The EU Digital Product Passport, Explained From the Regulation Itself
Products sold in the EU will progressively need a digital passport, reached by scanning a QR code on the product. Here is what the law actually says, which deadlines are real, and how to set up the QR side so you are not locked into anyone — including us.
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What the regulation actually requires
The Ecodesign for Sustainable Products Regulation — Regulation (EU) 2024/1781, in force since 18 July 2024 — creates the Digital Product Passport. Article 9(1) is blunt about what it means once a product category is covered:
"products can only be placed on the market or put into service if a digital product passport is available"
The passport is a digital record — materials, repairability, recycled content, compliance documentation — attached to the physical item. And the way a person or system reaches it is by scanning a data carrier on the product. The regulation names its expected form: information "should be easily accessible by scanning a data carrier, such as a watermark or a quick response (QR) code".
ESPR itself is a framework. No product needs a passport until the European Commission adopts a delegated act for its category — which is why the honest answer to "when is my deadline?" depends entirely on what you sell.
Deadline tracker, category by category
Most articles about the DPP assert dates the law has not set. This table separates what is statute from what is still pending. Last verified against the Official Journal and Commission working plan: 7 August 2026.
| Category | Legal basis | Status |
|---|---|---|
| EV, industrial (>2 kWh) and LMT batteries | Regulation (EU) 2023/1542, Art. 13(6) & 77 | STATUTORY — 18 FEB 2027 |
| Textiles, garments and footwear | ESPR delegated act (priority in the 2025–2030 working plan) | DELEGATED ACT PENDING |
| Iron, steel and aluminium | ESPR delegated act (named in recital 49) | DELEGATED ACT PENDING |
| Furniture, tyres, detergents, paints, lubricants, chemicals, ICT products | ESPR delegated acts (named in recital 49) | DELEGATED ACT PENDING |
| Wine (nutrition e-label — related, but not a DPP) | Regulation (EU) 2021/2117, Art. 119 | IN FORCE — 8 DEC 2023 |
A date you may see quoted for textiles — 2027, or 2028 — is a prediction, not law. The first ESPR working plan was adopted on 16 April 2025 and prioritises the categories above, but until a delegated act is published in the Official Journal, no textile DPP deadline exists. We check this page against the primary sources and update the verification date above when anything changes.
Batteries are the template — and the QR mandate is explicit
The battery regulation is the first passport with a statutory date, and it shows how the others will likely work. Article 13(6):
"From 18 February 2027, all batteries shall be marked with a QR code as described in Part C of Annex VI."
For EV batteries, industrial batteries above 2 kWh and light-means-of-transport batteries, that QR resolves to the battery passport. The technical specification of the code itself, in full: it "shall be in high contrast to the background colour and of a size that is easily readable by a commonly available QR reader". That is the entire requirement — the regulation deliberately makes the code itself trivial. Everything that matters happens behind it: the identifiers (which must follow ISO/IEC 15459), the data, and the resolution.
The code must be printed or engraved "visibly, legibly and indelibly" on the battery — which means it will outlive every marketing campaign, every website redesign, and possibly every vendor relationship the manufacturer has. That permanence is why the next section is the one that should drive your vendor choice.
The rule nobody quotes: no vendor lock-in — by law
Article 77(5) of the battery regulation requires that passport data be:
"based on open standards and be in an interoperable format, transferable through an open interoperable data exchange network without vendor lock-in, machine-readable, structured and searchable"
ESPR uses the same "without vendor lock-in" wording for the DPP. The EU is not just mandating the passport — it is mandating that you be able to leave your passport provider. When evaluating any vendor, including us, the checklist that phrase implies is:
- The printed QR should resolve on a domain you control. If the vendor's domain is on your packaging, you cannot leave them without a reprint. QRCodeStack supports custom domains so the URL on your product is yours.
- The URL should follow an open standard, not a proprietary scheme. A GS1 Digital Link URL carries your GTIN in a standardised path any conformant system can parse — no vendor needed to interpret it.
- Your data must be exportable. Identifiers, destinations and scan history, in machine-readable form, on request.
This is worth internalising even outside the EU: packaging outlives vendors, and the regulation is simply forcing the industry to design for that fact.
One code for checkout, consumers and regulators
The DPP is arriving at the same time as GS1 Sunrise 2027 — retail's transition to 2D barcodes at the point of sale. That convergence is not a coincidence, and it points at the practical answer for packaging design: one QR code whose URL is a GS1 Digital Link.
A Digital Link URL — https://yourbrand.com/01/09520123456788 — carries the GTIN in the path. The checkout reads the product identifier. A shopper's phone opens the product page. A regulator or recycler resolves the same code to the passport data. Batch (/10/) and serial (/21/) numbers extend the path for item-level passports, which is exactly what the battery regulation's unique-identifier requirement needs.
QRCodeStack generates GS1 Digital Link QR codes against the ratified GS1 URI Syntax standard (release 1.7.0, August 2026), resolves them on your own domain, and keeps the destination editable after printing — the scan can point at a product page today and a passport record when your delegated act lands, without touching the artwork.
How to prepare, by situation
- You make or import batteries: your date is 18 February 2027 and it is statutory. The QR, the passport record and ISO/IEC 15459 identifiers all need to be in place before products ship.
- You sell textiles, furniture, steel or the other priority categories: no binding date exists yet — but packaging and labelling designed now should assume a QR will be required. Designing in a Digital Link code today costs nothing; retrofitting one after a delegated act lands costs a packaging cycle.
- You redesign packaging between now and 2027: put the 2D code on this cycle. Sunrise 2027 gives it a retail function immediately; the DPP gives it a regulatory function later. Same printed symbol.
- Whatever you sell: apply the lock-in checklist above to any vendor. The regulation's authors assumed providers will come and go; your packaging should too.
Frequently Asked Questions
What is the EU Digital Product Passport?
A digital record for a physical product, mandated by the EU Ecodesign for Sustainable Products Regulation (2024/1781). Once a delegated act covers a product category, products in that category can only be placed on the EU market if a digital product passport is available, accessed by scanning a data carrier such as a QR code on the product or its packaging.
When does the Digital Product Passport become mandatory?
Category by category. The only hard statutory date so far is batteries: from 18 February 2027, LMT batteries, industrial batteries above 2 kWh and EV batteries must carry a QR code linking to a battery passport under Regulation 2023/1542. For textiles, steel, furniture, tyres and the other priority categories, the obligation only starts when each category's delegated act is adopted — none of those dates are fixed yet.
Is a QR code required for the Digital Product Passport?
The regulation requires a data carrier on the product, and names the QR code as the expected example. The battery regulation goes further and mandates a QR code outright, specifying only that it be high-contrast and readable by a commonly available QR reader.
What does the no-vendor-lock-in requirement mean?
Both ESPR and the battery regulation require passport data to be based on open standards, interoperable, and transferable without vendor lock-in. In practice: your QR should resolve on a domain you control, follow open identifier standards such as GS1 Digital Link, and your data must be exportable — so you can change providers without reprinting packaging.
Is the EU wine e-label the same as a Digital Product Passport?
No. Wine e-labels come from a different regulation (2021/2117, applying from December 2023) with its own rules — notably that the electronic label must carry no marketing and collect no user data. The DPP sits under ESPR and has different content requirements. Both use a QR code as the carrier.
Can one QR code serve the Digital Product Passport and retail checkout?
That is the direction the industry is converging on. A GS1 Digital Link QR carries the product's GTIN in the URL path, so retail point-of-sale systems can read the identifier while a phone scan resolves to the passport or product page — one printed symbol serving checkout, consumers and regulators.
Putting a passport-ready QR on your product?
GS1 Digital Link codes on your own domain, editable destinations after printing, and standards-conformant resolution — so the code you print this year still works whatever the delegated acts decide.
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