Digital Product Passport Requirements by Product Category

There is no single universal Digital Product Passport checklist. The EU's Digital Product Passport framework sets common rules for how passports work, including product identification, data carriers, interoperability, persistence and controlled access. But the actual product information inside a passport is set by the legislation that applies to the relevant product category. ESPR itself requires product-specific delegated acts to decide the data, carrier details and whether a passport works at model, batch or item level.¹ That means two products can both have a Digital Product Passport and still have different:

• legal bases
• application dates
• data requirements
• access rules
• identifiers
• model, batch or item-level requirements
• levels of regulatory certainty.

Batteries already have a detailed adopted passport regime applying from 18 February 2027.² Detergents and surfactants have an adopted model-level DPP regime under separate 2026 legislation, generally applying from 23 September 2029.³ Toys have another adopted model-level passport regime applying from 1 August 2030.⁴ Textiles, tyres, iron and steel, aluminium, furniture and other product groups are at different stages of ESPR development. Their final product-specific DPP requirements should not be presented as settled before the relevant acts are adopted.⁵⁶ So the useful question is not simply "What fields are required in a DPP?" It is:

What information is required for this product category, under which law, from when, at what level, and who can access it?

This page is the central ActivateDigital reference for answering that question.

Find your product category

Status guide

• Required now: the relevant legal requirement currently applies.
• Adopted, applies later: the requirement is in adopted law but its application date has not arrived.
• Proposed / draft: an official draft or proposal exists but is not final law.
• In official development: a Commission plan, study or preparatory process indicates direction, but the final requirement is not settled.
• Required under other law: the information is legally required today under another regime, but is not established as DPP content.
• Not established: current evidence does not establish the proposition. This does not mean "definitely no".
• Not applicable: the regime or field does not meaningfully apply in that context.

Existing Knowledge: Textile DPP Timeline and Regulatory Status remains the specialist textile timing page. Who Needs a Digital Product Passport? remains useful for the separate question of which economic operators carry responsibilities.

Why there is no universal DPP template

A Digital Product Passport has a common system architecture, but that is different from saying every passport contains the same product data.

A useful way to think about the EU approach is in three layers.

1. Common DPP system architecture

ESPR establishes common technical and governance concepts. Product-specific rules then apply them.

The horizontal architecture includes concepts such as:

• a persistent unique product identifier
• a data carrier linking the physical product to the digital record
• interoperable, machine-readable information
• data persistence
• role-based access
• Registry interaction
• technical standards
• the possibility of model, batch or item-level passports.¹

These are system requirements. They are not the same thing as product-information fields.

2. Product information that recurs across regimes

Some information appears repeatedly because product law needs to identify the product and the responsible actors. Examples can include:

• product or model identity
• manufacturer or responsible economic operator
• classification or commodity information where applicable
• conformity or legal references
• traceability identifiers.

Recurring does not mean universal. A product-specific act still determines what belongs in that passport.

3. Category-specific information

This is where passports can diverge sharply.

Battery law includes battery chemistry, performance, expected lifetime, dismantling information and individual lifecycle data such as state of health.²

The detergent regime includes intentionally added substances and, where relevant, microorganism information.³

Toy DPP data include CE marking, relevant standards/certificates and specified allergenic fragrances.⁴

Future textile rules may select information relating to materials, circularity, production sites, environmental performance or other areas, but official preparatory work is not the same as an adopted textile field list.⁸

The consequence is important:

A real Battery Passport is evidence of what one regulated passport contains. It is not proof that every future DPP will contain the same information.

Product information: how the regimes differ

The table below is deliberately a comparison, not a universal checklist.

It uses the regulatory relationship of each field in each category. "Required under other law" means exactly that: the data is already regulated, but it should not be labelled as DPP content unless the relevant passport law says so.

This is why a green tick is not enough. The same field can be:

• adopted DPP law in one regime
• official development in another
• required under separate existing product law in another
• not yet established elsewhere.

Existing Knowledge: the estate already has specialist pages for Country of Origin on a Textile Passport, Carbon, Water and Environmental Data in a Textile DPP, Durability and Repairability in a Textile DPP and the governed Textile DPP Data: 22-Field Guide. The 22-field guide should remain a readiness/evidence model, not be repositioned as the statutory textile DPP schema.

Keep the DPP system separate from the product data

A common source of confusion is mixing the passport's technical architecture with the information the product law asks the passport to carry.

Product identifiers

ESPR requires a persistent unique product identifier as part of the DPP architecture.¹

That does not mean every DPP is legally required to use GTIN.

ESPR Annex III refers to GTIN or equivalent in the information architecture available to product-specific acts. Current primary evidence does not establish a universal rule that every DPP must use a GS1 GTIN or GS1 Digital Link.¹

Existing Knowledge: Barcodes and Product Identifiers should remain the specialist destination and be expanded cross-category. Product, Operator and Facility Identifiers remains useful for the separate identity-object question.

Data carrier

A data carrier connects the physical product, packaging or accompanying documentation to the passport as the applicable law specifies.¹

A QR code is one possible carrier used or specified in particular regimes. It is not a safe universal synonym for "Digital Product Passport".

For implementation choices, see QR, Data Matrix or NFC: Choosing a Lasting Carrier.

The EU DPP Registry

The Registry became operational on 20 July 2026.⁹

It is not simply a central database containing every piece of product-passport information. The architecture remains decentralised, while the Registry supports registration, identifiers and the regulatory information needed for discovery, verification and enforcement.⁹¹⁰

See EU DPP Registry: Where Passport Data Actually Lives and DPP Registry Records: Your Audit Trail and Personal Data.

Who can see the data?

Not everything in a DPP is necessarily public.

ESPR lets product-specific rules define access. Battery law is the clearest adopted example: it separates public information from information limited to authorities/notified bodies and information available to actors with a legitimate interest.²

That access structure should not be copied automatically into another category before its own law is final.

See Who Can See What in a Digital Product Passport.

Model, batch or item?

ESPR explicitly allows the applicable product act to specify whether a DPP is created at model, batch or item level.¹

Adopted regimes already show different approaches:

• batteries combine model information with individual-battery lifecycle data²
• detergents are model-level by default³
• toys are model-level, subject to interaction with other Union law⁴
• construction uses a product-type architecture.¹¹

So "every product needs its own item-level passport" is not an accurate universal rule.

See Model, Batch or Item Level for a Textile Passport, which is the current estate page to expand into the cross-category granularity reference.

Category snapshots

Batteries

The Battery Passport is currently the most detailed adopted example.

From 18 February 2027, each covered LMT battery, industrial battery above 2 kWh and electric-vehicle battery placed on the market or put into service must have an electronic battery passport.²

The passport mixes model information with information specific to the individual battery, including lifecycle information resulting from use. The Regulation also distinguishes public data from restricted access classes.

Safe conclusion: battery businesses can prepare against adopted requirements now.

Unsafe conclusion: all future DPPs will look like the Battery Passport.

Battery Digital Product Passport Requirements

Textiles & apparel

Textiles are an ESPR priority, but the product-specific passport requirements are still being developed.

The Commission currently gives Q4 2027 as the indicative timing for adoption of the textile delegated act. It explicitly says implementation timelines may evolve.⁶

Official preparatory work discusses candidate information territories and possible data architecture. That evidence is useful for readiness, but a study proposal is not a final legal requirement.⁸

Safe conclusion: organise strong product identity, evidence provenance and data governance now, and monitor likely category fields.

Unsafe conclusion: publish a fixed "2028 textile DPP deadline" or call factory, carbon, recycled content or another study field already mandatory DPP data.

Existing destinations: What Is a Textile Digital Product Passport?, Textile DPP Timeline and Regulatory Status and Textile DPP Data: 22-Field Guide.

Detergents & surfactants

The 2026 Detergents and Surfactants Regulation creates a separate adopted DPP regime.

It is model-level by default and includes mandatory product identity, manufacturer/operator information, compliance references and detailed ingredient information. The Regulation generally applies from 23 September 2029.³

This is strategically important because it demonstrates that DPP design is already diverging across product laws.

Detergent and Surfactant Digital Product Passport Requirements

Toys

The Toy Safety Regulation creates another adopted model-level DPP.

It applies from 1 August 2030 and requires passport information including a unique product identifier, manufacturer/economic-operator information, traceability identification, relevant conformity information, CE marking and specified allergenic fragrances.⁴

The law also provides a useful warning against over-reading product regulation: addresses of places of manufacture and storage appear in the technical documentation, but they are not simply part of the mandatory DPP data list in Annex VI.⁴

Toy Digital Product Passport Requirements

Tyres

Tyres are on the current ESPR development track.

Existing tyre law already structures product information including tyre identification and performance/label data.¹² That information may be relevant to future DPP design, but existing tyre-label data is not automatically future DPP content.

The correct current position is development, not a final requirements checklist.

Tyre Digital Product Passport Requirements

Iron & steel

Iron and steel is a near-term ESPR product group. The Commission currently indicates Q4 2026 for the delegated act and says exact information requirements will be defined through that process.¹³

Safe conclusion: this category deserves close monitoring now.

Unsafe conclusion: convert candidate product, material, circularity or sustainability information into a final statutory field list before the act is adopted.

Iron and Steel Digital Product Passport Requirements

Construction products

The Construction Products Regulation establishes an adopted construction DPP-system framework and requires the Commission to set up the construction DPP system by delegated act.¹¹

It is a useful comparator because its information architecture centres on product type, and because the operational framework is not identical to the Battery Passport.

Construction Products Digital Product Passport Requirements

Aluminium

Aluminium is on the 2027 ESPR development track.⁵

The category is important, but exact passport contents, access and granularity are not final.

Aluminium Digital Product Passport Requirements

ICT & electronics

The current Working Plan includes energy-related and ICT/electronics work, but it should not be reduced to one generic electronics-passport promise.

ESPR permits the Commission, in defined circumstances, to decide that another Union digital-information system achieves the relevant objectives rather than requiring a separate DPP.¹ EPREL is therefore an important precedent and possible alternative architecture for some energy-related products.

Existing Knowledge: EPREL: What a Mandatory EU Product Register Produced.

ICT and Electronics Digital Product Passport Requirements

Food

Food is expressly excluded from ESPR's scope.¹

That does not mean food lacks structured product-data obligations. Food law already covers areas such as ingredients, allergens, responsible food-business-operator information, origin in specified circumstances and traceability.¹⁴¹⁵

The correct current message is:

There is no generic ESPR food DPP requirement. Existing food information is adjacent regulation, not DPP law.

Does My Product Category Need a Digital Product Passport? Food, Cosmetics, Jewellery and Common Misstatements

Beauty & cosmetics

Current evidence does not establish one generic EU cosmetics DPP.

Cosmetics already have a substantial product-information regime, including the Product Information File, responsible-person duties and electronic notification to the Commission.⁷

Those systems create useful structured product data. They should not be renamed a Digital Product Passport.

Does My Product Category Need a Digital Product Passport? Food, Cosmetics, Jewellery and Common Misstatements

Jewellery & watches

Current evidence does not establish one generic EU jewellery or watches DPP.

General product-safety identification/manufacturer duties, REACH substance controls and selected upstream due-diligence regimes may apply depending on the product and operator.¹⁶¹⁷

Again, existing compliance data is useful. It is not evidence of a generic jewellery DPP.

Does My Product Category Need a Digital Product Passport? Food, Cosmetics, Jewellery and Common Misstatements

The timeline: do not turn a planned act into a compliance deadline

DPP dates are often oversimplified.

There are several different dates that matter:

• legislation adopted
• entry into force
• application
• DPP-specific application
• planned delegated act
• planned implementing act
• study or consultation milestone
• technical/Registry milestone.

Those are not interchangeable.

An indicative delegated-act date is not a legal application deadline.

That distinction is especially important for textiles. A planned Q4 2027 act does not, by itself, create a fixed "textile DPP compliance date".

Digital Product Passport Timeline: What Applies When?

What is genuinely common across DPPs?

The strongest commonality is infrastructure, not one product-data schema.

Across the EU DPP architecture, the recurring system concepts include:

• a persistent product identity
• a carrier linking the physical object to digital information
• machine-readable and interoperable data
• persistence
• controlled access
• standards
• Registry and enforcement integration where applicable.¹⁹¹⁸

Product information is more variable.

Identity and responsible-operator information recur frequently. So do conformity and traceability concepts. But carbon, recycled content, factory location, ingredients, durability or lifecycle information depend much more heavily on the product regime.

That is the core rule to carry into any implementation project:

Build a flexible product-data system around verified category requirements. Do not hard-code an imagined universal DPP schema.

What businesses can prepare now

The absence of one universal field list does not mean businesses should wait.

It means preparation should focus on low-regret data capabilities rather than speculative compliance fields.

Prepare

These are useful across regulated product-data programmes and expensive to reconstruct later:

Product identity and hierarchy Know how model, variant, batch and item relationships work in your own systems. Do not assume the final regulatory level, but make the relationships explicit.

Manufacturer and responsible-operator data Keep legal entity names, addresses, roles and identifiers controlled rather than scattered across free text.

Product classification Maintain category, customs or commodity classifications where they apply, with provenance and change history.

Existing regulated composition and product information If fibre composition, ingredients, safety data or other particulars are already required by current sector law, structure them now as current law, not as speculative DPP fields.

Conformity and evidence references Give declarations, certificates, test reports and other evidence stable identifiers, dates, owners and scopes.

Evidence provenance For every important product fact, know where it came from, what it actually proves, when it was checked and what happens if evidence conflicts.

Machine-readable data Avoid storing critical product truth only in PDFs, emails and narrative supplier notes.

Existing Knowledge: Passport Evidence: How We Know, and What a Blank Means, When a Test Contradicts a Supplier Declaration, What You May Publish When You Do Not Know and Which Product Attributes Are Worth Fixing Once.

Watch

Keep these flexible where official work points towards them but final category rules are not settled:

• textile production-site/facility information
• textile recycled-content methods
• textile environmental and durability information
• tyre circularity and future DPP fields
• iron/steel and aluminium product-specific information
• final service-provider rules
• final access rules in developing regimes.

Do not build around yet

Do not make the entire compliance architecture depend on assumptions that current primary evidence does not establish:

• every DPP uses GTIN
• every DPP uses GS1 Digital Link
• every DPP uses a QR code
• every DPP is item-level
• every category requires factory location
• every category requires carbon footprint
• every category requires recycled content
• every category exposes complete supply-chain data
• every consumer product will inevitably receive a DPP.

Existing Knowledge: How to Prepare for a Digital Product Passport and Is Your Product Data Ready for a DPP? remain the deeper readiness destinations.

How we know

ActivateDigital separates legal certainty from useful forward-looking evidence.

A statement marked Adopted, applies later is different from one marked In official development. A current labelling duty under another law is different from a DPP requirement. "Not established" means the evidence does not currently establish the proposition. It does not mean regulators have definitively rejected it.

For important regulatory statements, the evidence path should be:

plain-English answer → why this status → legal or official basis → primary source

The default page should stay readable. Detailed legal provisions belong in the supporting evidence layer.

The source hierarchy used here prioritises enacted EU law and EUR-Lex, then European Commission implementation material and official studies. Vendor pages are not used as authority for mandatory regulatory claims.

Existing Knowledge: Passport Evidence: How We Know, and What a Blank Means.

How We Know: Sources, Status and Evidence for Digital Product Passport Requirements

Direct answers

Does every product need a Digital Product Passport?

No universal rule says every physical product already needs a DPP. Requirements depend on applicable Union law and product-specific measures. Food, for example, is expressly outside ESPR.¹

Is there one standard Digital Product Passport template?

No. There is a common DPP system architecture, but product information, access and granularity differ by regime.

What information is required in a DPP?

There is no universal product-information field list. The relevant product law determines the required data. Use the category and product-information comparison above.

Does a DPP require a GTIN?

A persistent unique product identifier is part of the ESPR architecture, but current EU primary evidence does not establish GTIN as a universal requirement for every DPP.¹

Existing Knowledge: DPP identifiers.

Does every DPP require a QR code?

No universal QR-only requirement is established by ESPR. The applicable product law determines the carrier requirements. Particular regimes can specify or use QR or other carrier arrangements.¹

Is all DPP information public?

No. Access is category-specific. Battery law, for example, includes public and restricted access classes.²

Existing Knowledge: Who Can See What in a DPP?.

Are Digital Product Passports item-level?

Not universally. ESPR allows product-specific rules to choose model, batch or item level. Adopted regimes already use different approaches.¹²³⁴¹¹

When do Digital Product Passports become mandatory?

There is no single date. Battery Passports for covered batteries apply from 18 February 2027. Other categories have different legal or development timelines.

Digital Product Passport Timeline: What Applies When?

What should companies prepare now?

Prepare governed product identity, operator data, classifications, current regulated information, evidence provenance and machine-readable data. Watch category-specific development fields. Do not hard-code unconfirmed universal assumptions.

Existing Knowledge: How to Prepare for a DPP.

The practical rule

A Digital Product Passport is best understood as a common digital regulatory architecture with product-specific content.

That distinction prevents most of the expensive mistakes:

• treating a study as law
• treating a planned act as a deadline
• treating adjacent regulation as DPP content
• treating one adopted passport as the universal template
• hard-coding GTIN, QR, factory, carbon or item-level assumptions across every product.

Start with the category.

Then ask what is actually adopted, what is developing, what is already required elsewhere and what remains unknown.

That is the point of this Observatory.

Primary sources

• Regulation (EU) 2024/1781 (ESPR), especially Articles 1 and 9-13 and Annex III. EUR-Lex

  View official source

• Regulation (EU) 2023/1542 concerning batteries and waste batteries, especially Articles 77-78 and Annex XIII. EUR-Lex

  View official source

• Regulation (EU) 2026/405 on detergents and surfactants, especially Articles 21-25, 37 and Annex VI. EUR-Lex

  View official source

• Regulation (EU) 2025/2509 on the safety of toys, especially Articles 19-23, 49, 59 and Annex VI. EUR-Lex

  View official source

• ESPR and Energy Labelling Working Plan 2025-2030, COM(2025) 187 final. EUR-Lex

  View official source

• European Commission: Textile apparel and the Digital Product Passport.

  View official source

• Regulation (EC) No 1223/2009 on cosmetic products, including Articles 11 and 13. EUR-Lex

  View official source

• Study in support of the Digital Product Passport for textiles, JRC/Product Bureau supporting material, May 2026.

  View official source

• European Commission: The Digital Product Passport Registry is now live, 20 July 2026.

  View official source

• Commission Implementing Regulation (EU) 2026/1778 on the DPP Registry. EUR-Lex

  View official source

• Regulation (EU) 2024/3110 on construction products, especially Articles 75-80. EUR-Lex

  View official source

• Regulation (EU) 2020/740 on tyre labelling. EUR-Lex

  View official source

• European Commission: Digital Product Passport for Iron & Steel.

  View official source

• Regulation (EU) No 1169/2011 on food information to consumers. EUR-Lex

  View official source

• Regulation (EC) No 178/2002, General Food Law, especially Article 18 traceability. EUR-Lex

  View official source

• Regulation (EU) 2023/988 on general product safety, especially Article 9 product identification/manufacturer duties. EUR-Lex

  View official source

• Regulation (EC) No 1907/2006 (REACH) and relevant substance restrictions/communications. EUR-Lex

  View official source

• European Commission: Digital Product Passport implementation timeline. This is a regulatory information resource, not personalised legal advice. Product classification, scope and applicable obligations should be checked against the law applying to the specific product and operator.

  View official source

This is a regulatory information resource, not personalised legal advice. Product classification, scope and applicable obligations should be checked against the law applying to the specific product and operator.