EU Digital Product Passport (DPP): where things stand in 2026 — a guide for distributors

Regulation (EU) 2024/1781 on ecodesign for sustainable products (ESPR) creates the digital product passport. It entered into force on 18 July 2024, but it does not yet make any passport mandatory: the obligation will be triggered by delegated acts, adopted product group by product group. 2026 is the year of the plumbing — the European registry, the first delegated acts expected. For a distributor, it is the right moment to look at what the text actually requires, and which data will have to be held.

What the regulation provides, article by article

Chapter III of the ESPR is devoted entirely to the passport. Article 9 sets the rule: where a delegated act requires it, a product may be placed on the market only if a digital passport is available, and the data it contains must be “accurate, complete and up to date”. The same article states what each delegated act will have to define: the data to be included, the data carrier or carriers, the level — model, batch or item — at which the passport is established, who has access, who creates and updates it, and how long it must remain available, at least for the expected lifetime of the product.

The following articles complete the arrangement:

• Article 11 — essential design requirements: interoperability between passports, free access for customers, repairers, recyclers and authorities according to their respective rights, and continued availability of the passport even after the operator that created it ceases trading.
• Article 12 — unique identifiers: product, operator, facility.
• Article 13 — the European registry, which the Commission is to set up “by 19 July 2026”. It will hold at least the unique identifiers, and also the unique battery identifiers referred to in Article 77(3) of the Batteries Regulation.
• Article 14 — a public web portal allowing passport data to be searched and compared.
• Article 15 — customs checks on the passport at import.

The data the passport will carry

Annex III lists what delegated acts may require. For a distributor it is the best reading grid available today, because it says where each piece of data will have to be sourced:

• The unique product identifier and the GTIN (ISO/IEC 15459-6 or an equivalent standard), plus the relevant commodity codes such as the TARIC code.
• The compliance documentation required by the ESPR or by any other text applicable to the product: declaration of conformity, technical documentation, certificates.
• The manuals, instructions, warnings and safety information required by Union law.
• Information on the manufacturer, the importer (including its EORI number) and the operator established in the Union responsible for the tasks of Article 4 of Regulation (EU) 2019/1020 or Article 15 of Regulation (EU) 2023/988.
• The information required by Article 7: product performance on the parameters of Annex I — repairability score, durability score, carbon or environmental footprint — installation, maintenance and repair instructions, and dismantling information for treatment facilities.

On substances of concern, Article 7 sets a safeguard: those referred to in Article 2(27)(a) cannot be exempted from the information requirement where they are present above 0.1% weight by weight in the product, its relevant components or its spare parts. That is the same threshold as Article 33 of REACH: the data you collect today for REACH will be reused.

The timetable: what is dated and what is not

Only one deadline is currently fixed in a regulation for a product: the battery passport. Article 77 of Regulation (EU) 2023/1542 requires that, from 18 February 2027, every light means of transport battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the market be associated with an electronic record.

For everything else, all we have is the 2025-2030 working plan adopted by the Commission on 16 April 2025, which gives indicative years for the adoption of delegated acts. Those dates are the dates of the act, not of the obligation: Article 4(4) of the ESPR prohibits setting the date of application of a delegated act less than 18 months after its entry into force, save in duly justified cases.

A mid-term review of the working plan is planned for 2028. In other words: the scope and the dates will move again, and nobody can honestly announce today a date of obligation for consumer electronics or furniture. What will not move is the nature of the work to be done.

What the regulation already asks of a distributor

Article 30 sets out distributors' obligations: before placing a product covered by a delegated act on the market, check that it bears the CE marking and, where applicable, that it is labelled or linked to a digital product passport; check that it comes with the required documents and digital instructions, in a language easily understood by customers in the Member State concerned; and refrain from making it available until it is compliant.

One provision deserves the attention of every online store: Article 10(3). The operator placing the product on the market must give dealers and online marketplaces a digital copy of the data carrier or of the unique product identifier, so that customers who cannot see the product physically can still access it — free of charge, and within five working days of a request. In practice, the passport QR code becomes a media asset to store and distribute on every product page, just like an image.

The real project: getting supplier data to flow up

A distributor does not manufacture: composition, carbon footprint and spare-part availability are not in its systems. The project is therefore a collection project, and it runs in five steps.

1. Identify the families in your catalogue that appear in the working plan, starting with those whose delegated act is expected soonest.
2. Map what already exists: what you hold for REACH, RoHS, CE marking, the AGEC law or the EPREL register already covers part of Annex III.
3. Request the gap from your suppliers in structured form rather than as PDFs: one attribute per data point, with its unit and validity date.
4. Version it: the passport must stay accurate and up to date, so a value that changes must leave a trace of the previous value and its date.
5. Check completeness before publication, with a score per family calculated on the required attributes.

That is exactly the structure of the Compliance module in Pixee PIM: compliance attributes attached to the family, a supplier collection workflow, and a document export.

Frequently asked questions

Is the digital product passport mandatory in 2026?

No, not as such. The ESPR is in force, but the obligation arises from delegated acts, product group by product group, and none has yet made a passport required. The first deadline dated in a text is the battery passport, on 18 February 2027, under the Batteries Regulation. What belongs to 2026 is the Commission setting up the European registry, due by 19 July.

Is a passport needed per item sold, or per model?

It depends on the product: Article 9 provides that each delegated act specifies whether the passport is established at model, batch or item level. The Batteries Regulation already decides the point by associating a record with each battery concerned. For a catalogue the consequence is concrete: a data model that cleanly separates the product from its variants will support all three cases; a model that conflates them will support none.

Who has to create the passport when importing from outside the EU?

Each delegated act will designate the actors responsible for creating the passport and updating its data. What is already certain is that Annex III provides for the passport to include the contact details of the operator established in the Union responsible under Article 4 of Regulation (EU) 2019/1020 — a role that falls to the importer when the manufacturer is not established in the Union. On the legal detail of how the roles are allocated, it is wiser to wait for the delegated act covering your category than to build an organisation on an interpretation.

Can you prepare without knowing the exact data that will be required?

Yes, and it is the only reasonable strategy. The precise lists will vary by category, but the mechanism will not: data obtained from the supplier, stored as an attribute per product reference, dated, versioned, checked before publication and distributed to every channel. A company that can answer “which product lines in family X have no up-to-date declaration of conformity?” in minutes will be ready; a company that has to open a spreadsheet will not.