Digital Product Passport Requirements: What’s Mandatory in 2026 and 2027

For the past few years, the Digital Product Passport (DPP) has been easy to file under “something we’ll need to worry about eventually.”

Eventually is now getting a lot closer.

The infrastructure is now being put in place, product-specific rules are moving forward, and by February 2027, certain batteries sold in the EU will need a digital passport containing detailed, accessible information about everything from their composition and performance to their origins and end-of-life handling.

And that first deadline matters even if you do not sell batteries.

The Digital Product Passport is part of a much broader shift in how the EU expects companies to manage and communicate product information. Over time, more manufacturers, retailers, distributors, and brands will need to prove not only what a product is, but where its materials came from, what claims can be substantiated, how it should be repaired or recycled, and whether that information can be traced back to a reliable source.

That makes DPP compliance much more than a QR-code project. It is fundamentally a product information challenge.

So, what is actually mandatory today? What changes in 2027? And what should companies be doing now to make sure their product data is ready?

What is a Digital Product Passport?

A Digital Product Passport is a structured digital record associated with a product, component, or material. It is designed to make reliable information available throughout the product lifecycle, supporting sustainability, circularity, and regulatory compliance.

Depending on the category, a DPP may contain information about product identity, materials, origin, environmental performance, durability, repair, reuse, hazardous substances, and recycling. Users access it through a data carrier, such as a QR code, attached to the product, packaging, or accompanying documentation.

A DPP must use a unique identifier, follow applicable interoperability requirements, be registered in the EU DPP Registry, and remain accurate over time. The Registry stores identifiers and metadata, while detailed data remains decentralized under the responsible operator or a service provider.

Which companies are affected?

The Ecodesign for Sustainable Products Regulation (ESPR) establishes a framework that can ultimately apply to most physical goods placed on the EU market, including components and intermediate products. Food, feed, medicines, living organisms, and products of human origin are among its exclusions.

The ESPR does not automatically require every covered product to have a passport. Product-specific delegated acts determine which products need one, what information it must include, and when compliance begins.

The rules apply to domestic and imported products. Responsibility can fall on manufacturers, authorized representatives, importers, distributors, dealers, or fulfillment service providers. Primary responsibility for creating an accurate DPP generally sits with the economic operator placing the product on the EU market. Online marketplaces will also need to make applicable passports accessible during distance sales.

A UK, US, or Asian brand is therefore not outside the regime simply because it has no EU factory. 

Any business selling an in-scope product into the EU must determine which operator is responsible and ensure the required information can move across the supply chain.

What is mandatory in 2026?

For most sectors, 2026 is the year the DPP infrastructure becomes operational, not the year every product needs a passport.

The EU DPP Registry became operational on July 20, 2026. Six harmonized technical standards were formally adopted in July, with two additional standards scheduled for September. The Commission also plans to adopt product-specific requirements for iron and steel in the fourth quarter of 2026.

Yet an adoption date is not a compliance date. The Commission states that companies will receive a transition period of at least 18 months after an ESPR delegated act is adopted. On that minimum timetable, even if the iron-and-steel act arrives as planned in late 2026, its practical deadline would fall in 2028 or later.

Inclusion in the ESPR working plan means a product group is being assessed and regulated; it does not create an immediate DPP obligation.

What becomes mandatory in 2027?

The clearest binding deadline is February 18, 2027. From that date, every electric-vehicle battery, light-means-of-transport battery, and industrial battery with a capacity greater than 2 kWh placed on the EU market or put into service must have a battery passport.

This covers EV batteries, batteries for e-bikes, e-mopeds, and e-scooters, and qualifying industrial batteries. The operator placing the finished battery on the market (not the supplier of an individual cell or module) is responsible for creating and maintaining the passport. It must be linked to the battery through a QR code.

The Commission’s August 2026 guidance maps 71 possible battery-passport data points and identifies which are mandatory, optional, conditional, or not yet required at launch. Relevant information includes identifiers, manufacturer details, model and serial or batch information, manufacturing location and date, weight, capacity, chemistry, critical raw materials, hazardous substances, performance, durability, and information supporting repair, reuse, and recycling.

Other sectors will advance during 2027. Delegated acts are planned for construction materials, textiles, aluminum, and tires. These are expected rule-adoption milestones, not automatic 2027 compliance deadlines. A planned 2027 textiles act, for example, does not mean every garment must carry a DPP before year-end; the minimum transition period still applies.

What is required for DPP success?

The visible QR code for a DPP is actually the final step. The difficult work is creating complete, transparent, and traceable product information behind it.

Completeness means identifying every required field, determining whether it applies at model, batch, or item level, and collecting it from systems and suppliers. Data may be spread across PIM, ERP, PLM, compliance, lifecycle-assessment, and supplier platforms. Missing evidence cannot be solved with polished copy at the last moment.

Transparency means making reliable information available to the right audience. Some data will be public, while other information may be restricted to authorities, repairers, or authorized actors. Sustainability claims should connect to calculations, certificates, and source records, not stand as unsupported marketing statements.

Traceability means giving products and operators stable identifiers and preserving the origin, timestamp, ownership, and approval history of each data point. Passport information must remain accurate as a product is repaired, repurposed, or otherwise changes.

Companies also need named data owners, validation workflows, supplier requirements, change controls, and interoperable systems. A central product information layer can coordinate the data, but it must connect to the specialist systems where technical, environmental, and compliance evidence originates.

The 2027 battery deadline is only the beginning. As DPP requirements expand into additional sectors, businesses will need to have a reliable foundation for managing complete, transparent, and traceable product information.

That means bringing product data together, improving its quality, establishing clear governance, and making it easier to connect information from suppliers, compliance systems, ERP, PLM, and other sources. Those capabilities are valuable for DPP compliance, but they also support better product experiences, faster channel activation, and stronger readiness for future regulatory requirements.

Akeneo can help businesses build that foundation. By centralizing, enriching, governing, and distributing trusted product information, Akeneo gives teams a more scalable way to prepare for evolving requirements like the Digital Product Passport.

See how Akeneo can help you build a product information foundation that is ready for what comes next.