The EU Regulatory Framework for Digital Product Passports

With the entry into force of the Ecodesign for Sustainable Products Regulation (ESPR) on July 18, 2024, the European Union has taken a major step forward in its sustainability policy. Under this Regulation (EU) 2024/1781, the Digital Product Passport (DPP) has been made mandatory. The DPP thus serves as the primary instrument to enforce transparency regarding product sustainability across the EU internal market.

Key regulations

ESPR — Ecodesign for Sustainable Products Regulation (EU) 2024/1781

This overarching regulatory framework establishes the foundation for the Digital Product Passport (DPP). The regulation defines the general data requirements and obligations. Furthermore, the ESPR introduces the mechanism for delegated acts, which the European Commission will use to issue product-specific rules in the coming years. The regulation applies to all products placed on the EU market, regardless of whether they were manufactured inside or outside the EU. These product-specific rules will be published progressively through a rolling schedule running until 2030.

Battery Regulation — Regulation (EU) 2023/1542

This marks the first concrete DPP mandate for a specific product category. As of February 2027, battery passports will be mandatory for industrial batteries with a capacity exceeding 2 kWh and for all EV (Electric Vehicle) batteries. The passport must include life-cycle carbon footprint declarations, targets for recycled content of critical minerals, state-of-health metrics, and supply chain due diligence documentation.

AGEC — French Anti-Waste and Circular Economy Law

Unlike the upcoming EU legislation, this French national regulation is already in force. The AGEC law requires brands selling textiles in the French market to disclose comprehensive environmental and social information. WebIQ includes standard AGEC-compliant templates, enabling clients in the fashion and apparel sector to meet these requirements immediately.

Toy Safety Regulation (EU) 2025/2509

Alongside the Battery Regulation, this is the first sector-specific legislation to explicitly introduce DPP obligations. This signals a clear trend: the European Union is actively expanding the overarching DPP mandate from the ESPR into product-specific legislation.

DPP Data Requirements

What a Compliant DPP Must Contain

Requirements vary by product category and are specified in delegated acts. Based on the current ESPR text and early implementing acts, a compliant DPP is expected to include:

  • Unique Product Identifier: A dedicated identification code that fully complies with the ISO/IEC 15459 standard.
  • Material composition: A detailed percentage breakdown of all components, including the explicit disclosure of any substances of concern.
  • Environmental performance: Verified metrics regarding environmental impact, such as carbon footprint, energy consumption, and water usage.
  • Recycled content percentages: Clear documentation of the exact proportion of recycled materials utilized in the product.
  • Manufacturing location and date: Transparent data specifying the exact geographical facility and the date of production.
  • Supply chain events: A comprehensive log of traceability events, detailing the country, process type, and transportation method.
  • Compliance documentation: Official regulatory evidence, including declarations of conformity and relevant certifications.
  • End-of-life information: Actionable data and guidelines regarding product disassembly, repairability, and recycling processes.
  • Manufacturer and importer identity: Complete and verifiable organizational details for both the manufacturer and the importing entity.
  • Machine-readable format: Data structured in standardized formats (such as JSON or XML) required for seamless submission to the central EU registry.

WebIQ compliance approach

Compliance Without Complexity

WebIQ continuously monitors ESPR delegated acts as they are published by the European Commission. Once the requirements for a specific product category are finalized, the relevant data templates and export formats are automatically updated within the platform. These updates roll out seamlessly to customer dashboards, completely eliminating the need for manual configuration.

Our dedicated compliance team closely tracks key regulatory milestones, focusing on:

  • The ESPR Work Plan 2025–2030: The official timeline and release schedule for upcoming delegated acts.
  • Implementing Acts for the Battery Regulation: The specific regulatory mandates governing battery passports.
  • Harmonized DPP Standards by CEN/CENELEC: The suite of eight technical standards expected to be delivered through 2026.
  • Technical Specifications for the Central EU Registry: The data architecture required for mandatory EU submissions, ahead of its launch in July 2026.
  • National Transposition: Country-specific frameworks and member state requirements, such as France's AGEC and Italy's SNET.

For businesses navigating complex regulatory landscapes, our specialized team provides tailored compliance advisory. We identify exactly which requirements and timelines impact your specific product portfolio, ensuring your resources are deployed where they deliver the highest value.