Ontzi

2026 · Regulation

Product passport

ESPR is the framework; the first mandatory Digital Product Passport is 18 February 2027, for batteries. The work is structured product data that can be identified, hosted and updated.

—Days the ESPR framework has already applied
—Days until the first mandatory product passport
18 Jul 202418 Feb 2027

Regulation 2024/1781 is the framework. The first mandatory passport date is 18 February 2027, for batteries under Regulation 2023/1542.

Regulation (EU) 2024/1781 — the Ecodesign for Sustainable Products Regulation — is the Union framework for performance, information and a Digital Product Passport. It has applied as a framework since 18 July 2024. It does not set one passport date for every product. Concrete data fields, carriers and deadlines come per product group, through delegated acts. The first working plan prioritises textiles, furniture, tyres, mattresses, iron and steel, and aluminium.

The first mandatory passport already has a date. Under the Batteries Regulation (EU) 2023/1542, a battery passport applies from 18 February 2027 for the covered categories — electric-vehicle, industrial and light-means-of-transport batteries above the stated capacity. A central registry is an index, not a data store: it points to where the economic operator hosts the passport.

A record, not a label

A passport is structured data about a specific item or batch: identity, composition, substances, performance, dismantling, and whatever the delegated act requires — accessible via a data carrier, typically a QR code, and updatable across the life cycle. That information is spread across PLM, ERP, suppliers, tests and after-sales. A sustainability PDF, a catalogue page or a one-off project site will not survive a model change or a spare-part revision.

Later ESPR groups reuse the same problem: a unique identifier, a hosted dataset, a carrier on the product, registration in the index, and a way to update the record when the product changes. Building that only for batteries, as a brochure, leaves textiles and steel to start again.

Where it breaks

  • Master data: which products, batches and identifiers are in scope, and which delegated act or sectoral rule applies.
  • Collection: component and supplier data, tests and declarations mapped to a passport schema rather than a shared drive.
  • Lifecycle: who generates the passport, who hosts it, who updates it after a change, and how QR or API access still resolves.

What we build

Product master data, component and supplier collection, a hosted structured passport, and updates when the product changes — with a QR or API that still resolves.

Primary text

This field note is general information, not legal advice. Which product groups are in scope, and on which date, depends on the relevant regulation or delegated act and should be checked for each manufacturer.

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