● Knowledge · 07 Context

Digital Product Passport: the battery passport comes first.

With the Ecodesign Regulation (ESPR 2024/1781) the EU is introducing the Digital Product Passport (DPP) for entire product categories - from textiles to steel. Batteries lead the way: the digital battery passport under Regulation 2023/1542 becomes the first legally mandatory DPP on 18 February 2027. Whoever builds it is building the blueprint for everything that follows.

Reading time approx. 9 min · Updated: · Not legal advice
No. 1
First mandatory DPP
The battery passport from 18 Feb 2027
2024/1781
ESPR in force
Ecodesign Regulation since 18 July 2024
6+
Product groups
Prioritised in the 2025 ESPR working plan
1 QR
Data carrier
One scan, role-based data layers
In brief
  • The DPP is an EU-wide concept. The Ecodesign Regulation (ESPR 2024/1781) makes the Digital Product Passport the standard instrument for sustainable products - product group by product group.
  • Batteries go first. The digital battery passport under Regulation 2023/1542 becomes the first mandatory DPP on 18 Feb 2027 - ahead of textiles, steel and everything else.
  • The architecture is the same. Unique identifier, QR code as the data carrier, role-based access, decentralised data storage - what the battery passport implements today, the ESPR will prescribe for further sectors tomorrow.
  • Build once, use twice. A clean battery passport infrastructure is at the same time your DPP infrastructure for upcoming product groups - data model, serialisation and access logic are reusable.
01 · Basics

What is a Digital Product Passport?

A Digital Product Passport (DPP) is a structured record for an individual product, accessible via a data carrier - in practice a QR code - on the product itself. It answers the questions that used to be scattered across PDFs, certificate folders and supplier spreadsheets:

1
What is inside?

Materials, critical raw materials, hazardous substances, recycled content and the carbon footprint - machine-readable instead of a loose document.

2
Where does it come from?

Manufacturing site, economic operator, conformity evidence and supply chain due diligence - traceable for market surveillance and procurement.

3
What happens afterwards?

Repair, dismantling, second life and recycling - the data the circular economy needs travels with the product.

Its legal basis is the Ecodesign for Sustainable Products Regulation (ESPR) 2024/1781, in force since 18 July 2024. It defines the DPP as a framework - which product group follows when, and with which data fields, is set by the Commission via delegated acts.

02 · Pioneer

Why the battery passport is the first DPP

The Battery Regulation 2023/1542 was faster than the ESPR: in Article 77 it already mandates a complete product passport - with a unique identifier, QR code and role-based data layers. That makes the battery passport the EU's first legally mandatory Digital Product Passport and the real-world test for the entire DPP concept:

17 Aug 2023

Battery Regulation 2023/1542 in force

The EU adopts the digital battery passport - years before the ESPR creates the DPP framework for other products.

18 Jul 2024

ESPR 2024/1781 in force

The Ecodesign Regulation anchors the Digital Product Passport as the standard instrument for almost all physical products in the EU single market.

16 Apr 2025

First ESPR working plan

The Commission prioritises the first product groups - including textiles, iron and steel, aluminium, furniture, tyres and mattresses.

18 Feb 2027Deadline

The first mandatory DPP goes live

Every EV, LMT and industrial battery above 2 kWh needs a digital battery passport with a QR code - the DPP turns from concept into market reality.

03 · Architecture

The DPP architecture - already reality in the battery passport

What the ESPR defines as a framework, the Battery Regulation already implements in concrete terms. The building blocks are identical:

DPP building block (ESPR)Implementation in the battery passportStatus
Unique product identifier per unitSerial number per ISO/IEC 15459, linked to model and batch data (Art. 77(3))In the battery passport
Data carrier on the productQR code per ISO/IEC 18004, printed or engraved - visible, legible, durable (Art. 13)In the battery passport
Role-based data accessPublic layer for everyone, deeper layers for recyclers, market surveillance and persons with a legitimate interestIn the battery passport
Decentralised data storageData stays with the economic operator or its service provider - the EU only runs a central registry of identifiersIn the battery passport
Interoperability & open standardsGS1 Digital Link as the URL structure, data model per DIN DKE SPEC 99100, ready for Catena-X / AASIn the battery passport
Updatability across the life cycleDynamic data such as state of health (SoH), repairs and second-life status is kept up to dateIn the battery passport

Simplified comparison based on ESPR 2024/1781 (Ch. III) and Regulation (EU) 2023/1542 (Art. 77, Annex XIII). Which data specifically belongs in the battery passport is covered in Which data goes into the battery passport?

04 · Outlook

Which product groups are next

The first ESPR working plan (April 2025) names the prioritised candidates. The concrete DPP obligations arrive per group via delegated acts - realistically phasing in from around 2027/2028:

Textiles & apparel
Fibre composition, recycled content, repairability - one of the first candidates of the ESPR working plan.
Iron & steel
Carbon-intensive base materials: origin, emission data and scrap shares become subject to proof.
Aluminium
Like steel a prioritised base material - with a focus on energy input and recycled content.
Furniture & mattresses
Materials, hazardous substances, disassembly and spare parts for the circular economy.
Tyres
Abrasion, lifetime and material recovery - data for the environment and market surveillance.
Electronics & ICT
Under discussion as a follow-up candidate: repairability, critical raw materials and software update commitments.

As of July 2026: dates not yet final

The delegated acts for the ESPR product groups are still pending - scope and deadlines may shift. Only the battery passport is fixed: 18 February 2027, with no transition period for new products.

05 · Strategy

What this means for manufacturers

The battery passport is not an isolated solution - it is the first stage of an EU-wide data infrastructure. That changes the calculation:

1
Build once

Serialisation, QR output, role-based passport pages and supplier data - the battery passport infrastructure is the DPP infrastructure.

2
Use repeatedly

If you have further ESPR-covered products in your portfolio, you extend the data model - instead of starting a new IT project per product group.

3
Benefit early

Buyers and OEMs already ask for DPP capability in tenders today - a well-kept battery passport is the proof.

06 · FAQ

Frequent questions about the Digital Product Passport

What is a Digital Product Passport (DPP)?
A Digital Product Passport is a structured, digital record for an individual product - accessible via a data carrier such as a QR code on the product itself. It contains information on materials, origin, carbon footprint, repairability and recycling, and makes it available to consumers, market surveillance and the circular economy. Its legal basis is the EU Ecodesign for Sustainable Products Regulation (ESPR 2024/1781).
Is the battery passport a Digital Product Passport?
Yes. The digital battery passport under EU Battery Regulation 2023/1542 is the EU's first legally mandatory Digital Product Passport. It uses exactly the DPP architecture: a unique product identifier per ISO/IEC 15459, a QR code as the data carrier, role-based data access and decentralised data storage with the economic operator.
When does the Digital Product Passport become mandatory?
For batteries from 18 February 2027 (EV, LMT and industrial batteries above 2 kWh). For further product groups the European Commission sets the dates via delegated acts - the first ESPR working plan of April 2025 prioritises textiles, iron and steel, aluminium, furniture, tyres and mattresses, among others. Realistically these DPPs will phase in from around 2027/2028.
What data must a DPP contain?
The EU defines this per product group. For the battery passport it is more than 90 data points from Annex XIII of the Battery Regulation: material composition, critical raw materials, carbon footprint, recycled content, performance and durability data, plus dismantling and recycling information - split across public and access-restricted data layers.
Do I need dedicated software for the DPP?
In practice, yes. A DPP requires a unique identifier per unit, a permanently resolvable link, role-based access and updatable data across the entire life cycle - neither a static QR generator nor a PDF archive can deliver that. Whoever introduces battery passport software today is building their DPP infrastructure for upcoming product groups at the same time.
07 · Sources

Sources & further reading

Your first DPP - already mandatory today

Build the EU's first Digital Product Passport - with Batteriepasswerk.

Every battery passport from Batteriepasswerk is a fully-fledged Digital Product Passport: unique identifier, GS1 Digital Link QR, role-based access - compliant with EU 2023/1542 and DIN DKE SPEC 99100, hosted in the EU.