# Digital Product Passport Requirements by Product Category Source: https://activatedigital.ai/knowledge/digital-product-passport Last verified: 1 September 2026 Summary: Compare EU Digital Product Passport requirements by product category: current status, data, dates, access and what is still being developed. ## In 60 seconds 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. - Batteries: adopted, applying from **18 February 2027**. - Detergents and surfactants: an adopted model-level regime, generally applying from **23 September 2029**. - Toys: an adopted model-level regime, applying from **1 August 2030**. - Textiles, tyres, iron and steel, aluminium, furniture and other groups are at different stages of development, with no adopted passport requirement. - ESPR requires the product-specific delegated act to decide the data, the carrier detail and whether a passport works at model, batch or item level. But the **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. So 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**. Detergents and surfactants have an adopted model-level DPP regime under separate 2026 legislation, generally applying from **23 September 2029**. Toys have another adopted model-level passport regime applying from **1 August 2030**. 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. 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 claim. This does **not** mean "definitely no". - **Not applicable**: the regime or field does not meaningfully apply in that context. | Product category | Current DPP position | Key timing | What businesses should understand now | |---|---|---|---| | **Batteries** | **Adopted, applies later** | 18 February 2027 for covered LMT, industrial >2 kWh and EV batteries | The Battery Passport is detailed and combines model-level with individual-battery information. It is a strong real example, but not a universal DPP template. | | **Textiles & apparel** | **In official development** | Commission currently plans the textile ESPR delegated act for Q4 2027 | Final textile DPP fields, access rules and granularity are not yet fixed. Official preparatory work is useful evidence of direction, not final law. | | **Detergents & surfactants** | **Adopted, applies later** | Regulation generally applies from 23 September 2029 | The adopted regime uses a model-level DPP and specifies mandatory product, operator, compliance and ingredient information. | | **Toys** | **Adopted, applies later** | 1 August 2030 | The adopted regime is model-level and includes identity, operator, conformity and selected safety information. | | **Tyres** | **In official development** | 2027 delegated-act track | Tyres already have regulated label/database information, but that existing data must not be presented as final DPP content. | | **Iron & steel** | **In official development** | Q4 2026 is the Commission's indicative delegated-act timing | This is a near-term regulatory track, but exact final DPP data should wait for the adopted act. | | **Construction products** | **Adopted framework, implementation pending** | Commission indicates further DPP implementation work in 2027 | The Construction Products Regulation establishes a DPP-system framework, including product-type architecture. Further implementation is still required. | | **Aluminium** | **In official development** | 2027 delegated-act track | Exact product-specific passport data are not final. | | **ICT & electronics** | **In official development / product-specific** | Measures run across the current ESPR work programme | Do not assume one universal "electronics DPP". In some cases, an equivalent digital system such as EPREL may be used rather than a separate DPP. | | **Furniture** | **In official development** | 2028 delegated-act track | Keep the category on the watchlist. Exact DPP content is not final. | | **Mattresses** | **In official development** | 2029 delegated-act track | The category is prioritised, but a detailed passport field list is not yet established. | | **[Footwear](https://activatedigital.ai/knowledge/digital-product-passport/footwear)** | **In official development** | Separate official study due by end 2027 | Study-stage evidence should not be presented as an adopted footwear DPP. | | **Food** | **Not applicable to ESPR** | No ESPR DPP date | Food is expressly excluded from ESPR. Existing food-information and traceability law still creates substantial structured product data. See [whether food supplements need a passport](https://activatedigital.ai/knowledge/digital-product-passport/food-supplements). | | **Beauty & cosmetics** | **Not established** for a generic EU DPP | No confirmed generic DPP date | Cosmetics already have structured regulatory information such as the Product Information File and electronic notification, but that is not the same as a DPP. | | **Jewellery & watches** | **Not established** for a generic EU DPP | No confirmed generic DPP date | Product-safety, chemical and some supply-chain rules may apply, but current evidence does not establish one generic EU jewellery DPP. | | **Chemicals** | **In official development / study** | No final generic DPP date | The Commission has signalled further work rather than a settled generic chemicals DPP specification. | | **Paints / lubricants** | **Not established** in the current first Working Plan | No current product-specific DPP timetable | Do not turn earlier ESPR priority discussions into a current final passport requirement. | **Existing Knowledge:** [Textile DPP Timeline and Regulatory Status](https://activatedigital.ai/knowledge/status/textile-passport) remains the specialist textile timing page. [Who Needs a Digital Product Passport?](https://activatedigital.ai/knowledge/regulation/who-carries-the-obligation) 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. Think of the EU approach 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. 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. The detergent regime includes intentionally added substances and, where relevant, microorganism information. Toy DPP data include CE marking, relevant standards/certificates and specified allergenic fragrances. 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. **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 a **comparison**, not a universal checklist. It uses the regulatory relationship of each field in each category. "Required under other law" means the data is already regulated, but it should not be labelled as DPP content unless the relevant passport law says so. | Product information | Batteries | Textiles | Detergents | Toys | Tyres | Construction | Iron / steel | Food | Cosmetics | Jewellery | |---|---|---|---|---|---|---|---|---|---|---| | **Product / model identity** | Adopted, applies later | In development | Adopted, applies later | Adopted, applies later | Required under other tyre law | Adopted framework | In development | Required under food law | Required under cosmetics law | Required under general product-safety law where applicable | | **Manufacturer / responsible operator** | Adopted, applies later | In development | Adopted, applies later | Adopted, applies later | Existing adjacent requirements | Framework / product-law dependent | In development | Food business-operator rules apply | Responsible-person rules apply | Manufacturer/economic-operator rules may apply | | **Manufacturing facility / factory** | **Adopted, applies later**: manufacturing-plant location is specified | **In development**: production-site concepts appear in official preparatory work | Not established as a mandatory passport field | Required under other toy technical-documentation rules, not the mandatory DPP field set | Not established as a final DPP field | Not established as a universal DPP field | Not final | Not a generic DPP field | Manufacturing method belongs in the PIF, not a generic DPP | Not established as a generic DPP field | | **Country of origin / provenance** | Do not confuse with plant location | In development / not final | Not established as mandatory DPP data | Not established as mandatory DPP data | Not established as final DPP data | Product-specific | In development / not final | Required in defined food-law circumstances | Required for imported cosmetics in defined contexts | No generic DPP provenance field established | | **Composition / materials / ingredients** | Adopted, applies later | Fibre composition is already regulated under textile law; future DPP treatment is still developing | **Adopted, applies later**: ingredient/substance information | Selected allergen data in the DPP; broader materials data also exist in technical documentation | Existing tyre data do not yet equal a final DPP composition requirement | Product-specific framework | In development | Ingredients required under food law | Ingredients / safety data regulated under cosmetics law | Substance restrictions may apply under REACH | | **Recycled content** | Part of the adopted battery passport architecture where underlying obligations apply | In official development, not final | Not established as mandatory DPP data | Not established | Circularity direction under development | Product-specific | In development | Not a generic DPP field | Not a generic DPP field | Not established as a generic DPP field | | **Carbon / environmental information** | Battery passport architecture includes carbon-footprint information where underlying obligations apply | In official development, not final | Not a universal mandatory field in the adopted detergent dataset | Not established as mandatory DPP data | Future DPP treatment not final | Product-specific | Sustainability information is under development | Separate food/environmental rules may apply; no generic DPP | Separate claims/environmental rules may apply; no generic DPP | Separate claims/environmental rules may apply; no generic DPP | | **Durability / performance / repair** | Extensive adopted performance, durability and dismantling information | In official development | Not a core mandatory field set | Not a general DPP requirement | Existing tyre performance data are already regulated, but future DPP reuse is not final | Performance/conformity is central to the framework | Product-specific development | Not a DPP regime | Not a generic DPP regime | Not a generic DPP regime | | **Conformity / safety** | Adopted passport references include conformity information | Development + existing textile law depending on subject | Adopted compliance statement / legal references | **Adopted, applies later**: CE, standards and conformity references | Existing tyre law applies | Central to construction framework | In development | Existing food law | Existing cosmetics law | Existing product-safety / chemicals law | | **Traceability / lifecycle / end of life** | Extensive model + individual lifecycle information | Traceability/circularity concepts are under development | Adopted traceability identity, but not a battery-style lifecycle history | Adopted traceability identity; not a battery-style lifecycle model | Existing tyre identification + future circularity work | Product-type framework | In development | Existing food traceability law | Existing product/batch structures | Existing product identification; selected upstream duties may apply | 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:** we already have specialist pages for [Country of Origin on a Textile Passport](https://activatedigital.ai/knowledge/fields/country-of-origin), [Carbon, Water and Environmental Data in a Textile DPP](https://activatedigital.ai/knowledge/evidence/environmental-figures), [Durability and Repairability in a Textile DPP](https://activatedigital.ai/knowledge/evidence/durability-and-repairability) and the governed [Textile DPP Data: 22-Field Guide](https://activatedigital.ai/knowledge/fields). The 22-field guide is a readiness and evidence model, **not 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. 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. [Existing Knowledge: Barcodes and Product Identifiers](https://activatedigital.ai/knowledge/fields/identifiers). [Product, Operator and Facility Identifiers](https://activatedigital.ai/knowledge/fields/the-three-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. 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](https://activatedigital.ai/knowledge/passport/choosing-a-carrier-that-still-works). ### The EU DPP Registry The Registry became operational on **20 July 2026**. 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. See [EU DPP Registry: Where Passport Data Actually Lives](https://activatedigital.ai/knowledge/regulation/where-passport-data-lives) and [DPP Registry Records: Your Audit Trail and Personal Data](https://activatedigital.ai/knowledge/evidence/what-the-registry-records). ### 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. 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](https://activatedigital.ai/knowledge/passport/who-sees-what). ### Model, batch or item? ESPR explicitly allows the applicable product act to specify whether a DPP is created at **model, batch or item level**. Adopted regimes already show different approaches: - batteries combine model information with individual-battery lifecycle data - detergents are model-level by default - toys are model-level, subject to interaction with other Union law - construction uses a product-type architecture. 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](https://activatedigital.ai/knowledge/guides/granularity), which is our current 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. 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](https://activatedigital.ai/knowledge/digital-product-passport/batteries) ### 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](https://activatedigital.ai/knowledge/regulation/what-a-delegated-act-decides). It explicitly says implementation timelines may evolve. 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. 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](https://activatedigital.ai/knowledge/fields/recycled-content) or another study field already mandatory DPP data. Existing destinations: [What Is a Textile Digital Product Passport?](https://activatedigital.ai/knowledge/regulation/textile-product-passport), [Textile DPP Timeline and Regulatory Status](https://activatedigital.ai/knowledge/status/textile-passport) and [Textile DPP Data: 22-Field Guide](https://activatedigital.ai/knowledge/fields). ### 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**. It shows DPP design already diverging across product laws. [Detergent and Surfactant Digital Product Passport Requirements](https://activatedigital.ai/knowledge/digital-product-passport/detergents) ### 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. The law also shows the risk of 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. [Toy Digital Product Passport Requirements](https://activatedigital.ai/knowledge/digital-product-passport/toys) ### Tyres Tyres are on the current ESPR development track. Existing tyre law already structures product information including tyre identification and performance/label data. 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](https://activatedigital.ai/knowledge/digital-product-passport/tyres) ### 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. 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](https://activatedigital.ai/knowledge/digital-product-passport/iron-steel) ### 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. 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](https://activatedigital.ai/knowledge/digital-product-passport/construction-products) ### Aluminium Aluminium is on the 2027 ESPR development track. Exact passport contents, access and granularity are not final. [Aluminium Digital Product Passport Requirements](https://activatedigital.ai/knowledge/digital-product-passport/aluminium) ### 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. [EPREL](https://activatedigital.ai/knowledge/digital-product-passport/tyres/eprel-data-reuse) is an important precedent and possible alternative architecture for some energy-related products. Existing Knowledge: [EPREL: What a Mandatory EU Product Register Produced](https://activatedigital.ai/knowledge/evidence/what-a-product-register-produces). [ICT and Electronics Digital Product Passport Requirements](https://activatedigital.ai/knowledge/digital-product-passport/ict-electronics) ### Food Food is expressly excluded from ESPR's scope. 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. 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](https://activatedigital.ai/knowledge/digital-product-passport/product-category-scope) ### 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. 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](https://activatedigital.ai/knowledge/digital-product-passport/product-category-scope) ### 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. 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](https://activatedigital.ai/knowledge/digital-product-passport/product-category-scope) ## The timeline: do not turn a planned act into a compliance deadline DPP dates are often oversimplified. Several different dates 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. | Timing | What it means | |---|---| | **20 July 2026** | The EU DPP Registry became operational. | | **Q4 2026** | Current Commission indicative timing for iron/steel delegated act and battery access-rights implementation work. | | **18 February 2027** | Battery Passports become mandatory for the covered battery categories. | | **2027** | Current development track includes textiles, tyres and aluminium, with the textile page specifying Q4 2027 as planned delegated-act timing. | | **2028** | Furniture delegated-act track in the current Working Plan. | | **2029** | Mattresses and other measures remain on the Working Plan horizon. | | **23 September 2029** | Detergents and surfactants regulation generally applies. | | **1 August 2030** | Toy Safety Regulation generally applies. | **An indicative delegated-act date is not a legal application deadline.** For the full date list, see [every dated DPP obligation](https://activatedigital.ai/knowledge/data). 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?](https://activatedigital.ai/knowledge/digital-product-passport/timeline) ## 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. 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. **Build a flexible product-data system around verified category requirements. Do not hard-code an imagined universal DPP schema.** ## Which 2D code should you actually use? That is a separate implementation decision from whether the product needs a passport. The safe order is **product law -> passport granularity -> identifier -> encoded syntax -> physical carrier -> routing**. A QR Code, GS1 DataMatrix and Data Matrix carrying a GS1 Digital Link URI can all be relevant in different implementations, but they are not interchangeable names for the same thing. If the question is **which 2D architecture to choose**, use the [2D Product Identity Map](https://activatedigital.ai/knowledge/passport/2d-product-identity-map). If the question is **whether EU law requires GTIN or GS1**, keep using [Barcodes and Product Identifiers: What You Need](https://activatedigital.ai/knowledge/fields/identifiers). For the legal effect of the standards themselves, use [DPP Standards and Presumption of Conformity](https://activatedigital.ai/knowledge/status/standards). ## What businesses can prepare now The absence of one universal field list does not mean businesses should wait. 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](https://activatedigital.ai/knowledge/fields/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 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](https://activatedigital.ai/knowledge/evidence), [When a Test Contradicts a Supplier Declaration](https://activatedigital.ai/knowledge/evidence/conflicting-values), [What You May Publish When You Do Not Know](https://activatedigital.ai/knowledge/evidence/stating-what-you-do-not-know) and [Which Product Attributes Are Worth Fixing Once](https://activatedigital.ai/knowledge/guides/product-data-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](https://activatedigital.ai/knowledge/guides/what-to-do-now) and [Is Your Product Data Ready for a DPP?](https://activatedigital.ai/knowledge/guides/the-data-you-already-have) go deeper on readiness. Preparation is limited by what you already hold, not by what any act will eventually ask for. You can [check what your existing product data can support](https://activatedigital.ai/dpp-readiness-checker), which is a data check and not a compliance statement. ## 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 claim. 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](https://activatedigital.ai/knowledge/evidence). [How We Know: Sources, Status and Evidence for Digital Product Passport Requirements](https://activatedigital.ai/knowledge/digital-product-passport/methodology) ## 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. ### 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. [Existing Knowledge: DPP identifiers](https://activatedigital.ai/knowledge/fields/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. ### Is all DPP information public? No. Access is category-specific. Battery law, for example, includes public and restricted access classes. [Existing Knowledge: Who Can See What in a DPP?](https://activatedigital.ai/knowledge/passport/who-sees-what). ### 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. ### 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?](https://activatedigital.ai/knowledge/digital-product-passport/timeline) ### 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](https://activatedigital.ai/knowledge/guides/what-to-do-now). ## 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 adopted, what is developing, what is already required elsewhere and what remains unknown. ## Keep exploring The questions this page usually raises next. - [Go deeperCross-category referenceWhen does each category actually apply?Broad scope naturally leads to timing.→](https://activatedigital.ai/knowledge/digital-product-passport/timeline) - [Go deeperSpecific questionWhat about food, cosmetics or jewellery?→](https://activatedigital.ai/knowledge/digital-product-passport/product-category-scope) - [Related questionCross-category referenceWhat can I prepare before every rule is final?Moves from status to low-regret action.→](https://activatedigital.ai/knowledge/guides/the-data-you-already-have) ## In this section The approved Passport resources that sit under this page. - [Go deeperCategory requirementsBattery Digital Product Passport RequirementsWhich batteries need an EU Battery Passport from 18 February 2027, what data it contains, who can access it and what businesses can prepare now.→](https://activatedigital.ai/knowledge/digital-product-passport/batteries) - [Go deeperCategory requirementsDetergent and Surfactant Digital Product Passport RequirementsWhat Regulation (EU) 2026/405 requires for detergent and end-user surfactant DPPs, including model-level data, ingredients, carriers and 2029 timing.→](https://activatedigital.ai/knowledge/digital-product-passport/detergents) - [Go deeperCategory requirementsToy Digital Product Passport RequirementsWhat the EU Toy Digital Product Passport contains, when it applies, how model-level identity works and why factory technical-documentation data is not automatically passport data.→](https://activatedigital.ai/knowledge/digital-product-passport/toys) - [Go deeperCategory requirementsTextile Digital Product Passport RequirementsWhat is actually known about EU textile Digital Product Passport requirements, what Q4 2027 means, which data are still developing and what to prepare now.→](https://activatedigital.ai/knowledge/digital-product-passport/textiles) - [Go deeperCategory requirementsTyre Digital Product Passport RequirementsWhat is currently known about EU tyre Digital Product Passport requirements, how tyre-label and EPREL data differ from future DPP rules and what to prepare now.→](https://activatedigital.ai/knowledge/digital-product-passport/tyres) - [Go deeperCategory requirementsConstruction Products Digital Product Passport RequirementsWhat the EU Construction Products Regulation already establishes for Digital Product Passports, what still needs implementing and what manufacturers should prepare now.→](https://activatedigital.ai/knowledge/digital-product-passport/construction-products) - [Go deeperCategory requirementsIron and Steel Digital Product Passport RequirementsIron and steel DPP status, Q4 2026 delegated-act timing, candidate data, CBAM overlap and what manufacturers can safely prepare now.→](https://activatedigital.ai/knowledge/digital-product-passport/iron-steel) - [Go deeperCategory requirementsAluminium Digital Product Passport RequirementsCurrent EU aluminium DPP status, 2027 ESPR timing, CBAM overlap, what data is not final and the low-regret product data to prepare now.→](https://activatedigital.ai/knowledge/digital-product-passport/aluminium) - [Go deeperCategory requirementsICT and Electronics Digital Product Passport RequirementsHow EU DPP rules are emerging for ICT and electronics, where EPREL fits, which data already exists and why there is no universal electronics passport.→](https://activatedigital.ai/knowledge/digital-product-passport/ict-electronics) - [Go deeperCross-category referenceFactory, Manufacturing Location and Country of Origin in Digital Product PassportsDoes a DPP require factory or country-of-origin data? Separate manufacturer, plant, facility ID, country of manufacture, origin, provenance and supplier location by regime.→](https://activatedigital.ai/knowledge/digital-product-passport/factory-origin) - [Go deeperHow we knowHow We Know: Sources, Status and Evidence for Digital Product Passport RequirementsHow ActivateDigital distinguishes EU law, adopted future rules, official development, adjacent law and uncertainty in Digital Product Passport research.→](https://activatedigital.ai/knowledge/digital-product-passport/methodology) Also worth reading - [What to do nextSmall businessDigital Product Passport Readiness for Small Businesses: What to Check FirstSmall team or no dedicated compliance function? Start with the small-business readiness sequence.→](https://activatedigital.ai/knowledge/guides/small-business-dpp-readiness) ## Related - [Who Checks DPP Information? Registry, Conformity and Market Surveillance](https://activatedigital.ai/knowledge/evidence/who-checks-dpp-information): Does registration prove every field is compliant? - [GS1 Digital Link: What It Is, What Resolves It and How It Carries a Passport](https://activatedigital.ai/knowledge/fields/gs1-digital-link): GS1 Digital Link as an implementation choice, not a universal mandate - [DPP Data Requirements: Mandatory, Conditional and Voluntary Information](https://activatedigital.ai/knowledge/passport/mandatory-conditional-voluntary-data): Mandatory, conditional and voluntary DPP data are different things - [Can One 2D Barcode Handle Checkout, Packaging Information and a Passport?](https://activatedigital.ai/knowledge/passport/one-2d-barcode-pos-ppwr-dpp): when one data carrier can serve several Union-law information duties - [Digital Product Passports and Personal Data: Where GDPR May Apply](https://activatedigital.ai/knowledge/passport/personal-data-and-gdpr): Can a DPP contain personal data? - [How a DPP Requirement Moves from EU Planning to an Applicable Product Rule](https://activatedigital.ai/knowledge/regulation/how-dpp-requirements-take-effect): How to read the status behind each product rule - [Where Do I Start With a Digital Product Passport?](https://activatedigital.ai/knowledge/start): Where to start, and the six routes through Knowledge ## Primary sources - [**Regulation (EU) 2024/1781 (ESPR)**, especially Articles 1 and 9-13 and Annex III. EUR-Lex](https://eur-lex.europa.eu/eli/reg/2024/1781/oj) EU law - [**Regulation (EU) 2023/1542 concerning batteries and waste batteries**, especially Articles 77-78 and Annex XIII. EUR-Lex](https://eur-lex.europa.eu/eli/reg/2023/1542/oj) EU law - [**Regulation (EU) 2026/405 on detergents and surfactants**, especially Articles 21-25, 37 and Annex VI. EUR-Lex](https://eur-lex.europa.eu/eli/reg/2026/405/oj) EU law - [**Regulation (EU) 2025/2509 on the safety of toys**, especially Articles 19-23, 49, 59 and Annex VI. EUR-Lex](https://eur-lex.europa.eu/eli/reg/2025/2509/oj) EU law - [**ESPR and Energy Labelling Working Plan 2025-2030, COM(2025) 187 final.** EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187) Official guidance - [**European Commission: Textile apparel and the Digital Product Passport.**](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/textile-apparel_en) European Commission - [**Regulation (EC) No 1223/2009 on cosmetic products**, including Articles 11 and 13. EUR-Lex](https://eur-lex.europa.eu/eli/reg/2009/1223/oj) EU law - [**Study in support of the Digital Product Passport for textiles**, JRC/Product Bureau supporting material, May 2026.](https://susproc.jrc.ec.europa.eu/product-bureau/sites/default/files/2026-05/Textiles_DPP_20260513.pdf) Official study - [**European Commission: The Digital Product Passport Registry is now live**, 20 July 2026.](https://single-market-economy.ec.europa.eu/news/digital-product-passport-registry-now-live-2026-07-20_en) European Commission - [**Commission Implementing Regulation (EU) 2026/1778** on the DPP Registry. EUR-Lex](https://eur-lex.europa.eu/eli/reg_impl/2026/1778/oj) Delegated or implementing act - [**Regulation (EU) 2024/3110 on construction products**, especially Articles 75-80. EUR-Lex](https://eur-lex.europa.eu/eli/reg/2024/3110/oj) EU law - [**Regulation (EU) 2020/740 on tyre labelling.** EUR-Lex](https://eur-lex.europa.eu/eli/reg/2020/740/oj) EU law - [**European Commission: Digital Product Passport for Iron & Steel.**](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/iron-steel_en) European Commission - [**Regulation (EU) No 1169/2011 on food information to consumers.** EUR-Lex](https://eur-lex.europa.eu/eli/reg/2011/1169/oj) EU law - [**Regulation (EC) No 178/2002, General Food Law**, especially Article 18 traceability. EUR-Lex](https://eur-lex.europa.eu/eli/reg/2002/178/oj) EU law - [**Regulation (EU) 2023/988 on general product safety**, especially Article 9 product identification/manufacturer duties. EUR-Lex](https://eur-lex.europa.eu/eli/reg/2023/988/oj) EU law - [**Regulation (EC) No 1907/2006 (REACH)** and relevant substance restrictions/communications. EUR-Lex](https://eur-lex.europa.eu/eli/reg/2006/1907/oj) EU law - [**European Commission: Digital Product Passport implementation timeline.**](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en) European Commission *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.*