Digital Product Passport: What Manufacturers Must Do

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From 18 February 2027, manufacturers and importers of certain batteries must provide a digital passport with a QR code. Consumer-goods companies and retailers with affected products or in priority groups such as textiles must now set up data models, data carriers and supply-chain processes. The central EU register will be established by 19 July 2026.

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Battery-passport launch in February 2027: Which batteries are first affected

Commission Regulation (EU) 2023/1542 mandates the battery passport from 18 February 2027. The obligation covers batteries for electric vehicles, light means of transport (LMT) and industrial batteries with more than 2 kWh capacity that are placed on the EU market or put into service. The passport must be maintained as an electronic data record and made accessible via a QR code.

Manufacturers or importers placing such batteries on the market are responsible. The passport contains a unique identifier, model and battery data plus further information as set out in Annex XIII of the Regulation. Early versions focus on static data; later updates may include performance and condition data.

Many consumer products contain or are sold with such batteries. Electronics retailers, power-tool makers and providers of e-mobility products are therefore directly affected. If you only sell finished goods, you must ensure that the built-in or supplied batteries carry the passport.

Central Register and Standards: Deadline 19 July 2026

The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) entered into force on 18 July 2024. It establishes the framework for digital product passports across all product categories. Article 13 requires the European Commission to set up a central register by 19 July 2026. This register will hold data carriers and unique product identifiers. It does not store the full product data but enables authorities and authorised users to locate and verify the information.

In May 2026, CEN/CENELEC published the first standards in the EN 182xx series. EN 18220 governs data carriers. EN 18222 defines APIs for lifecycle management and search. At least one data carrier must be readable with a standard smartphone without additional apps. GS1 Digital Link URIs are considered the preferred solution for QR codes.

Companies may store their data decentrally. The register simply points to the respective dataset. Any business placing products on the EU market must ensure registration and linkage with the register.

Required Data and Supply-Chain Integration

According to Annex XIII and Article 77 of the Battery Regulation, the battery passport requires roughly 80 to 90 attributes. They are grouped into clusters such as general battery and manufacturer information, material composition and critical raw materials, carbon footprint, performance and durability data, supply-chain traceability, and details on repair, reuse, and recycling.

More general requirements for product passports under the ESPR will be specified in delegated acts for each product category. These typically cover product identification, eco-design parameters, ingredient information, repairability, recyclability, and end-of-life instructions. Part of the data is publicly accessible; other sections are protected by role-based access.

Data must remain up to date throughout the entire product life cycle. That calls for structured procurement along the supply chain. Suppliers need to deliver material declarations, proof of origin, and environmental metrics. EU importers assume responsibility for accuracy and completeness when the manufacturer is based outside the EU. Contracts with suppliers must include explicit data-delivery obligations.

Starting the data chain in 2027 means negotiating with suppliers under time pressure. Pulling it into contracts and master data in 2026 saves double the work for textiles and other groups.

QR Code, Data Carrier and Placement

The data carrier must be permanently attached to the product, its packaging, or accompanying documents. QR codes are the standard. They have to comply with EN 18220 and contain a unique identifier that links to the passport. RFID or NFC solutions are permitted, but do not replace the smartphone-readable carrier.

Placement must survive the entire life cycle. For packaging, ensure adequate size and contrast. The code must not use short URLs or redirects that could jeopardise permanent accessibility. GS1 recommendations call for Digital-Link URIs so scanners can retrieve structured information directly.

Responsibilities of Importers, Dealers and SMEs

Any party placing a product on the EU market is an economic operator under the rules. For imports from third countries, the importer bears the obligation. Dealers may not place products without the required passport and must not obstruct access to existing passports. With own-brand or direct imports, they carry full responsibility for data collection and maintenance.

SMEs face the challenge that many suppliers still lack structured data. A central product database, clear supplier requirements, and pilot projects for the first affected items are typical first steps. Leveraging existing GS1 and PLM systems reduces effort. Platforms must support the upcoming API standards.

Practical Implementation: Checklist for Consumer-Goods Companies

1. Audit product portfolio for affected batteries and future groups (textiles, furniture, electronics) and prioritise by deadlines.
2. Review existing product data (master data, BOM, LCA, supplier declarations) for completeness and structure, then create a single source of truth.
3. Amend supplier contracts to include concrete data-delivery obligations (materials, footprints, origin) and agree on transfer formats.
4. Select technical solution: unique identifier (GTIN), GS1-compliant QR code, backend with role-based access control, and interfaces to future standards.
5. Run a pilot for one to two products, prepare registration in the database, and define internal responsibilities and update processes.

Next Groups and Longer-term Preparation

The ESPR work plan 2025-2030 prioritises textiles and apparel as well as tyres for delegated acts around 2027. Furniture and additional groups follow later. The specific data requirements and transition periods are set out in the delegated acts. Transition periods typically run to at least 18 months.

Companies that start building data structures and supplier processes now can meet later requirements with minimal extra effort. Those who only react to the next deadline risk bottlenecks in data collection and technical integration. The obligations cover not only in-house production but the entire supply chain relevant to the EU market.

Frequently Asked Questions

Image source: AI-generated (July 2026)