ESPR preparation

Digital Product Passport — prepared today

The EU Ecodesign Regulation (ESPR) is making the Digital Product Passport mandatory for more and more product groups. PPWR-Ready structures your product data now — before the requirement applies to you.

Preparation for an upcoming EU requirement — not yet a confirmation of conformity, as the underlying EU rules are not yet final.

What is the digital product passport?

The digital product passport is a data set that accompanies a product throughout its life cycle and is retrievable via a data carrier — usually a QR code. Its legal basis is the Ecodesign Regulation (EU) 2024/1781 (ESPR), which replaced the earlier Ecodesign Directive.

The ESPR provides only the framework. What a passport must contain in detail is laid down by the Commission for each product group in a separate delegated act . Without such an act there is no passport obligation for a product group — and no way to describe a passport as complete.

That is why this page consistently speaks of preparation and not of conformity.

When does the product passport apply?

The position as at 28 September 2026 — and it is clearer than the public debate suggests:

  • The battery passport is the only passport obligation binding today. It applies from 18 February 2027 and is based not on the ESPR but on the Batteries Regulation (EU) 2023/1542.
  • The European DPP register has been operational since 20 July 2026 (Implementing Regulation (EU) 2026/1778). It is available — but the obligation to populate it arises only per product group.
  • Six harmonised standards have been listed since 15 July 2026 (Implementing Decision (EU) 2026/1736): EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223. They describe how a passport is structured technically.
  • There is no delegated act for packaging, and none for textiles either. Anyone offering an “ESPR-compliant product passport” for these groups today cannot point to any requirement.

So the infrastructure is in place and the obligations follow product group by product group. For companies this means: the data work can be done today, without waiting for the delegated act.

ESPR and PPWR: two passports that are often confused

This is the most common confusion on the subject — and it leads companies to prepare the wrong thing:

ESPR — the product passport

Concerns the product: durability, reparability, recycled content, substances of concern, carbon footprint. Regulation (EU) 2024/1781.

PPWR Article 12 — the packaging data carrier

Concerns the packaging: material composition and separate collection, as harmonised labelling. Regulation (EU) 2025/40.

Both are complementary, not identical. A product may require an ESPR passport and at the same time carry packaging that falls under Article 12 of the PPWR. More on the packaging side on the page PPWR — the EU Packaging Regulation.

What data does a product passport contain?

The exact scope is set out in the relevant delegated act. Across product groups, however, a common core is emerging:

  • Unique identifier of the product, the economic operator and the facility
  • Durability and reparability — service life, repair instructions, availability of spare parts
  • Substances of concern — which are contained and where
  • Recycled content and information on material composition
  • Carbon footprint — always stating the methodology, otherwise the figure cannot be placed in context
  • Disassembly and disposal instructions for the end of the life cycle

Three access levels, not one

A product passport is not fully public. The ESPR distinguishes who may see which field:

  • Public — retrievable by anyone, such as care instructions or material details
  • Authorities — for market surveillance and customs, such as details of the conformity assessment
  • Specialists — for repairers and recyclers, such as disassembly instructions

How it works

Capture your product data in a structured way

1
Create product data

Record durability, repairability, CO₂ footprint and other details per product.

2
Generate a QR code

Every product gets its own QR code linking to the public product passport page.

3
Publish and be ready

As soon as the ESPR requirement applies to your product group, your data is already prepared.

Benefits

A head start instead of last-minute stress

Prepared early

Capture the data calmly instead of scrambling right before the deadline.

One system for everything

Packaging reporting and product passport preparation run in the same dashboard.

Public QR page

Customers and authorities find the product passport data directly via the QR code on the packaging.

What PPWR-Ready prepares for the product passport

A product passport does not come from a form but from data that has to be maintained anyway. PPWR-Ready brings it together at the article:

  • Passport fields at the article — durability, reparability, spare parts, repair and disassembly instructions, substances of concern, carbon footprint with methodology
  • Field catalogue as an allow list — each field carries its access level (public, authority, specialist). What is not in the catalogue does not appear in the passport. That reverses the usual approach, in which everything is visible that has not been expressly blocked
  • Frozen versions — every publication fixes its data state; later changes create a new version instead of overwriting the old one
  • Public passport page with QR code — retrievable per article, optionally via the GS1 Digital Link notation
  • Battery passport as a separate module — with the data set of the Batteries Regulation, separate from the ESPR passport

And what the software does not do

Two limitations that belong to the matter:

  • No registration in the European DPP register. The register has been operational since July 2026; PPWR-Ready structures the data and makes it available, but does not register it there.
  • No statement of conformity. As long as no delegated act exists for a product group, no one can describe a passport as complete — not even software. What is created here is a structured body of data that can wait for the act.

PPWR-Ready is an independent software company and not legal advice. The software supports recording and structuring; responsibility for the information remains with the company.

Frequently asked questions about the digital product passport

Do I need a product passport today?

Only for batteries, and only from 18 February 2027. For all other product groups the obligation arises with the Commission’s respective delegated act.

Does the product passport also cover packaging?

Not through the ESPR — there is no delegated act for it. Packaging carries its own harmonised labelling under Article 12 of the PPWR. These are two different obligations.

What is the difference between the ESPR and the Ecodesign Directive?

The ESPR is a regulation and applies directly in all Member States. It replaced the earlier Ecodesign Directive and extended its scope far beyond energy-related products.

Is all data in the product passport public?

No. The ESPR distinguishes between publicly accessible information, information for authorities and information for specialists such as repairers and recyclers. Which field sits at which level follows from the delegated act.

Is it worth starting now?

The effort lies not in the passport itself but in obtaining the data — recycled content, substance details and carbon figures come mostly from suppliers. That work is independent of the delegated act and can be brought forward.

Sources

This page summarises the position as at 28 September 2026 and does not replace legal advice. The relevant legal act prevails; delegated acts per product group may set further requirements.

Related pages: PPWR · Product compliance · Conformity declaration · RoHS

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