ESPR
ESPR Articles 9–13: The DPP Provisions
The core ESPR articles behind the DPP — Article 9 the requirement, Article 10 technical design, Article 12 registry data and Article 13 the registry.
The Digital Product Passport core of ESPR (EU) 2024/1781 sits in five articles. They do not answer "which data" — delegated acts do that — but they set the principles the system must be built on.
Article 9 — the passport requirement
For products brought into scope by a delegated act, this establishes the passport, its link to a data carrier and the data requirements listed in Annex III. The passport must exist when the product is placed on the market — it is not a document to be completed later.
Article 10 — technical design
This is the article with the most operational consequence. Four principles:
- Open standards: closed, proprietary formats are not acceptable.
- Machine readability: data cannot be served only as a human-readable page.
- No vendor lock-in: passport data must be portable without dependence on one supplier.
- Data persistence: accessibility for the expected lifetime of the product.
These four are the reason the EN family described in the DPP standards guide exists. They also give you concrete vendor questions: "can I export my data in a standard format?", "if I switch providers, do my printed links break?" See choosing DPP software.
Article 11 — data carriers and identifiers
Requires the carrier to be physically attached to the product and unique identifiers to be used. The technical detail arrives via EN 18219 and EN 18220. See EN 18220.
Article 12 — registry data
Defines what is submitted to the registry: unique identifiers, economic operator information, product category and the commodity code for customs. Note: passport content does not go to the registry.
Article 13 — the central DPP Registry
Obliged the Commission to establish a central registry by 19 July 2026. The registry is an index holding the identifier, hosting address and verification data. See the EU DPP Registry guide and registering a DPP step by step.
Enforcement: Articles 77–83
Enforcement runs through Market Surveillance Regulation (EU) 2019/1020; penalties are set by Member States and must be effective, proportionate and dissuasive. See market surveillance and enforcement.
Frequently asked questions
Do these articles bind me today?
Not directly. They bind once a delegated act for your product group is adopted and its transition period ends — but the technical principles should shape your system design now.
Does Annex III give the full data list?
Annex III gives categories and principles; the exact field list comes with the delegated act. See DPP data fields.
What does "no vendor lock-in" mean in practice?
That you can take your data out in a standard format and that your printed QR links keep working when you change provider. It is the strongest argument for using a resolver. See what a resolver is.
