ESPR Regulation Guide: Digital Product Passport Requirements

What is the ESPR regulation?

The Ecodesign for Sustainable Products Regulation (ESPR) is the EU's flagship sustainable-products law. It entered into force on 18 July 2024 as Regulation (EU) 2024/1781 and replaces the older 2009 Ecodesign Directive. ESPR dramatically widens the scope of EU product rules — moving from energy-related products only to almost every physical good sold on the EU market — and introduces the Digital Product Passport (DPP) as the primary tool for proving compliance.

In short: if your business places physical products on the EU market, ESPR will reach you within this decade. The first delegated acts are expected in 2027.

Who does ESPR apply to?

ESPR is a framework regulation. It sets the rules, then the European Commission adopts product-specific delegated acts that activate those rules for individual product groups. The 2025–2030 working plan prioritises:

• Textiles and footwear (first category, expected from 2027)
• Iron, steel and aluminium
• Furniture, including mattresses
• Tyres
• Detergents, paints and lubricants
• Consumer electronics and small ICT equipment
• Chemicals and energy-related products already covered by the old directive

Construction products and batteries are governed by their own dedicated regulations (CPR and the EU Battery Regulation respectively), but follow the same Digital Product Passport logic.

Digital Product Passport requirements under ESPR

Article 9 of ESPR makes a Digital Product Passport mandatory for every product covered by a delegated act. The DPP is a structured digital record, accessible via a data carrier on the product, that follows the item through its lifecycle. The core DPP requirements are:

• Unique product identifier. Every in-scope product (and in many cases every individual unit) must carry a unique identifier compliant with ISO/IEC 15459 — in practice, a GS1 Digital Link URI.
• Data carrier on the product. A QR code, data matrix or NFC tag must be physically present on the product, packaging or label, readable with a standard smartphone with no app required.
• Structured, machine-readable data. Information must be supplied in a standardised, interoperable format so authorities and third parties can consume it programmatically.
• Role-based access. Different audiences — consumers, repairers, recyclers, customs and market-surveillance authorities — must see different layers of the data set.
• EU Product Passport Registry. Each DPP must be registered with the central EU registry that the Commission is currently building.
• Retention. DPP data must remain available for the lifetime of the product, plus the retention period specified by the relevant delegated act.

What data goes inside a Digital Product Passport?

The exact attribute set is defined per product category, but every DPP under ESPR is expected to cover:

• Product identity, model and manufacturer details
• Material composition, including recycled and bio-based content
• Substances of concern, aligned with REACH and the SCIP database
• Origin and supply-chain information for major production stages
• Environmental performance: carbon footprint, water use, durability
• Repair, spare-parts and disassembly instructions
• End-of-life routing for reuse, refurbishment and recycling
• Compliance documentation, including the EU declaration of conformity

Other ESPR obligations beyond the DPP

The Digital Product Passport is the most visible part of ESPR, but it sits alongside several other obligations that delegated acts can switch on for a given product group:

• Minimum durability, reliability and reusability standards
• Minimum recycled content and design-for-recycling rules
• Restrictions on substances inhibiting circularity
• A ban on the destruction of unsold consumer products (already in force for textiles and footwear from July 2026 for large companies)
• Mandatory disclosure of the share of unsold goods discarded each year
• Performance and information requirements covering carbon and environmental footprints

ESPR compliance timeline

• July 2024 — ESPR enters into force.
• July 2026 — Destruction ban on unsold textiles and footwear applies to large companies.
• 2027 — First product-specific delegated acts expected (textiles is widely briefed as first).
• February 2027 — EU Battery Passport mandatory under the parallel Battery Regulation.
• 2027–2030 — Rolling delegated acts for the rest of the priority categories.
• 2030 — Construction Products Regulation DPPs phase in for major product families.

How to prepare for ESPR and Digital Product Passport requirements

1. Confirm scope. Map each of your product lines to the ESPR working plan. If you sell textiles, electronics, furniture, tyres or steel-bearing goods into the EU, treat 2027 as your deadline.
2. Run a data gap analysis. Compare the attribute list above to what you already capture in PLM, ERP, PIM and supplier portals. Most brands have 40–60% of the data already — the rest sits with tier-2 and tier-3 suppliers.
3. Lock down identifiers. Move from product-level GTINs to serialised GS1 Digital Link URIs so each unit can carry its own DPP.
4. Pilot a connected pack. Print or weave QR codes on one SKU family, wire them through a resolver, and verify the consumer, repairer and recycler views.
5. Pick a DPP platform. Choose a hosting and resolver partner that supports GS1 Digital Link, role-based access, and EU Product Passport Registry integration out of the box.
6. Establish governance. Name an executive owner for ESPR compliance, define change- control on DPP-bearing data, and retain audit logs for the legally required period.

Frequently asked questions

Is ESPR already law?

Yes. ESPR has been in force since July 2024. Specific product obligations activate as the Commission adopts delegated acts, starting with textiles in 2027.

Do I need a separate DPP for batteries?

Yes — battery passports are governed by Regulation (EU) 2023/1542 and are mandatory from 18 February 2027. The same data-carrier and resolver pattern applies, but the data set and access model are defined in the Battery Regulation rather than ESPR.

Does ESPR apply to non-EU manufacturers?

Yes. ESPR applies to any product placed on the EU market, regardless of where it was manufactured. The legal responsibility sits with the importer or authorised representative inside the EU.

What happens if a product is non-compliant?

Market-surveillance authorities can require corrective action, restrict or withdraw the product from sale, and impose fines. Member states set their own penalty regimes, and several have signalled fines linked to a percentage of annual turnover.

Further reading

For a deeper dive into ESPR and Digital Product Passport infrastructure, our SmartLinks platform documentation breaks down the regulation, the GS1 standards underneath it, and the rollout schedule:

• SmartLinks: ESPR & Digital Product Passport overview — how SmartLinks maps to every ESPR data requirement.
• SmartLinks: GS1 Digital Link explained — the identifier standard that powers ESPR-compliant DPPs.
• SmartLinks: DPP rollout timeline — category-by-category dates from 2024 through 2030.
• SmartLinks: DPP & ESPR glossary — plain-English definitions of the terms used above.
• SmartLinks: Connected-product concepts — resolvers, role-based views and the architecture behind a working DPP.