Digital Product Passport 2026: Who Must Act?

Key dates for retailers

Five dates structure the whole topic — each one comes back later in the article:

• February 18, 2027 — the first mandatory product passport: LMT batteries (e.g. for e-bikes), EV batteries and industrial batteries above 2 kWh (Regulation 2023/1542, Article 77, 2023).
• July 19, 2026 — the ban on destroying unsold clothing, accessories and footwear already applies to large companies (ESPR, Articles 24–26, 2024).
• September 27, 2026 — the EmpCo directive on environmental claims (2024) applies in full.
• around 2029 — the expected start of the passport for textiles and apparel: a delegated act planned for 2027 plus a transition period of at least 18 months (an estimate based on Article 4 of the ESPR).
• July 20, 2026 — the Commission launched the digital product passport registry; six of the eight technical standards are already harmonized.

What is a digital product passport?

A digital product passport (DPP) is a set of data about a specific product, accessible electronically through a data carrier — in practice usually a QR code on the product, its packaging or its documentation. That is how it is defined by Regulation 2024/1781 (ESPR) (Article 2(28)–(30)), which entered into force on July 18, 2024. It is not a single PDF file: the data must be based on open standards, machine-readable and independent of any single provider (Article 10). The ESPR is also a framework regulation — on its own, it does not impose the passport obligation on any product group. The obligations arise only in delegated acts, adopted separately for each category, and it is those acts that will set the data scope, the level of detail (model, batch or individual item) and where the carrier goes.

Who does the DPP apply to, and from when?

As of August 2026 no product-specific delegated act under the ESPR has been adopted — the only hard passport deadline comes from the separate batteries regulation. The timeline for the remaining categories follows from the Commission's working plan for 2025–2030, adopted on April 16, 2025. Its dates are indicative:

Two rows matter most. Batteries: from February 18, 2027 no LMT battery, EV battery or industrial battery above 2 kWh may be placed on the market without a passport accessible via a QR code. Textiles and apparel — the most common assortment of a multibrand store: the delegated act is planned for 2027 and is followed by a transition period of at least 18 months, so expect compliance around 2029.

How to read these dates

The delegated-act dates are declarations from a working plan, not law — the timeline has already slipped once (the first acts were expected in 2025/2026; the current expectation is late 2026 or 2027). You will only know the final shape of the obligations from the adopted act for your category.

What exactly must a multibrand retailer do — and what not?

A multibrand retailer does not create passports and does not register them — but it will have to verify and display them. In ESPR terminology a store is both a "dealer" and a "distributor", with two sets of obligations:

• A gate at goods intake (Article 30(2)–(3)): before you make a product available on the market, you check that it is linked to a passport as the delegated act requires; a product without one cannot go on sale.
• The passport before purchase (Article 31(2) and Article 9(2)): the passport must be easily accessible to potential customers before the contract is concluded — including in distance selling. For ecommerce this means the passport has to be visible on the product listing itself; an email after checkout is too late.
• Records for 10 years (Article 36(2)): when an authority asks, you identify who supplied a product to you and whom it went to next — with quantities and models; the answer is due within 15 days.

Registering passports in the EU registry is the duty of the economic operator placing the product on the market — usually the manufacturer or the importer (Article 13). Watch out for two exceptions: if you import from outside the EU or sell products under your own brand, you place the product on the market yourself — and you take over the manufacturer's full set of obligations, registration included.

Where will a store get passport data from dozens of brands?

The law gives you a concrete mechanism: the economic operator placing a product on the market must provide retailers, free of charge, with a digital copy of the data carrier or of the unique identifier within at most 5 working days of a request (Article 10(3) ESPR). Two things are still up to you. Revise your contracts with brands: a clause on supplying passport data, added at the next renewal of terms, costs little and clearly divides responsibility. And set up a single place for product data — a PIM, an ERP or the store platform — because data from dozens of suppliers scattered across spreadsheets and email will not survive verification at goods intake. The scale of the problem is evident in an IW Köln survey of 1,078 German companies (Intereconomics, 2025): only about half of the companies shared digital product data at all, and of that half just 18% did so in a standardized form. Four percent of respondents had started preparing for the DPP. These are German figures (fall 2024) — and there is little reason to expect other EU markets to look better.

How much does preparing for the DPP cost?

The honest answer: credible per-company estimates do not exist — the ESPR impact assessment (2022) openly calls the costs hard to quantify, and the ranges circulating online have no source behind them. Only fragments can be priced: printing the identifier on an item costs fractions of a eurocent, and in the Commission's textile example certifying recycled content runs from €2,232 with one certified article down to €575 per article with fifty — strong economies of scale. DPP software vendors quote ranges from thousands to tens of thousands of euros per year; treat those as indicative only — they come from companies selling the tools. The Commission's own consultation, for that matter, found cost the least-cited challenge (25% of respondents) — cited far more often were the complexity of products and supply-chain data (79%) and the credibility of the information (74%). If you want to know your starting point, begin not with buying a tool but with an audit of your product data: an ecommerce diagnosis of that scope is €3,000–5,500 net and 2–4 weeks of work.

Should you buy a DPP plugin or platform yet?

For the typical assortment of a multibrand store — not yet, for entirely objective reasons. The data scope a passport must cover will be set only by the delegated acts; for apparel there is no such act, so nobody can sell you a "fully compliant" DPP plugin for textiles today. Six of the eight technical standards (data exchange, identifiers, APIs) were harmonized on July 15, 2026; two are still in the works. Mature PIM platforms are only now building passport features, usually as partner connectors rather than native modules. The tool market will mature together with the delegated acts; buy today and you pay for guessing at the requirements. The reverse order makes sense: you can move well-organized product data into any tool, but no tool will fix data you do not have.

When can you afford to wait?

There are at least four situations where calm observation is a better decision than an investment. If your assortment falls outside the categories of the 2025–2030 working plan — watch, do not invest: the plan covers textiles, tires, aluminum, furniture and mattresses, among others, but not everything an ecommerce store sells. The ban on destroying unsold clothing currently applies only to large companies; medium-sized ones follow from 2030, and micro and small businesses are exempt. Goods placed on the market before the delegated act's application date can, as a rule, still be sold off — the obligation concerns the first placing on the EU market (a conclusion from the definitions in the ESPR; delegated acts may settle the details differently). And there is the argument from history: the timeline has slipped before, and overinvesting in compliance with rules whose final shape nobody knows can cost as much as being late.

What should you do before the end of 2026?

It depends on your assortment profile — four typical scenarios:

1. You sell batteries, e-bikes or equipment with industrial batteries: act now. The February 18, 2027 deadline is written directly into the regulation, and without a passport the product cannot be placed on the market.
2. Apparel or footwear, large company: the ban on destroying unsold items already applies to you — tighten your procedures for returns and unsold stock, and start a product data audit in parallel.
3. Apparel or footwear, SME: a product data audit plus a passport-data clause in brand contracts at the next renewal. No tool purchases.
4. Assortment outside the working plan: follow the Commission's consultations for your category and do not buy anything "just in case".

Whichever scenario applies, everything comes down to the state of your product data — it determines how much this compliance will end up costing you.

How we can help

This article is a neutral guide — and that is the role we take in our work too: we advise, we do not sell DPP tools and we take no commission from their vendors. If you want to know how ready your product data is for passport verification, start with an independent ecommerce diagnosis — we will show you where that data actually lives, what is missing and which first step makes sense at your scale.