By Operator One Editorial — 17 April 2026
Two pieces of EU legislation together define what is coming: the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781, in force since 18 July 2024) and the Battery Regulation (Regulation (EU) 2023/1542, in force since 17 August 2023). Together they establish the Digital Product Passport (DPP) and the first product category to which it applies.
The DPP is not a marketing concept. It is a structured, machine-readable record per product, accessible via a data carrier (typically a QR code or similar) printed on or attached to the product, containing identity, materials, recyclability, and supply-chain data. The data must be accessible to consumers, regulators, customs, and waste-treatment operators.
The first wave: batteries
Under Article 77 of the Battery Regulation, the battery DPP applies from 18 February 2027 to:
- LMT batteries (light means of transport — e-bikes, e-scooters, etc.)
- Industrial batteries with a capacity above 2 kWh
- Electric vehicle batteries
Each individual battery placed on the EU market from that date must carry a unique identifier linking to its DPP, hosted on an interoperable system. The information required ranges from manufacturer details and chemical composition to carbon footprint, recycled content percentages, and end-of-life handling instructions.
Why this matters before 2027
The marketplace side is what brings the timeline forward.
Marketplaces selling LMT batteries, e-bikes, or larger battery products will be required to verify that products listed carry a valid DPP from the moment the obligation enters into force. Amazon, Bol, Kaufland, and the major electronics-heavy marketplaces have all signalled that DPP fields will be added to product feed schemas during 2026 in preparation, mirroring the EPR-registration verification pattern we already saw for Spain and Germany.
That means brands selling LMT batteries or batteries above 2 kWh need to:
- Confirm with their battery cell supplier that the supplier is preparing DPP data (cell origin, chemistry, carbon footprint per Annex II of the Battery Regulation)
- Decide who will operate the DPP infrastructure — the brand itself, the importer, or a third-party DPP operator
- Assign a unique product identifier scheme — GS1 codes are the most common reference standard
- Plan the physical data-carrier integration with packaging and label workflows
What comes after batteries
The ESPR working plan for 2025–2030 has identified the following priority categories for the next DPP waves: textiles, furniture, tyres, detergents, paints, lubricants, iron, steel, and aluminium. The Commission is expected to adopt delegated acts for the first ESPR product groups during 2026 and 2027, with practical obligations starting from 2028 onward.
The pattern with EPR is the pattern that is likely to repeat with DPP: a regulation in force, a phased application, then marketplace verification at upload. Brands that wait for the marketplace block before preparing will have their listings removed.
The Operator One position
For brands where Operator One is Merchant of Record on EU marketplaces, the DPP obligation lands jointly: the brand owns the product data (composition, carbon footprint, supplier chain), we operate the marketplace listing and ensure the DPP identifier is wired into the listing feed where the marketplace requires it. Brands selling batteries on EU marketplaces today should start the conversation with their MoR or compliance partner now — not in late 2026.
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