Who Needs a Digital Product Passport (DPP) in the EU and How to Prepare

Who Needs a Digital Product Passport (DPP) in the EU and How to Prepare

A Digital Product Passport (DPP) is not mandatory for every product or every company in the EU in 2026. EU DPP requirements are being introduced progressively for specific product groups through applicable EU legislation. For businesses, the key question is whether future obligations apply to their products and what preparation can start now.

Is the DPP already mandatory in the EU?

There is no single date after which every product in the EU must have a Digital Product Passport.

Under the Ecodesign for Sustainable Products Regulation --- ESPR (EU) 2024/1781 --- specific DPP requirements are established for relevant product groups through delegated acts.

The applicable delegated act determines, among other things:

-
what data the DPP must contain; -
which data carrier must be used and where it must be placed; -
whether the passport applies at model, batch or individual-item level; -
who can access particular data; -
who creates and updates passport information.

A product category being included in EU plans therefore does not mean that a DPP is already mandatory for it.

Who will be responsible for the DPP?

Obligations depend on the applicable legislation and the company's role in the supply chain.

For products covered by ESPR requirements, key obligations apply to economic operators placing relevant products on the EU market or putting them into service. Depending on the situation, these can include manufacturers and importers; distributors and dealers also have defined obligations.

What matters is therefore not only company size, but which product is placed on the EU market and in what role the company acts.

When will DPP become mandatory for textiles and clothing?

Textiles and apparel are among the ESPR priority product groups, but final DPP requirements for this category have not yet been adopted.

Adoption of the relevant ESPR Delegated Act is currently planned for Q4 2027. This is an indicative timetable and may change as legislative and technical work progresses.

This means there is currently no final EU-approved list of every field that each fashion brand must include in a DPP.

After ESPR delegated acts are adopted, economic operators are provided with a transition period of at least 18 months. The planned adoption date therefore is not the date on which DPP automatically becomes mandatory for all relevant products.

What has the EU already defined?

Although sector-specific requirements are still being developed, the basic DPP principles are already established in the ESPR.

In particular, the Digital Product Passport must be linked to a persistent unique product identifier through a data carrier. Data must be based on open standards and interoperable formats, and the system must support data portability without dependence on a single provider.

On 20 July 2026, the European Commission also launched the Digital Product Passport Registry and a testing environment for businesses.

The Registry is not a central repository containing the complete product passport. DPP data is stored in a decentralised system, while the Registry is used to register unique identifiers and the registration data and metadata required by legislation.

Is a QR code the DPP?

No.

A QR code can serve as a data carrier through which a user accesses the Digital Product Passport. The specific carrier and its placement are determined by the applicable requirements for the relevant product group.

The DPP itself is digital information linked to the product's unique identifier.

Product → data carrier → unique identifier → Digital Product Passport

How can businesses prepare for DPP?

Businesses do not need to guess requirements that have not yet been adopted or create dozens of fields "just in case".

A more practical approach is to:

1.
Identify your product category and the EU legislation that applies to it. 2.
Define your role in the chain: manufacturer, brand, importer, distributor or another participant. 3.
Map where product data currently sits --- internally, with suppliers, in certificates and other documents. 4.
Identify data gaps and information that is difficult to obtain or verify. 5.
Test the process with a small number of real products rather than restructuring the entire catalogue at once.

The goal today is not to predict future requirements, but to create a data and process foundation that can adapt as sector-specific EU rules are adopted.

In brief

Does every product in the EU need a DPP?\ No. The requirement applies to products for which the relevant legislation establishes a mandatory Digital Product Passport.

Is DPP already mandatory for clothing?\ No. Specific ESPR DPP requirements for textiles and apparel are still being developed.

Are small companies exempt?\ Company size alone does not determine whether a DPP is required. The applicable legislation, product and economic operator role must be considered.

Does the EU store the complete product passport?\ No. The DPP architecture is decentralised. The EU Registry stores required registration data and identifiers, not the complete detailed passport.

Should businesses prepare now?\ Yes. Businesses can already organise product data, the processes for obtaining and verifying it, and test future DPP workflows on a limited number of products without presenting unadopted requirements as current law.

Want to test DPP with your products?

FIORGO is developing Digital Product Passport infrastructure around the current EU regulatory framework and evolving sector-specific requirements.

We are inviting companies to join our pilot project and test DPP workflows with real products.