With the publication of the European Commission's first official FAQ document on the Digital Product Passport (DPP) on 20 May 2026, practical guidance on implementing the requirements of the EU Ecodesign Regulation (ESPR) is now available for the first time. The document is intended to serve as a continuously updated guide and addresses, in particular, questions relating to implementation, market surveillance, and compliance. The Digital Product Passport is a key instrument of the ESPR and is designed to make product-related information digitally accessible in the future. However, whether a product actually requires a DPP is not determined by the inclusion of a product group in the ESPR work plan but by the relevant product-specific legal act. There is therefore no general obligation for all products to have a DPP.
Implementation from July 2026 onwards
Several important deadlines are approaching in the coming months for producers, importers, and other economic operators. The Implementing Act establishing the central DPP register, which will regulate the operational functioning of the register, is expected to be adopted by 19 July 2026. The publication of the first harmonised standards has also been announced for mid-2026. These standards will include, among other things, specifications for identifiers, data carriers, data formats, interfaces, security, and interoperability. The first product-specific legal acts are expected to be adopted gradually between 2026 and 2030. By contrast, automated checks of the Digital Product Passport by customs authorities at the EU's external borders are not expected to be fully implemented until 2030.
What obligations will come up?
Several obligations for businesses are becoming clearer. Responsibility for the accuracy and completeness of DPP data generally rests with the respective registering economic operator. At present, there is no general requirement for external certification or third-party verification of the information contained in the DPP. However, companies must maintain a backup copy of their Digital Product Passport with an independent DPP service provider, even if they host the data themselves. In addition, voluntary information, such as sector-specific labels or additional sustainability data, may be included in the Digital Product Passport, provided that it is clearly identified as voluntary and does not compromise the interoperability of the system. The Commission also clarifies that the data carrier to be used in the future has not yet been determined. Whether a QR code, NFC, RFID, or another technology will be used will only be decided through the ongoing standardisation process and the relevant product-specific legislation. Similarly, the public DPP web portal will be launched at a later stage than the central register.
Non-compliance may jeopardise market access
In the future, manufacturers and importers must ensure that all required product data remains complete, accurate, up to date, and accessible throughout the entire product life cycle. Retailers, particularly those operating online, will only be permitted to offer products for sale if a valid Digital Product Passport is available. Compliance with these requirements will be monitored by market surveillance authorities. Breaches may result in sales bans, product recalls, fines, and significant reputational damage. Companies may also face competitive disadvantages, as well as potential restrictions in public procurement procedures or access to financing. Furthermore, consumers may be entitled to claim compensation from producers for non-compliant products. Under certain circumstances, liability may also extend to importers, authorised representatives, or fulfilment service providers. In addition, Member States are required to establish effective, proportionate, and dissuasive sanctions. Compliance will be enforced by national market surveillance authorities and, in the future, also by customs authorities.
Those who start too late risk high follow-on costs
Companies should use the coming months to prepare their internal processes for the introduction of the Digital Product Passport. Particular attention should be paid to the forthcoming decisions on the central DPP register, the publication of the technical standards, and the first product-specific legal acts, as these will determine which product groups will actually be subject to the DPP requirement and what specific obligations will apply.
If you have any questions about the Digital Product Passport, the trade-e-bility advisory team will be happy to assist you.
