Digital Product Passport Is Live: What Manufacturers Should Prepare for in 2026–2027
The Digital Product Passport has moved from a regulatory concept to an operating part of the European Union’s product-compliance framework. As of September 2026, the EU Digital Product Passport Registry is live, the rules governing its operation have been adopted, and manufacturers can see much more clearly how product identification, registration and data exchange will work. This does not mean that every physical product sold in the EU already requires a passport. Obligations are being introduced product by product through the Ecodesign for Sustainable Products Regulation, commonly known as the ESPR, and through other EU legislation. The distinction matters because 2026 and 2027 are primarily a transition period for many industries, while certain battery manufacturers face a firm passport deadline on 18 February 2027. For other sectors, including textiles, iron and steel, aluminium and tyres, the immediate task is to organise reliable product and supply-chain information before detailed requirements become applicable.
The Digital Product Passport Has Moved Into Its Operational Phase
The legal foundation for the Digital Product Passport comes principally from Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation, which entered into force on 18 July 2024. The ESPR allows the European Commission to introduce sustainability and information requirements for a very broad range of physical goods sold or put into service in the EU. Instead of imposing an identical information package on every industry, it establishes a common framework and leaves the detailed requirements to later rules for individual product groups. This approach is important for manufacturers because a passport for a textile product will not necessarily contain the same data, have the same level of identification or follow exactly the same update process as a passport for steel, furniture or another regulated product. Companies therefore need to understand both the common DPP principles and the legislation affecting their own products.
A Digital Product Passport is essentially a structured electronic record connected to a product through a persistent unique identifier and a data carrier, which may take the form of a QR code or another machine-readable method specified by the relevant legislation. Depending on the product rules, the passport may contain information about materials, sustainability characteristics, repairability, recycled content, substances of concern, technical documentation, the manufacturer, other economic operators and end-of-life treatment. Access is not necessarily identical for everyone. Certain information may be available to customers, while other information can be reserved for market-surveillance authorities, customs officials, repairers, recyclers or other authorised parties. This makes the DPP more than a digital product label: it is intended to maintain usable product information throughout a significant part of the product’s life cycle.
The architecture is also different from the idea of one enormous EU database holding every piece of information about every product. Under the ESPR, DPP information is based on a decentralised model. Economic operators remain responsible for creating and maintaining the relevant passport data, while the EU registry stores the information necessary to identify and verify registered passports, including unique identifiers and, where applicable, commodity codes for products entering the EU customs territory. The rules also require information to remain accessible in an interoperable format rather than being locked into one supplier’s proprietary technology. For manufacturers, this has an important commercial consequence: the long-term value lies in controlling accurate product data and identifiers, not simply in purchasing a QR-code generator or a standalone compliance application.
What Actually Changed in 2026
A major practical step occurred in July 2026 when the European Commission announced that the Digital Product Passport Registry had gone live. Commission Implementing Regulation (EU) 2026/1778, adopted on 16 July 2026, sets out how the registry operates and how manufacturers and other economic operators will interact with it. The registry includes a secure user interface as well as an API for automated registration, mechanisms for checking submitted information, registration of unique identifiers and relevant commodity codes, and records of changes made to registrations. After successful registration, the registry can generate a unique registration identifier and provide evidence that the relevant DPP registration has been completed. This gives manufacturers something much more concrete than the broad legal principles that existed when the ESPR first entered into force.
The 2026 rules also clarify who can make registrations. Economic operators need verified status before they can register new Digital Product Passports or modify relevant registration information. The regulation provides methods for verifying natural persons and legal entities using recognised electronic identification credentials. A verified economic operator is also responsible for keeping its registration information accurate, complete and up to date and for protecting the credentials and IT systems used to interact with the registry. Businesses that use another organisation to carry out registration work do not simply transfer away their legal responsibility: the verified economic operator remains responsible for compliance with the applicable obligations. Manufacturers should therefore treat registration authority and account control as governance matters rather than leaving them entirely to an external technology supplier.
What did not change in 2026 is equally important. The registry becoming operational does not create an immediate passport duty for every manufacturer selling goods in Europe. Under the ESPR, the Commission must adopt product-specific delegated acts defining the actual information required, the relevant data carrier, whether the passport applies at model, batch or individual-item level, who may access particular information, who may update it and how long the passport must remain available. As a general rule, the application date of a new ESPR delegated act cannot be earlier than 18 months after that act enters into force, unless an earlier date is justified under the Regulation. Manufacturers should therefore separate three different events when planning: publication of a proposed rule, adoption of the final delegated act and the later date on which businesses must actually comply.
Which Manufacturers Face the Closest 2026–2027 Changes
The Commission’s first ESPR and Energy Labelling Working Plan for 2025–2030 provides the clearest indication of which industries should be preparing first. The plan gives iron and steel an indicative adoption timetable of 2026. Textiles and apparel, tyres and aluminium have indicative 2027 dates, while a horizontal measure concerning repairability, including a possible repairability score, is also scheduled for 2027. Furniture follows with an indicative 2028 date and mattresses with 2029. These dates concern the planned adoption of EU measures rather than an automatic requirement to attach a compliant DPP to every affected product on 1 January of the stated year. The distinction is particularly important for budgeting because the ESPR normally provides businesses with a compliance period after a delegated act enters into force.
Iron and steel illustrate how this process works in practice. The original working plan placed these intermediate products on the 2026 timetable, but as of 17 September 2026 the relevant Commission initiative remains in the rule-development process, with adoption planned for the fourth quarter of 2026. Preparatory work has examined the information that could be required for the Digital Product Passport and how sustainability data can travel through steel supply chains, but manufacturers should not treat preliminary proposals as final legal fields. A company producing steel, importing it into the EU or using large quantities of regulated intermediate steel in downstream production should nevertheless begin identifying where information on materials, production routes, environmental characteristics, product identification and supporting evidence currently resides. Waiting for the final legal text before locating this data could leave too little time for supplier engagement and internal system changes.
Textiles and apparel, aluminium and tyre manufacturers are one stage further from an immediate ESPR compliance date, but 2027 is still commercially important. The Commission’s working plan places the adoption of measures for these groups in that year, meaning companies should expect increasingly specific draft requirements, consultations and technical discussions. Textile businesses in particular often work with multi-tier international supply chains in which fibre producers, fabric mills, dyeing facilities, garment manufacturers, brand owners and importers hold different parts of the relevant information. Aluminium products can similarly involve several production and processing stages before reaching the EU market. The sensible objective for 2026–2027 is therefore not to guess every future mandatory DPP field. It is to establish a dependable process for receiving, checking, linking and retaining supplier information so that confirmed legal requirements can later be added without rebuilding the entire data process.
Batteries Are the First Major 2027 DPP Deadline
Batteries require a different level of urgency because their passport obligation does not depend on a future ESPR product-specific act. Regulation (EU) 2023/1542 already establishes a firm date. From 18 February 2027, each light means of transport battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the EU market or put into service must have an electronic battery passport. From the same date, all batteries covered by the Regulation must carry a QR code, although the information reached through that code differs by battery category. For the battery categories subject to the full passport requirement, the QR code provides access to the battery passport and is linked to a unique identifier assigned by the economic operator placing the battery on the market.
The battery passport shows why manufacturers should think about the DPP as an ongoing information record rather than a static webpage. The Batteries Regulation requires both information concerning the battery model and information connected to the individual battery. Different access levels apply to different categories of data. Publicly available information is separated from information intended for authorities and notified bodies, while certain detailed information can be available to parties with a legitimate interest, including actors involved in repair, remanufacturing, second-life use or recycling. Depending on the relevant access category, the passport can include information on composition, performance and durability, battery status and data resulting from use. The economic operator placing the battery on the market is responsible for ensuring that passport information is accurate, complete and up to date.
For battery manufacturers, vehicle manufacturers, importers and businesses integrating industrial batteries into larger products, preparation therefore has to move beyond general DPP awareness. Companies need to know which legal entity will place each battery on the EU market, how the unique identifier will be generated and maintained, which information comes directly from their own manufacturing records, which fields depend on suppliers and which information may change during the battery’s life. They also need to ensure that data intended for different audiences can be separated according to access rights. The February 2027 deadline leaves little room for a sequential approach in which procurement, compliance, engineering and IT departments begin their work only after another team has finished. Data collection, legal interpretation, product identification and testing of the complete passport process need to run in parallel.
How Manufacturers Should Prepare Without Overcomplicating the DPP
The first useful step for most manufacturers is a product-data inventory. Rather than beginning with a technology purchase, the company should identify what information already exists for each affected product family and where it is maintained. Relevant sources may include product master records, bills of materials, technical files, declarations of conformity, supplier certificates, environmental calculations, manufacturing records, repair instructions and recycling documentation. Each important data field should have an identifiable owner and supporting evidence. The manufacturer should also distinguish information that is stable at model level from information that changes by batch or by individual product. This distinction will become important because product-specific EU rules can require a DPP to operate at model, batch or item level, and managing millions of item-level records is very different from maintaining one record for a product model.
Supplier management is the second major area. Many of the sustainability characteristics expected to appear in future passports cannot be created accurately by the final manufacturer without information from earlier stages of the value chain. Existing purchasing agreements may require suppliers to meet technical specifications but say little about structured sustainability data, updates or documentary evidence. During 2026 and 2027, manufacturers should review whether suppliers can provide relevant information in a consistent format, how changes will be communicated and who is responsible when a material, production site or component changes. Contracts for new products can also address the right to use supplier information for regulatory reporting. The objective is not to collect every possible environmental figure in advance. It is to prevent a situation in which a mandatory DPP field cannot be completed because the evidence exists several tiers upstream and nobody is required to provide it.
Internal governance deserves the same attention as supply-chain data. A Digital Product Passport touches compliance, product management, procurement, manufacturing, sustainability, IT, quality control and sometimes after-sales operations. If each department maintains a separate version of the same information, inconsistencies can quickly appear between the DPP, technical documentation and the physical product. Manufacturers should therefore determine which internal record is authoritative for each category of data, who approves a passport before market release and what event triggers an update. Product changes should be linked to DPP change management so that a new material, supplier, facility or specification is assessed for its effect on published information. This is particularly important because EU rules require DPP data to be accurate and current, making information maintenance a continuing compliance responsibility rather than a one-off task at product launch.
A Practical Readiness Plan for the Rest of 2026 and 2027
Manufacturers should first establish who will carry the regulatory responsibility for products placed on the EU market. For an EU manufacturer this may be relatively straightforward, while international supply chains require closer coordination between the producer, importer and other relevant economic operators. Businesses that will need to register Digital Product Passports should also prepare for the identity-verification process introduced by the 2026 registry rules and decide who inside the organisation is authorised to manage registrations and user access. Battery businesses should treat this as an immediate operational requirement because their February 2027 deadline is fixed. Companies in sectors awaiting ESPR delegated acts can use the same work to establish responsibilities before large numbers of registrations become necessary.
A controlled pilot with a small number of real products is usually more useful than trying to build a company-wide DPP programme in one step. The pilot should follow the complete information journey: creation of the product identifier, connection between the physical data carrier and the electronic record, retrieval of supplier information, validation of required fields, control of public and restricted information, registration and later correction of data. Manufacturers should also consider continuity. The ESPR requires Digital Product Passport information to remain available for the period defined by the applicable product rules, and it requires a back-up copy to be made available through an independent DPP service provider when a product is placed on the market. Any chosen solution therefore needs to support long-term access, data transfer and changes of service provider rather than making the manufacturer dependent on one proprietary arrangement.
The most realistic way to plan the next 12 to 18 months is to treat 2026 as the year in which DPP infrastructure became operational and 2027 as the year in which the first major product-level obligation becomes visible at scale. Battery businesses have the clearest immediate compliance date, while manufacturers of steel, textiles, apparel, tyres and aluminium should follow the applicable EU rulemaking closely and prepare their product information before final obligations take effect. Companies do not need to predict every future data field, and they should avoid redesigning all business systems solely on the basis of draft proposals. They do need reliable identifiers, traceable evidence, clear responsibility for data quality and suppliers capable of providing the information required from them. Those foundations will remain useful even as individual delegated acts define different DPP content for different products.
