Battery Passport vs Textile DPP vs General DPP

Three regimes, one shared architecture

The EU isn't running one Digital Product Passport programme — it's running three, each governed by its own regulation:

• Battery Passport — EU Battery Regulation (2023/1542)
• Textile DPP — first delegated act under ESPR (2024/1781)
• General ESPR DPP — the rolling framework covering electronics, furniture, tyres, metals and more

All three share the same underlying architecture — GS1 Digital Link carriers, resolver-based access, role-based views, EU Product Passport Registry — but the data sets, deadlines and enforcement models differ in meaningful ways.

Deadlines compared

• Battery Passport — mandatory from 18 February 2027. Hard date, no category-by-category staging. This is the first DPP regime to actually switch on.
• Textile DPP — expected from 2027 under the first ESPR delegated act, with a phased approach by company size and product type.
• General ESPR DPP — rolling deadlines from 2027 through 2030 as each category's delegated act is adopted.

Scope compared

• Battery Passport — EV batteries, Light Means of Transport (LMT) batteries and industrial batteries above 2 kWh. Per-unit, not per-SKU.
• Textile DPP — finished apparel, footwear, accessories and home textiles placed on the EU market. Per-unit identifiers expected from day one.
• General ESPR DPP — almost every other physical product, prioritised by category. Per-SKU or per-unit depending on the category.

Data sets compared

The required attributes overlap heavily but each regime has its own headline data points.

• Battery Passport — battery chemistry, carbon footprint over the lifecycle, recycled content (cobalt, lead, lithium, nickel), state of health, supply-chain due diligence under the Battery Regulation's Annex VII.
• Textile DPP — fibre composition, country and facility of each production stage, substances of concern, care and repair instructions, end-of-life routing.
• General ESPR DPP — durability, reparability, recyclability, recycled content, environmental footprint and category-specific performance metrics.

Access models compared

All three use role-based views, but the audience priorities differ.

• Battery Passport — heavy emphasis on second-life operators, recyclers and customs authorities. Consumer view is comparatively narrow.
• Textile DPP — consumer view is central, with strong repair, resale and recycling slices. Authority view covers substances of concern and origin.
• General ESPR DPP — varies by category, but typically balances consumer, repairer, recycler and authority views.

Where they overlap

• Identifier standard — ISO/IEC 15459, in practice GS1 Digital Link
• Data carrier — QR code on or with the product
• EU Product Passport Registry — all three feed the same registry
• Retention — for the product's expected lifetime plus a regulation-specific period
• Interoperability — CIRPASS-aligned data models, W3C Verifiable Credentials, JSON-LD

What this means for platform choice

If your business spans more than one of these regimes — say, an electronics brand that also ships rechargeable batteries — you don't want three separate DPP stacks. Pick a platform that supports the shared architecture once and layers regime-specific data sets on top. That's the design philosophy behind SmartLinks — one resolver, one identifier strategy, three regime-aware data sets.

Further reading

• Battery Passport 2027 readiness
• Fashion & Apparel DPP 2027
• ESPR regulation guide
• DPP timeline by industry