Digital product passport requirements without the myths
10 min read
Digital product passport requirements: why the GPSR sets none, which EU laws do and from when, who registers the passport and what to prepare now.
You make products outside the EU, perhaps e-bike batteries, toys or textiles, and keep hearing that every product will soon need a digital product passport, often credited to the EU General Product Safety Regulation (GPSR). The passport is a set of product data that customers, businesses and authorities reach by scanning a code on the product. The GPSR does not require one; passports arrive product group by product group.
What a digital product passport is, in plain words
Under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR), a digital product passport is a set of data specific to a product, reached through a data carrier such as a QR code (Article 2(28) ESPR (opens in a new tab)). The data carrier sits on the product, its packaging or accompanying documents and links to a persistent unique product identifier (Article 10(1)).
The data stays with the operator that created the passport or a service provider, with a back-up copy at such a provider (Articles 10(4), 11(c)); the Commission's EU registry holds identifiers and registration data, not the full passport (Article 13).
Myth: the GPSR requires a digital product passport
It does not. The General Product Safety Regulation (EU) 2023/988 (opens in a new tab) contains no passport obligation; its Article 21 only allows the required information to be given additionally in digital form, such as a QR code, without replacing the labeling duties in Articles 9, 11 and 16.
A passport becomes mandatory only where a specific act says so, under the ESPR a delegated act (Article 9(1)). Ecodesign regulations under the old Directive 2009/125/EC, such as the motor efficiency regulation, continue to apply (Article 79 ESPR) and create no passport duty.
As of 5 October 2026, no ESPR delegated act with passport requirements had been adopted. The Commission's indicative timeline then planned them for iron and steel (late 2026), textiles, tyres and aluminium (2027), furniture (2028), mattresses and ICT products (2029), each with a transition of at least 18 months.
Digital product passport requirements by law and date
Dates apply to products placed on the market from that day; earlier toys and detergents may still be sold (Article 57(1) Toy Safety Regulation, Article 36 of Regulation (EU) 2026/405).
| Product group | Legal basis | Passport required from | One passport per |
|---|---|---|---|
| LMT batteries (e-bikes, e-scooters), electric vehicle batteries, industrial batteries over 2 kWh | Battery Regulation (EU) 2023/1542 (opens in a new tab), Article 77 | 18 February 2027 | Individual battery (Article 77(1), (2)) |
| Detergents and end-user surfactants | Regulation (EU) 2026/405 (opens in a new tab), Article 21 | 23 September 2029 (Article 37), transition to 23 September 2030 (Article 36); technical rules to follow (Article 21(10)) | Model (Article 21(2)(a)) |
| Toys | Toy Safety Regulation (EU) 2025/2509 (opens in a new tab), Article 19 | 1 August 2030 (Article 59) | Toy model (Article 19(2)(a)) |
| Construction products | Regulation (EU) 2024/3110 (opens in a new tab), Articles 22(7), 75, 76 | 18 months after the delegated act on the passport system enters into force; not adopted as of 5 October 2026 | Product type (Article 77(1)(a)) |
| ESPR product groups, iron and steel planned first | ESPR, Articles 4 and 9 | Set in each delegated act, as a rule at least 18 months after it enters into force (Article 4(4)) | Model, batch or item (Article 9(2)(d)) |
From 18 February 2027, every battery needs a QR code (Article 13(6) Battery Regulation), but only the three categories above need a passport (Battery Regulation 2027). For toys, the passport replaces the EU declaration of conformity (Recitals 54 and 58), which also shapes your representative's mandate.
Who provides the passport: operator, data carrier, registry
| Task | ESPR products | Batteries | Toys |
|---|---|---|---|
| Provide the passport and keep it accurate | Manufacturer (Article 27(1)(c)); importer checks it (Article 29(2)(c)) | Operator placing the battery on the market, or an operator it authorizes in writing (Article 77(4)) | Manufacturer (Articles 7(2), 19(1)) |
| Data carrier | Product, packaging or documents, as the delegated act sets (Article 10(1)(b)) | QR code (Articles 13(6), 77(3)) | Toy or affixed label, otherwise packaging or documents (Article 19(7)) |
| Upload to the EU registry | Operator placing the product on the market (Article 13(4)) | Operator placing the battery on the market (Article 77(10)) | Manufacturer (Article 7(2)(d)); importer checks it (Article 9(2)(e)) |
Your EU representative and the passport
Under the ESPR, the manufacturer's duties in Article 27(1), including the passport, cannot form part of an authorized representative's mandate (Article 28(1)). Under the Toy Safety Regulation, the representative may create the passport if the mandate says so, on the manufacturer's behalf and under the manufacturer's responsibility (Annex IV, Part I, point 5); the mandate must cover keeping it available for 10 years (Article 8(3)(a)).
The toy passport also names the manufacturer, any authorized representative and your EU economic operator under Article 4 of Regulation (EU) 2019/1020 (Annex VI, points (b) and (c)); ESPR delegated acts can do the same (Annex III, point (k)).
The EU registry: verification first, then customs checks
The registry went live on 20 July 2026 with a testing environment (Commission (opens in a new tab)); Implementing Regulation (EU) 2026/1778 (opens in a new tab) sets its rules. Only a verified economic operator can register passports (Article 4(3)). A company not required to be established in the EU proves its identity with a qualified electronic seal, a certified digital company stamp under the eIDAS Regulation (EU) No 910/2014, or an electronic attestation of attributes issued under Union law (Article 4(2)(b)).
Your verified status ends when your identification means expire, after three years at the latest; then you cannot register new passports or modify registry data until you verify again (Article 4(4)). Third parties registering for you must be verified too, and you remain fully responsible (Article 19(4)).
Whoever releases a product covered by an ESPR delegated act for free circulation at EU customs must give customs its unique registration identifier, which the registry issues on registration (Articles 13(5), 15(1) ESPR). The automatic check against the registry must run by 6 August 2030 (Article 15(2), (3)); toys get the same check (Article 23 Toy Safety Regulation).
What manufacturers outside the EU can prepare now
- Map your portfolio: check each product, and every battery inside it, against the table above.
- Settle who places the product on the market: your EU importer or, if you ship directly to EU customers, your own company; that operator registers (for toys, the manufacturer).
- Plan the verification: get a qualified electronic seal or an EU electronic attestation of attributes, and try the Commission's testing environment.
- Collect supplier data: agree who delivers which value; for batteries, Annex XIII lists the public data, from material composition to rated capacity.
- Choose identifiers and hosting: battery QR codes and identifiers follow ISO/IEC 15459 (Article 77(3) Battery Regulation); for ESPR passports, the harmonized standards EN 18216 and EN 18219 to EN 18223 give a presumption of conformity with Articles 10 and 11 as far as they cover them (Implementing Decision (EU) 2026/1736 (opens in a new tab)).
- Brief your EU partners: dealers and online marketplaces get a digital copy of the data carrier within five working days of a request (Article 10(3) ESPR, Article 19(12) Toy Safety Regulation).
Example: a U.S. maker of home batteries and garden tools
A U.S. company sells 10 kWh home storage batteries and cordless garden tools with 2 kg battery packs through a Dutch importer. The home battery weighs over 5 kg, so it is an industrial battery (Article 3(1), point (13)) and needs a passport for each unit placed on the market from 18 February 2027.
The importer places the batteries on the market and is responsible for the passport and the registry upload (Article 77(3), (4) and (10)); since the U.S. company holds the data, the importer authorizes it in writing to maintain the passport (Article 77(4)).
The 2 kg garden tool packs are portable batteries: they need a QR code from the same day, but no passport. The tools need none until an ESPR delegated act covers them.
Common mistakes with the digital product passport
- Treating any QR code as a passport. A passport needs a persistent unique identifier, interoperable data, a back-up and, where required, registration (Articles 10, 11 and 13 ESPR).
- Dropping paper information. Under the ESPR, safety information stays on paper (Article 27(7)), and the GPSR labeling duties remain.
- Building on a closed platform. Passport data must be transferable without vendor lock-in and stay available after insolvency or the end of your EU activity (Articles 10(1)(d), 11(e) ESPR).
Conclusion: prepare by product group, not by rumor
The digital product passport arrives law by law: batteries in February 2027, detergents in 2029, toys in 2030, ESPR product groups once their delegated acts apply.
Compliance belongs in product development from the start, because the same passport data must answer customers, retailers, authorities and customs. Product documents and labels are the groundwork of every passport and part of our Compliance pillar, within the agreed scope and mandate; the passport itself remains the duty of the manufacturer or the operator placing the product on the market. For the EU economic operator named in the passport, see EU Authorized Representative.
Frequently asked questions
Does the GPSR require a digital product passport?
No. Regulation (EU) 2023/988 contains no passport obligation; Article 21 only allows the required information to be provided additionally in digital form. Passports come from delegated acts under the Ecodesign Regulation (EU) 2024/1781 and from sector laws such as the Battery Regulation and the Toy Safety Regulation.
When does the digital product passport become mandatory?
It depends on the product group: from 18 February 2027 for LMT batteries, electric vehicle batteries and industrial batteries over 2 kWh (Article 77(1), Regulation (EU) 2023/1542), from 23 September 2029 for detergents and from 1 August 2030 for toys. ESPR product groups follow their delegated acts, as a rule at least 18 months after each enters into force.
Who registers the passport in the EU registry?
The economic operator placing the product on the market (Article 13(4) ESPR, Article 77(10) Battery Regulation); for toys, the manufacturer, checked by the importer (Articles 7(2)(d), 9(2)(e) Toy Safety Regulation). It must be verified first; a company outside the EU uses a qualified electronic seal or an electronic attestation of attributes (Article 4(2)(b), Regulation (EU) 2026/1778).
Can my EU Authorized Representative create the passport for me?
Under the ESPR, no: the manufacturer's duties in Article 27(1), including the passport, cannot form part of the representative's mandate (Article 28(1)). Under the Toy Safety Regulation, the representative may create the passport if the mandate says so, on the manufacturer's behalf and responsibility (Annex IV), and the mandate must cover keeping it available for 10 years (Article 8(3)(a)).
Is a QR code on my product a digital product passport?
Not by itself. A passport is a data set linked through a data carrier to a persistent unique product identifier, based on open interoperable formats, with a back-up copy and, where the applicable law requires it, registration in the EU registry (Articles 2(28), 10, 11 and 13 ESPR).
