Do I need a Digital Product Passport?

Three questions. You get your scope, the date that applies to you, and what data you will have to collect — with no email required to see the answer.

The checker

Q1Do you place products on the EU market?

That means selling as a brand or own-label, or importing into the EU.

Q2What is the product?
Q3Which kind of battery?

The obligation is probably not yours

A Digital Product Passport binds whoever places the product on the EU market — normally the EU brand or the importer of record, not the factory that made it. You will still be asked for the data, and how easily you can hand it over will start to affect who your customers buy from.

See the supplier side

In scope — and this is the firm one

18 Feb 2027

Battery passports are mandatory from 18 February 2027, a date that has not moved. The delegated act detailing the data is expected 18 August 2026. You will need Annex XIII data: composition, carbon footprint, recycled content and sourcing — most of which sits with your cell supplier rather than with you.

How the data gets collected

Not in battery-passport scope

Portable batteries and SLI (car starter) batteries are not covered by the battery passport requirement. Other duties under the Battery Regulation may still apply to you — labelling and carbon-footprint declarations run on their own timetables.

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In scope, with time to prepare

~2028–2029 · indicative

Textiles are in the ESPR queue. The delegated act is expected around 2027 with roughly an 18-month transition, which puts the obligation in the 2028–2029 range — indicative, and it can move. You will need the JRC textile dataset: fibre composition, chemicals, tier data, recycled content and end-of-life. Collecting it is the long pole, not publishing it.

Start with the supplier data

In the ESPR queue

indicative · act-dependent

Your category is in the ESPR working plan, which means a passport is coming but its delegated act sets the date and the data. Those windows are indicative and they move. The work that does not change is knowing your supply chain — that is the part worth starting now.

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Not currently in ESPR passport scope

Toys, cosmetics and food are not in the ESPR Digital Product Passport scope — they sit under their own regimes, which have their own labelling and traceability duties. We would rather tell you that than sell you something you do not need. If that changes, the category pages will say so.

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This is a signal, not legal advice, and not a guarantee of completeness. Dates other than the battery deadline depend on delegated acts that have not been adopted yet.

The same questions, answered plainly

Is a Digital Product Passport mandatory?

For batteries, yes — from 18 February 2027, for EV, industrial above 2 kWh and light means of transport batteries. For everything else it depends on your category: the ESPR sets the framework and a delegated act per category sets the date and the data. Textiles are expected around 2028 to 2029.

Do I need one?

You need one if you place an in-scope product on the EU market — as a brand, an own-label seller or the importer of record. If you manufacture outside the EU for someone else, the obligation normally sits with your EU customer, though they will need data from you.

What products require a Digital Product Passport?

Batteries first, then the ESPR queue: textiles, furniture, electronics, tyres, iron and steel, aluminium, footwear and mattresses, each on its own delegated act. Toys, cosmetics and food are not in ESPR passport scope — they have separate regimes.

When is it mandatory?

The battery date is firm: 18 February 2027, with the delegated act expected 18 August 2026. Every other category depends on an act that has not been adopted yet, so any date you see for them — including ours — is indicative.

Once you know you are in scope

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