Digital product passport under ESPR: beyond batteries

The digital product passport under ESPR is often discussed as if it were a battery topic. It is not. The battery passport is simply the first one with a fixed date. The Ecodesign for Sustainable Products Regulation turns the same idea into a general tool that will reach steel coils, aluminium profiles, clothing, tyres, furniture and, over time, many electrical products.

This article explains what Regulation (EU) 2024/1781 requires of a passport, which product groups are planned first, how the ESPR passport differs from the battery passport, and what manufacturers and their suppliers can prepare now. It reflects the state as of July 2026 and is not legal advice.

What the digital product passport is

The digital product passport (DPP) is a set of product data, defined per product group, reachable through a data carrier on the product and linked to a unique product identifier.

The legal basis is Regulation (EU) 2024/1781, adopted on 13 June 2024. It entered into force on 18 July 2024 and replaced the Ecodesign Directive 2009/125/EC, which had covered energy-related products only. ESPR applies to almost all physical goods, with exceptions such as food, feed, medicinal products and certain aspects of vehicles that are regulated elsewhere.

ESPR itself does not switch on any passport. It sets the framework. Each product group receives its own delegated act, which defines the ecodesign requirements and the passport content for that group.

What every ESPR passport must do

Articles 9 to 11 of ESPR set requirements that apply to all passports, whatever the product.

Market access. Once a delegated act requires it, a product may only be placed on the market or put into service if a passport is available. Its data must be accurate, complete and up to date.

Granularity. The delegated act decides whether the passport exists at model, batch or item level. This single choice drives most of the data effort: a model-level passport is a datasheet; an item-level passport is a record per serial number.

Identifier and carrier. The passport must be connected through a data carrier, such as a QR code, to a persistent unique product identifier. The carrier must be physically present on the product, its packaging or its documentation. Annex III refers to the ISO/IEC 15459 series for identifiers and data carriers.

Open and interoperable. Passport data must be based on open standards, in an interoperable format, machine-readable, structured, searchable and transferable without vendor lock-in.

Access rights. Different actors, from customers and repairers to recyclers, market surveillance and customs, get access to different data, as defined per product group.

Storage and durability. The passport is stored by the economic operator or by a passport service provider, must remain available for at least the expected lifetime of the product, including after insolvency of the operator, and must ensure data authentication, reliability and integrity.

Personal data. Customer personal data may not be stored in the passport without explicit consent.

Which products come first

The Commission adopted the first Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 on 16 April 2025. It calls the passport a key pillar of ESPR and states that every product for which ecodesign measures are adopted will have a passport, unless an equivalent system exists, such as the EPREL database for energy-labelled products.

The indicative timetable for adoption of measures:

Adoption is not the same as application. Each delegated act will include a transition period before its requirements apply. But the direction is clear, and for suppliers of steel and aluminium it is close.

The battery passport compared with the ESPR passport

The battery passport comes from a different law, the Batteries Regulation (EU) 2023/1542. Under Article 77, from 18 February 2027 each LMT battery, each industrial battery with a capacity above 2 kWh and each electric vehicle battery placed on the market or put into service must have an electronic record, the battery passport. ESPR links the two: the Commission's registry stores the unique identifiers for batteries as well.

Our EU battery passport guide explains the battery side in detail.

The registry and the standards

Article 13 of ESPR required the Commission to set up, by 19 July 2026, a registry that stores at least the unique identifiers and, for products entering the EU, the commodity code. Economic operators upload the data and receive a registration identifier in return.

The Commission launched the DPP registry together with a testing environment on 20 July 2026. According to a LexisNexis report on the launch, six of the eight harmonised standards being developed with CEN-CENELEC for the passport have been published. For IT teams, that means the plumbing is becoming concrete: identifiers, carriers, data exchange and access control are moving from discussion papers to specifications you can build against.

What manufacturers and suppliers can prepare now

1. Map your products to the working plan. Identify which of your products, or your customers' products, fall into the priority groups, and follow the preparatory studies for them.
2. Decide how you will identify items. If item- or batch-level passports are likely, you need persistent unique identifiers and a carrier that survives the product's life, and you need them in production, not in a spreadsheet afterwards.
3. Locate the data. Compliance documents, material composition, substances of concern and supplier information often sit in different systems. Find out who owns each data point.
4. Think about data quality. "Accurate, complete and up to date" is a legal requirement. Data that comes from measurements should be traceable to how and when it was measured.
5. Plan for integrity and security. Passport data must be authenticated and protected against manipulation. The same discipline applies to connected devices under the Cyber Resilience Act.
6. Choose a hosting model. Store passports yourself or use a passport service provider, and plan for availability over the product's whole lifetime.

Where process data fits

ESPR passports are mainly about product information: compliance, composition, use and end of life. Production process data is not a general ESPR requirement. Yet for some products, inline quality data is exactly the evidence behind statements about durability or performance.

Battery modules show where this goes. A weld that joins cells in a module is a quality-critical feature, and a record of how every weld was graded is the kind of item-level evidence a passport can point to. We discuss this in where weld quality data fits in the battery passport.

How NeuroControls approaches this

We work on the passport question from the production side. In the BMFTR-funded research project DIGIBATT360 (February 2026 to January 2029), coordinated by VARTA Storage with Fraunhofer IIS, Circulor, VRI and NeuroControls, the partners are extending the digital battery passport with a federated data space and AI-based analytics. Our published role is cognitive sensing and returned-goods analysis; within it, we are developing an inline edge node designed to grade every weld of a battery module, with the verdict designed to go into the module's battery passport. The project is listed on our research projects page and our battery industry page.

Our recording software keeps a versioned manifest, per-segment SHA-256 hashes and an append-only journal, and exports to open formats such as JSONL and CSV: the kind of provenance a passport will need from its data sources. Our data solutions page shows how measurement data becomes a traceable record. Our work on inline weld inspection in the e-LAS+ project is described in our look back at the e-LAS+ project.