By Operator One Editorial — 2026-06-14
The Digital Product Passport (DPP) is no longer a discussion document. With the Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781, "ESPR") in force since July 2024, the European Commission has the legal instrument it needs to demand a structured, machine-readable, lifecycle-aware data record for almost every physical product placed on the EU market. The first mandatory rollout — the Battery Passport under Regulation (EU) 2023/1542 — lands on 18 February 2027. The ESPR Working Plan 2025-2030 lines up textiles, furniture, iron and steel, aluminium, tyres, detergents, paints, lubricants and consumer electronics behind it. Brands that wait for delegated acts to be published before they start preparing will be moving data infrastructure under deadline pressure, on a marketplace where listings can be silently suppressed for missing fields.
What ESPR actually requires
ESPR replaces the old Ecodesign Directive (2009/125/EC) and extends its scope from energy-related products to essentially every physical good sold in the EU, with narrow exceptions for food, feed, medicinal products and living organisms. The regulation itself is a framework: the binding product rules come through delegated acts adopted product group by product group. Each delegated act will specify, among other things, the ecodesign performance requirements (durability, reparability, recycled content, carbon footprint) and the information requirements that populate the DPP.
The DPP itself is a structured data record tied to a unique product identifier, accessible through a data carrier — most commonly a QR code or other type of machine-readable link — printed on the product, its packaging, or accompanying documentation. Different stakeholders see different layers of the data: consumers see usage, repair and end-of-life information; economic operators see batch and component data; market surveillance authorities see the full record, including evidence supporting compliance claims.
The ESPR Working Plan 2025-2030 priority groups
The Commission's first ESPR Working Plan, adopted in April 2025, sets the order in which delegated acts will arrive. The priority product groups are:
- Textiles, especially apparel and footwear — driven by the EU Strategy for Sustainable and Circular Textiles. Expected to carry data on fibre composition, country of last substantial transformation, recycled content, microplastic shedding, durability and repairability.
- Furniture, including mattresses — recycled content, repairability score, presence of substances of concern, end-of-life dismantling guidance.
- Tyres — rolling resistance, wet grip, retreadability, recycled rubber content.
- Iron, steel and aluminium — embodied carbon, recycled content, traceability of primary inputs.
- Consumer electronics and small household appliances — repairability index, spare parts availability windows, software support duration, recycled content of critical raw materials.
- Energy-related products already covered by the old Ecodesign Directive (boilers, fans, motors, lighting, displays) are migrating into ESPR and will get DPP requirements as their measures are revised.
- Chemicals in scope: detergents, paints, lubricants and cosmetics.
Delegated acts for the first wave (textiles, furniture, tyres, iron and steel) are expected to be adopted between late 2026 and 2028, with transition periods of typically 18 to 36 months before they apply. The Commission has also flagged a horizontal delegated act on a common DPP technical architecture, which will set the rules every product-specific passport has to inherit.
The Battery Passport: the first real test
The Battery Regulation (EU) 2023/1542 is the first piece of EU law that operationalises a mandatory DPP. From 18 February 2027, every industrial battery above 2 kWh, every electric-vehicle battery, and every LMT (light means of transport, e.g. e-bike, e-scooter) battery placed on the EU market must carry a Battery Passport, accessible via a QR code on the battery itself.
The required data set is more demanding than many brands realise. It includes:
- Battery model, manufacturer, place and date of manufacture, and a unique serial-level identifier;
- Chemistry, composition (including hazardous substances and critical raw materials such as cobalt, lithium, natural graphite and nickel), and recycled-content percentages from 2031 onward;
- Carbon footprint per functional unit (kWh of total energy delivered over service life), with values backed by a Commission-prescribed methodology and verified by a notified body;
- Performance and durability parameters — rated capacity, internal resistance, expected lifetime, state-of-health indicators;
- Due-diligence information on the supply chain for cobalt, lithium, natural graphite and nickel, aligned with OECD guidance;
- End-of-life handling: dismantling instructions, safety information for second-life and recycling operators.
The economic operator placing the battery on the market — typically the manufacturer or the importer — is responsible for the passport. For products sold through marketplaces, this responsibility flows through to whoever is the EU compliance contact for the listing. Brands selling EV-grade or LMT batteries through any EU channel from 2027 onward should treat the data assembly as a current-year project, not a 2027 one.
How marketplaces will verify
Marketplaces are not passive observers in the DPP regime. The Digital Services Act (Regulation (EU) 2022/2065) already requires online platforms to perform "know-your-business-customer" checks and to allow only traceable sellers on EU marketplaces. The General Product Safety Regulation (Regulation (EU) 2023/988), in force since December 2024, extended that to require an EU-based responsible economic operator for every product sold to EU consumers.
ESPR adds the next layer. Article 14 of ESPR explicitly addresses online marketplaces and search engines, requiring them to design their interfaces so that economic operators can display ecodesign and DPP information, and to cooperate with market-surveillance authorities. In practical terms, that means:
- Listing-level fields — marketplaces will collect the unique product identifier and DPP URL as structured attributes, and listings missing them for in-scope product groups will be blocked or suppressed.
- Spot-check enforcement — DG GROW and national market-surveillance authorities will sample listings, scan the data carrier, and verify the underlying claims. Mismatches between marketplace content and the DPP record (different country of origin, different recycled-content claim) will be treated as misleading commercial practice under the Unfair Commercial Practices Directive.
- Removal duties — once an authority issues a non-compliance notice, marketplaces must remove the listing within working days, similar to the takedown regime already used for CE-marking failures.
Amazon, bol, Kaufland, Cdiscount, Allegro, Zalando and the other major EU venues are already piloting structured ecodesign attribute fields. Brands that have clean product master data — a stable GTIN, a controlled attribute schema, and a single source of truth for sourcing and material claims — will plug into those fields in hours. Brands that rely on free-text descriptions will spend months reconciling.
What brands should be building now
The right preparation is not a DPP project; it is a product-data foundation that the DPP can sit on top of. The components that are stable across all expected delegated acts:
- A unique product identifier at the right granularity — for batteries this is serial-level; for textiles likely batch or SKU; for furniture model-level. GTIN/EAN remains the anchor, but brands should be able to append serial or batch numbers without breaking their PIM.
- A data carrier strategy — QR code on product, packaging or hangtag, with a persistent URL that resolves even if the brand changes platform. ISO/IEC 18004 (QR) and ISO/IEC 15459 (unique identifiers) are the relevant standards.
- Verifiable sourcing evidence — supplier declarations, chain-of-custody certificates (GRS, RCS, FSC, ASI, RJC, IRMA), and where required, third-party audit reports kept in a retrievable archive.
- A product carbon footprint methodology — aligned with the EU Product Environmental Footprint (PEF) where a Category Rule exists, otherwise ISO 14067. For batteries specifically, the Commission has prescribed the calculation rules.
- Repairability and recyclability data — disassembly time, spare-parts availability commitments, software-support windows for electronics, recycled-content percentages backed by mass-balance evidence.
- A clean attribute model in the PIM — channel-locale aware, with each ESPR field stored once and pushed to every marketplace. Free-text "sustainability" copy will fail verification.
- An EU-based economic operator — already required under GPSR and Regulation (EU) 2019/1020, and the natural holder of the DPP for non-EU brands.
The brands that will struggle in 2027 are not the ones whose batteries are non-compliant; the regulation has been signposted for years. They are the ones whose carbon-footprint number lives in a consultancy PDF, whose recycled-content claim sits in a marketing deck, and whose supplier declarations are in an inbox. Pulling those into a structured, query-able, audit-ready record is the work of the next eighteen months.
Where Operator One fits
Operator One operates as merchant of record across 27 EU markets and the UK, with a PIM and compliance layer designed to carry the channel-locale-specific attributes that ESPR and the Battery Regulation will require, and to route them to every marketplace we list on. Brands working with us — from a mid-market apparel label to consumer-goods groups like Dabur — get the regulatory plumbing handled inside the same flow that already moves their orders, VAT and EPR data; the DPP becomes another structured field on the product, not a separate project. For a deeper look at the model, see /merchant-of-record, /compliance-glossary and /marketplaces.