulations at once?

Yes, this is the norm. A battery in an e-bike falls under the Battery Regulation (for the battery) and the ESPR (for the e-bike). A piece of furniture with electrical components falls under both the furniture delegated act and the electronics act. The obligations accumulate.

What happens with model variants and configurations?

Every regulated product variant placed on the market needs to be covered by a valid DPP at the granularity required by the relevant act. The regulatory question is whether DPPs are issued per model, per batch or per individual item. Batteries are required at individual-item level; textiles are often modelled at model level, with the option to refine to individual-item level depending on the delegated act and use case.

Does the DPP apply to small series or limited editions?

Yes. The obligation has no threshold for small series. What matters is not the number of units but the product category and being placed on the EU market.

What about repair and spare parts?

Spare parts are usually part of the DPP of the main product, not separately subject to a passport. Components placed on the market separately (such as replacement batteries or motor assemblies) can trigger their own DPP obligations. The details are set out in the relevant delegated acts.

What role does the DPP play for AI-driven purchasing and commerce systems?

AI agents in B2B procurement and B2C commerce will increasingly access structured product data to interpret requests and make a pre-selection. The DPP is therefore developing into a machine-readable, trustworthy data foundation that these systems need. Anyone who builds a complete DPP positions themselves for visibility in future agentic commerce and AI procurement interfaces. Building compliance thus becomes an investment in AI visibility.