Where Does a Digital Product Passport Have to Appear on an Ecommerce Product Page?

EU law already says the Digital Product Passport has to be accessible before the customer is bound by a distance-sale contract. It does not yet prescribe one universal button position or page layout. The product-specific rule will decide the exact presentation, while the product identifier and DPP still need to point to the right product record.

The legal requirement is access before contract, not a universal page design

Article 9(2)(e) of ESPR is unusually useful for ecommerce teams.

When the Commission writes a product-specific delegated act, that act must specify the manner in which the DPP is to be made accessible to customers before they are bound by a contract for sale, hire or hire purchase, including in the event of distance selling.

That means three things.

1. The ecommerce journey is part of DPP compliance

The physical data carrier alone is not enough for a distance sale if the customer cannot access the physical product before buying it.

2. The final presentation is product-specific

The horizontal Regulation gives the outcome. The delegated act decides the detailed manner for that product group.

3. Access needs the right product identity

An ecommerce link that opens a generic sustainability page is not the same thing as making the relevant product passport accessible.

The page must connect the customer to the passport for the product identity and granularity required by the applicable rule.

That last point is easy to underestimate. If the DPP is at model level, the model-level passport may be correct. If the product rule requires batch or item level, the ecommerce system needs enough information to resolve the correct passport for the thing being offered.

Use How many passports a range needs for the model, batch and item boundary, and Which Product Facts Belong at Model, Variant and SKU Level? for the catalogue architecture underneath it.

What the operator has to give the retailer or marketplace

Article 10(3) of ESPR makes the upstream handoff explicit.

The economic operator placing the product on the market must provide dealers and online marketplaces with:

• a digital copy of the data carrier or the Unique Product Identifier, as relevant, so they can make it accessible to potential customers who cannot physically access the product
• that digital copy or a webpage link free of charge, promptly and in any event within five working days of a request.

For a brand selling through its own store, the same underlying architecture is still useful even though there is no separate retailer handoff.

The governed product record should be able to produce:

product identity → DPP address → customer-facing access route

without somebody manually pasting a different URL into every channel.

That is where Barcodes and Product Identifiers and What actually happens when somebody scans the code connect directly to ecommerce.

What should actually be visible on the product page?

Where the final product-specific rule has not yet prescribed the layout, the safest implementation principle is to make the DPP access route clear, product-specific and available before the customer commits to the purchase.

That can be implemented without pretending the law has chosen a universal UI.

A reasonable product-page pattern might be:

Product information Digital Product Passport [View product passport]

or:

Product passport Product identity, materials, care and applicable regulated information [Open passport]

The exact wording is a design decision, not a legal quotation.

The important operational tests are:

• does the link resolve to the right product?
• is it available before purchase?
• can the same route be supplied to retailers and marketplaces?
• does the identity survive changes to the storefront URL?
• does a variant selection change the DPP route where the DPP identity or data changes?
• can the customer reach the passport without creating an account or paying for access where public access is required?
• are restricted DPP fields still protected according to the applicable access rules?

The DPP is a data-access requirement. It should not be implemented as a marketing badge with no identity control underneath it.

You probably do not need to render every passport field on the product page

Making the DPP accessible is different from copying the complete DPP into the ecommerce page.

The passport is a separate governed digital record. An ecommerce product page can provide the route to that record.

This separation matters because:

• the DPP can contain information intended for different actors
• some DPP information may have restricted access
• the DPP may need a different lifetime from the ecommerce listing
• the product may stop being sold while its passport still needs to remain available
• the merchant may move from Shopify to another platform while the passport identity should remain stable.

For access-right boundaries, see Who Can See What in a Digital Product Passport.

For continuity after a listing or company changes, see When the link dies and What you can take with you when you leave a provider.

The DPP does not replace the other information an online offer must show

This is where ecommerce teams can accidentally collapse several legal duties into one link.

GPSR Article 19 already requires specified information to be clearly and visibly indicated in a covered EU online offer, including:

• manufacturer information
• EU responsible-person information where applicable
• product identification
• applicable warnings and safety information.

A DPP link should not be assumed to discharge those Article 19 duties.

The GPSR listing requirement and future DPP access requirement solve different legal questions.

Your ecommerce data model may therefore need to support both:

information displayed directly in the offer

and

access to the DPP as a separate product record.

The current GPSR listing requirements are owned by What Product Information Must an EU Online Listing Show Under the GPSR?. Marketplace-specific gates are separated in What an Online Listing Has to Carry by Law.

Shopify is a catalogue, not the legal identity layer

For a Shopify merchant, the useful starting point is the existing catalogue.

Shopify already holds native product and variant identity, weight and some trade data, while other passport inputs sit in metafields, supplier records, evidence files or outside the store entirely.

That means the product page can become the customer access point without forcing the complete passport to live inside Shopify itself.

A clean architecture looks like:

Shopify product / variant ↓ governed product identity ↓ persistent DPP address ↓ DPP record

The Shopify page then exposes the relevant DPP route before purchase.

This is preferable to tying the passport permanently to a theme route such as:

/products/blue-shirt-v4

which can change for commercial reasons.

The deeper catalogue question is covered in Digital Product Passports from a Shopify catalogue.

What about `dppcode.org`?

In the ActivateDigital architecture, dppcode.org is intended to provide the persistent address and resolution layer behind passports published through ActivateDigital.

That lets the ecommerce page link to a stable passport identity without making the merchant's current storefront URL the permanent passport address.

It is not:

• the EU DPP Registry
• an EU-operated domain
• legally required
• proof of DPP compliance
• a claim that every resolver standard has already been demonstrated.

The architectural distinction is useful:

commerce page = where the customer encounters the offer DPP address/resolver = how the right passport is reached DPP = the governed product record EU Registry = the official registration/index layer where the applicable law requires registration

The annotated worked example is at An annotated textile Digital Product Passport.

For the wider business question behind that architecture, see what the EU DPP Registry still leaves your business to build, host and manage.

Do online marketplaces have a different job?

The operator placing the product on the market has to give the marketplace the relevant digital carrier, UPI or link so the marketplace can make the DPP accessible where the customer cannot physically access the product.

That does not mean every marketplace will present it identically.

The applicable DPP product rule sets the legal accessibility requirement. The marketplace then has to provide an implementation that satisfies its own duties and the information supplied by the trader or economic operator.

At the same time, online marketplaces also have separate obligations under GPSR and other EU platform and product rules.

Do not use “the marketplace has the passport link” as a substitute for checking whether the offer itself carries the legally required information.

A practical ecommerce data model

For each sellable product or variant, maintain at least:

The ecommerce page should consume those fields. It should not invent them.

What should a business do now?

If your product does not yet have a live DPP obligation

Do not hard-code an unconfirmed legal placement into every theme.

Instead:

• create a stable product identity layer
• make sure the ecommerce product can resolve to a governed record
• preserve model and variant relationships
• create a reusable “product passport” component that can be positioned or relabelled later
• keep the DPP route separate from the storefront slug
• do not publish a final legal checklist before the product-specific rule exists.

If your product already has an adopted DPP requirement

Read that product-specific law first.

Then test:

• the exact point in the customer journey where DPP access is required
• the correct product granularity
• the required public information
• the access-right model
• the retailer/marketplace handoff
• the physical carrier and online route as one identity system.

Direct questions

Does the DPP have to be visible before checkout?

For ESPR products, the product-specific rule must specify how the DPP is accessible before the customer is bound by the contract, including distance selling. The exact UI and timing within the ecommerce journey depend on that rule, so do not generalise a universal button position where one has not been adopted.

Do I have to show the full DPP on the product page?

The horizontal ESPR does not say that the full passport must be copied into the ecommerce page. It requires the DPP to be made accessible in the manner specified by the applicable product rule.

Is a QR-code image on the product page enough?

Not automatically. The key question is whether the customer can access the correct DPP for the offered product before contract in the manner the product-specific law requires. A clickable link or product-passport control may be a better customer implementation than an image that has to be scanned from another device.

Does Shopify already satisfy the DPP ecommerce requirement?

No platform status by itself satisfies a future product-specific DPP obligation. Shopify can host the customer journey and the link, but the business still needs the correct identity, passport and governed data behind it.

Does the DPP link replace GPSR Article 19 information?

Do not assume so. GPSR Article 19 separately requires specified information to be clearly and visibly indicated in the online offer.

What would change this page

Recheck this page when:

• a product-specific delegated act sets exact distance-sale DPP presentation rules
• the Commission publishes binding or authoritative ecommerce UI guidance for DPP access
• marketplace legislation adds a harmonised DPP field or presentation requirement
• the textile delegated act is adopted
• an applicable product regime chooses a different carrier, identity or access model.

Current Commission textile guidance is useful direction, but the future textile delegated act remains the legal point at which the detailed requirement is fixed.

Try it on one product

Start with one product record and see which identity, catalogue and evidence fields are already usable before you decide how the DPP should be exposed in the storefront.

Activate one product →

Primary and official sources

• Regulation (EU) 2024/1781, Ecodesign for Sustainable Products Regulation Relevant here: Articles 9(2)(e), 10(3), 11, 29, 30 and 35.

  View official source

• European Commission, Textile Apparel and the Digital Product Passport Supports the Commission's current statement that the future textile DPP will be accessible at online points of sale and through a product data carrier, subject to the final delegated act.

  View official source

• European Commission, Digital Product Passport for Economic Operators Supports the current Commission business guidance that online marketplaces need to make DPPs accessible for products placed on the EU market through distance selling.

  View official source

• Regulation (EU) 2023/988, General Product Safety Regulation Relevant here only for the separate online-offer information duties discussed in the boundary section. Last verified: 3 September 2026. This page is practical guidance, not personalised legal advice.

  View official source

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0988 Relevant here only for the separate online-offer information duties discussed in the boundary section.

Last verified: 3 September 2026. This page is practical guidance, not personalised legal advice.