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Digital Product Passport: what sellers need to know

Published October 13, 2026

The Digital Product Passport (DPP) is a product record behind a QR code or similar data carrier, required by the EU Ecodesign Regulation (EU) 2024/1781 and by sector laws. As of October 2026 it is mandatory for no consumer product yet: the first passports are required for certain batteries from 18 February 2027, toys follow from 1 August 2030, and textiles, furniture and other groups only once the Commission has adopted product rules for them. What sellers can prepare now is the data.

What the Digital Product Passport is

The Ecodesign for Sustainable Products Regulation (ESPR) has applied since 18 July 2024. It lets the Commission set product rules by delegated acts, one product group at a time. Where such an act requires a passport, the product may only be placed on the market if a passport is available (Article 9).

The passport itself is a digital record, not a document you upload to Amazon. It is linked through a data carrier — usually a QR code on the product, its packaging or the accompanying documents — to a persistent unique product identifier (Article 10). Annex III lists what the product rules can require in it, for example:

  • the unique product identifier and the GTIN (EAN) of the product or its parts,
  • commodity codes such as the TARIC code,
  • declarations of conformity, technical documentation or certificates,
  • user manuals, instructions, warnings and safety information,
  • manufacturer, importer and EU responsible operator, with their identifiers,
  • product information set by the delegated act: materials, recycled content, repairability, substances of concern.

The Commission opened the central DPP registry on 20 July 2026 (Article 13 had set a deadline of 19 July 2026). It stores the unique identifiers and some metadata, not the product data itself, which stays with the company or its DPP service provider.

What applies when

DateWhat
18 July 2024ESPR in force; no product obligations by itself
16 April 2025First ESPR working plan 2025–2030 adopted
19 July 2026Ban on destroying unsold apparel and footwear applies to large enterprises
20 July 2026DPP registry live, with a test environment and helpdesk
18 February 2027Battery passport for LMT batteries (e-bikes, e-scooters), industrial batteries over 2 kWh and EV batteries; QR code on all batteries
19 July 2030Destruction ban and disclosure duty also apply to medium-sized enterprises
1 August 2030New Toy Safety Regulation applies, with a passport for every toy

For the ESPR product groups there is no date yet. A delegated act may not apply earlier than 18 months after it enters into force, except in justified cases (Article 4(4)). So even an act adopted in 2027 would normally apply in 2028 at the earliest.

Which product groups come first

The working plan adopted on 16 April 2025 (COM(2025) 187) prioritises these groups, with indicative years for adopting the rules:

Product groupIndicative adoption
Iron and steel2026
Textiles, in particular apparel2027
Tyres2027
Aluminium2027
Furniture2028
Mattresses2029
Repairability (horizontal, e.g. consumer electronics)2027
Recyclability and recycled content of electrical equipment2029

Footwear is not on the list: a study on it is to be finished by the end of 2027. Detergents, paints, lubricants and chemicals, named in Article 18 as candidates, were left out of this first plan. For marketplace sellers, apparel is the group to watch. Each delegated act will say what goes in the passport, who creates it and how shoppers reach it in distance selling (Article 9(2)(e)) — none of this is fixed for consumer goods yet.

Batteries and toys: the dates that are fixed

Batteries come first, under their own law. From 18 February 2027, each LMT battery, each industrial battery over 2 kWh and each electric vehicle battery placed on the market needs a battery passport (Article 77 of Regulation (EU) 2023/1542). From the same date, all batteries must carry a QR code (Article 13(6)). If you sell e-bike batteries or e-scooters as importer or own brand, ask your supplier now who creates the passport.

Toys follow with the new Toy Safety Regulation (EU) 2025/2509, which applies from 1 August 2030. Before placing a toy on the market, the manufacturer must create a passport for the toy model (Article 19), and the importer or manufacturer must register its identifiers in the EU registry (Article 22). The data carrier must be visible to shoppers before purchase, also online, and marketplaces must let sellers show the data carrier or a link to the passport (Article 14(3)). Toys placed on the market under the old directive before 1 August 2030 can still be sold afterwards (Article 57).

The ban on destroying unsold clothes and shoes

Also under the ESPR: since 19 July 2026, large enterprises may no longer destroy unsold apparel, clothing accessories and footwear (Article 25 and Annex VII). Medium-sized enterprises follow from 19 July 2030; micro and small enterprises are exempt. Unsold includes surplus stock and, where applicable, customer returns.

Exceptions are set by a delegated act, for example for unsafe, damaged or counterfeit goods and products that could not be donated. Large enterprises must also publish each year how many unsold products they discarded and why (Article 24).

A small seller is not banned from destroying stock, but must not destroy products that a large company handed over to get around the ban (Article 25(2)). If you buy return pallets or remaining stock, keep that in mind.

What to prepare now

Most of what a passport will contain is data you already need for the GPSR information in your listing. Collect it per product, in a structured form:

  • GTIN/EAN and the manufacturer’s model or type number,
  • manufacturer name, postal and electronic address; for non-EU manufacturers the EU responsible person,
  • materials with percentages — for textiles the legal fibre names,
  • commodity code (customs tariff number) and country of origin,
  • declaration of conformity, safety information and instructions in each language you sell in,
  • for batteries: type, capacity and who creates the battery passport.

Ask suppliers in writing now whether they will provide the passport, or the data for it, once the rules for their product group apply. If you sell under your own brand or import from outside the EU, you are likely the one who has to create it: under the ESPR, an importer or distributor who sells a product under its own name or trade mark counts as the manufacturer (Article 34).

Be careful with promises: a listing that says “with Digital Product Passport” or “DPP-ready” for a product group without rules makes a claim no one can check. Better leave it out.

Check your listing today

Passports are not due yet for most products — but the wording rules in your listing apply now. The free listing check finds fibre names that are not allowed (such as “bamboo”), missing toy warnings, banned environmental claims and “CE-geprüft” in your existing listing, in six languages and without an account.

Sources

  1. Regulation (EU) 2024/1781 (ESPR), Articles 4, 9–13, 18, 24, 25, 34 and Annexes III and VII
  2. Commission: Ecodesign and Energy Labelling Working Plan 2025–2030, COM(2025) 187
  3. Commission Daily News, 22 July 2026: Digital Product Passport Registry goes live
  4. Regulation (EU) 2023/1542 on batteries, Articles 13 and 77
  5. Regulation (EU) 2025/2509 on the safety of toys, Articles 14, 19, 22, 57 and 59
  6. Commission: Ban on destruction of unsold clothes and shoes enters into application

Information for sellers, not legal advice.

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