The Digital Product Passport is coming, that much is clear. But the question of what exactly it should contain is less easy to answer. The ESPR does not simply prescribe a set of broad information requirements that apply to all products, because specific requirements are added per product category via delegated acts. And it is precisely these details that make the difference between “we are working on it” and actual compliance.
In this article, we list the information requirements by topic and category.
The basics: what does the ESPR prescribe?
The ESPR (EU 2024/1781) describes in Article 9 and Annex III the categories of information to be made available through the DPP. Important: this is not a fixed number of data points identical for all products. The regulation describes types of information; the exact details are determined for each product group through delegated acts. The recent JRC report on DPP data requirements (March 2026) describes the methodology by which this is done per product group. However, the structure is already established and includes five main themes:
- Product identifier: a unique product identifier (UPI), a GTIN or equivalent item code, commodity code, facility identifier and a link to any previous DPPs.
- Economic operators: details of the manufacturer, importer (including EORI number) and if necessary an EU responsible representative.
- Compliance information: the EU Declaration of Conformity, technical documentation, digital user manual and safety information.
- Sustainability and circularity: material composition, carbon footprint, expected lifespan and more.
- System requirements and conditional fields. The requirements for the DPP itself.
Sustainability and circularity
The fourth theme is at the heart of the DPP. Here it is about material composition, recycled content, carbon footprint, energy efficiency, hazardous substances (substances of concern), reparability, disassembly instructions, end-of-life treatment, spare parts and expected life. In the organizations we assist, this is the block where most of the gaps are. Not because the information does not exist, but because it is scattered among departments that rarely talk to each other: production has the material specifications, R&D knows how repairable the product is, the sustainability department has the life cycle analysis. But no one has the big picture.
Which of these aspects actually become mandatory depends on the product group. The JRC report describes a four-step methodology for determining which requirements are relevant, proportionate and feasible for each group. The emphasis is on “fit-for-purpose” information: data that has real value for its intended users, from consumers to recyclers.
System requirements and conditional fields
The fifth theme concerns the system requirements of the DPP itself: hosting, availability time, access rights by user group, data integrity, interoperability with the EU DPP registry (to be operational by July 19, 2026) and the use of open, machine-readable data formats.
A number of information requirements are conditional, such as importer data that are only relevant when actual imports are made. The full set of additional requirements per product group will become final once the corresponding delegated act is published.
Additional requirements by product category
On top of the basic requirements come additional information requirements for each category, sometimes quite a lot. The table below gives an overview; then we explain the main groups.
| Category | Key additional information requirements | Delegated act | Expected DPP obligation |
| Batteries | Battery chemistry, carbon footprint/kWh, recycled content, State of Health, due diligence critical raw materials | Established (EU 2023/1542) | Feb. 18, 2027 (final) |
| Construction Products | EPD, DoPC, fire rating, thermal performance, GWP, environmental indicators | Own pathway through CPR (EU 2024/3110), Working Plan 2026-2029 | Phased by product family, expected from ~2028 |
| ICT and electronics | Critical raw materials, energy efficiency, repairability, lifetime, update policy, disassembly | Expected 2026-2027 | Expected ~2028-2029 |
| Textiles and clothing | Fiber composition, microplastics release, PFAS content, fiber origin | Expected late 2026 / early 2027 | Expected ~mid-2028 |
| Steel | COâ‚‚ emissions/ton, recycled content, alloy composition, origin of raw materials | Expected 2026 | Expected ~2027-2028 |
| Aluminum | COâ‚‚ emissions/ton, recycled content, alloy composition, origin of raw materials | Expected 2027-2028 | Expected ~2029 |
| Tires | Rolling resistance, wear indicator, noise rating, wet grip, microplastics | Expected 2027 | Expected ~2028-2029 |
| Furniture | Wood origin and certification, formaldehyde emissions, disassembly capabilities | Expected 2028 | Expected ~2029-2030 |
| Mattresses | Fire retardants, VOC emissions, recyclability foam | Expected 2029 | Expected ~2030-2031 |
The column “Expected DPP obligation” is based on the adoption date of the delegated act plus at least 18 months transition period. Only for batteries is this date legally fixed. For all other categories, it is an estimate based on the ESPR Working Plan 2025-2030.
Batteries: the first category with a mandatory DPP
Batteries have the most extensive set of additional requirements. The EU Battery Regulation (EU 2023/1542) requires, in addition to the basic data, information on battery chemistry and composition, carbon footprint per kWh over the entire life cycle, recycled content percentages for cobalt, lithium, nickel and lead, due diligence on critical raw materials, and State of Health as dynamic data that is updated over the life cycle. The battery passport will become mandatory on Feb. 18, 2027, for EV batteries and industrial batteries above 2 kWh. This is the first product category for which the DPP requirement is legally established.
Construction products: own route through the CPR
Construction products follow a separate path through the revised Construction Products Regulation (EU 2024/3110), applicable since Jan. 8, 2026. The CPR Working Plan 2026-2029 provides an indicative roadmap for each product family. Environmental reporting is being phased in: GWP declaration is mandatory since January 2026, core environmental indicators follow by 2030, and the full set of life cycle indicators by 2032. Organizations that already have EPDs in compliance with EN 15804+A2 have a solid foundation.
The CPR additionally requires a Declaration of Performance and Conformity (DoPC) in structured, machine-readable format. In the event of conflicts between the CPR and the ESPR, the CPR takes precedence.
ICT and electronics
ICT and electronics are expected to have additional requirements focused on material transparency, energy use, repairability and software support. The DPP is likely to require information on critical raw materials (such as rare earths and cobalt), energy efficiency, lifetime, update policies and disassembly. Software plays an explicit role here, as updates help determine longevity.
The delegated act is expected in 2026-2027, with a DPP requirement around 2028-2029. The biggest challenge lies in the complex supply chain: products consist of many components from globally dispersed suppliers, making data collection and verification difficult. Organizations with experience in RoHS, REACH and energy requirements have a foundation, but need to significantly expand their data management.
Textiles and clothing
Textiles and clothing will have additional requirements for fiber composition (type and percentage), washing requirements, microplastics release, PFAS content and fiber origin. The delegated act has not yet been published; adoption is expected in late 2026 or early 2027. The DPP requirement will follow at least 18 months later.
Steel, aluminum and other product groups
Steel and aluminum focus on COâ‚‚ emissions per ton, recycled content percentage, alloy composition and source of raw materials. The data collection overlaps heavily with CBAM obligations, which provides an advantage for organizations already working on them.
Tires build on the existing EU tire label, with rolling resistance, wear indicator, noise rating and wet grip as core data points. Microplastic wear is the newest data point. Furniture will have requirements for wood sourcing and certification (FSC/PEFC), formaldehyde emissions and disassembly capabilities (expected 2028). Mattresses focus on flame retardants, VOC emissions and foam recyclability (expected 2029).
For all categories except batteries, the final requirements will not be established until the relevant delegated act appears.
Batch or individual DPP?
The DPP requires a differentiated approach depending on the nature of the product. For standardized mass products, a batch DPP is usually sufficient, where one data set applies to a series of identical products. This is efficient and appropriate for products with homogeneous composition and limited variation, such as textiles, tires or simple electronics.
More complex products require a unique DPP per individual product. This is especially true for products with variable components, long lifespans and relevant use or maintenance data, such as electric vehicles, industrial machinery and advanced electronics. Here, traceability at the component level and over the entire life cycle is required.
In addition, a hybrid model emerges in practice, combining a batch-level basis with product-specific information. The choice between batch and unique DPP is thus not an administrative decision, but is linked to product design, supply chain complexity and future circularity requirements. More on this in our article on batch vs. individual DPP.
How do you determine which requirements apply to your organization?
It is not necessary to know all possible requirements by heart. Four steps reveal what is relevant.
- Start by determining the product category: which ESPR product group does the product fall into?
- Then start with the broad information requirements of Annex III, which apply to everyone.
- Add category-specific requirements based on the delegated act (if any) or expected requirements.
- Finally, filter by role in the chain: manufacturer, importer or distributor. This determines whether additional information must be entered, such as importer details and the EORI number.
The Empact DPP Tool goes through these steps automatically. Select the product category and role, and the tool instantly filters which requirements apply.
Three common mistakes
Starting late
The list of information requirements is long and the information needed comes from a variety of sources. Collecting and structuring it takes months, not weeks. Organizations that do not act until the delegated act is published have only 18 months left. The broad frameworks from the ESPR are already in place – they can be started today.
Assume that existing data is sufficient
Most organizations already have relevant documents. But a PDF on the shared drive is not the same as structured, machine-readable and interoperable data. The DPP requires information in a format that systems can read and exchange. A technical data sheet is a great starting point, but not an end solution.
Not involving the chain
Material origin, upstream carbon footprint, hazardous substances in purchased components: this information must come from suppliers. Organizations that treat the DPP as an internal project get stuck with the requirements that chain data requires. In this article on DPP and your supply chain, we describe how to effectively engage suppliers.
Find out what requirements apply to your organization
Want to know in five minutes which DPP requirements are relevant to your product? The free Empact DPP Tool filters by product category and role, analyzes existing documents, and instantly shows you what information is already available and where the gaps are.
Need help completing the dataset? Contact us for a no-obligation discussion about the impact on your business.