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Digital Product Passport FAQ
The 30 most common questions about the Digital Product Passport, answered briefly — deadlines, scope, cost, data, QR codes, customs and enforcement.
This page collects the questions we are asked most about the Digital Product Passport, with short answers. For depth see the DPP guide, for the law the ESPR guide, and for terminology the glossary.
Frequently asked questions
What exactly is a Digital Product Passport?
A structured digital record holding a product's identity, material composition, environmental performance, compliance evidence and end-of-life instructions, reached through a QR code, Data Matrix or NFC tag on the product.
When does the DPP become mandatory?
The only date fixed in law today is 18 February 2027 — the battery passport for EV, LMT and industrial batteries above 2 kWh. For ESPR product groups the obligation starts once the relevant delegated act's 18–36 month transition period ends: roughly 2027–2028 for steel, 2028–2029 for textiles.
Is the DPP mandatory in 2026?
No. 2026 is the infrastructure year: the EU DPP Registry went live and the system standards were published. Product-level obligations start with batteries in 2027.
Which products are in scope?
The ESPR Working Plan named six priority groups: iron and steel, aluminium, textiles/apparel, tyres, furniture and mattresses, plus two horizontal measures (repairability scoring, EEE recycled content) and the energy-related products carried over from the old Ecodesign Directive. Batteries come from a separate regulation.
I export to the EU from outside it — does this apply to me?
Yes. The duty attaches to placing a product on the EU market. The legal addressee may be the EU importer or authorised representative, but the data request reaches the manufacturer through the contract chain.
Who is responsible?
The economic operator placing the product on the EU market. For a non-EU manufacturer that is in practice the importer or authorised representative. Technical operation can be delegated to a service provider; legal responsibility cannot.
Are SMEs exempt?
There is no blanket exemption. Micro and small enterprises are exempt from specific provisions such as the unsold-goods destruction ban, but no such carve-out exists for the passport itself. See the SME guide.
Isn't my existing QR code enough?
Usually not. A marketing QR points at a web page. A DPP needs a standard identifier scheme, machine-readable data, access tiers, versioning and registry registration. See DPP vs barcode and QR.
Which data carrier should I use?
EN 18220 allows QR, Data Matrix, NFC and RAIN RFID, and requires at least one carrier to be free, app-free and smartphone-readable. In practice the default is a QR code. See QR code design.
Should the passport be per model or per item?
The delegated act decides. Textiles are expected at model or batch level, while batteries require item level, which brings serialisation and printing cost. See choosing granularity.
Will competitors see my data?
No. Only the public tier is open to everyone. Formulations, supplier lists and costs stay in restricted tiers, released only to authorised roles. See restricted data tiers.
How long must the passport stay online?
For the expected lifetime of the product. EN 18221 sets the storage and archiving rules, and backup service providers exist so the record survives the operator disappearing.
What does a DPP cost?
Compliance-only setups stay under €15,000 a year; enterprise programmes exceed €100,000. Per-passport cost is typically €0.50–€2.00, with QR printing under €0.02 a unit. Small brands usually spend €2,500–€10,000 in year one. See the cost guide.
What is the biggest cost line?
Not software — the labour of collecting supplier data. Getting fibre origin, recycled content and energy data from tier-2 and tier-3 suppliers is the longest item in the plan.
Is registration in the EU DPP Registry mandatory?
For in-scope products, yes. The unique identifier must be registered before the product is placed on the market. The registry holds the identifier and hosting pointer, never the passport content. See the Registry guide.
What will customs check?
That the declared commodity code matches the identifier registered in the registry. A mismatch can block release for free circulation. See DPP checks at customs.
What are the penalties for non-compliance?
Member States set them; ESPR requires them to be effective, proportionate and dissuasive. Beyond fines, products can be withdrawn from the market and companies temporarily excluded from public procurement. See the cost of non-compliance.
Do I have to publish a carbon footprint?
It depends on the product group. For batteries the carbon footprint value and performance class sit in the public tier. Other groups will be defined by their delegated act — and many brands already require it contractually. See the carbon guide.
Which languages must the passport be in?
The languages of the Member States where the product is sold. The practical approach is to store core data as language-independent codes and translate at the presentation layer. See multilingual passports.
Should I build my own system or buy one?
It depends on SKU count, internal capacity and integration needs. For most compliance-driven manufacturers a ready platform is faster and cheaper. See build vs buy.
Where do I start?
With scoping and a data inventory. An end-to-end pilot on one product family is the fastest way to learn. See a 90-day DPP pilot and the compliance checklist.
