The European Union is driving the shift towards a circular economy through rapidly increased regulation for digital product passports (DPPs), fundamentally reshaping how products are managed across their lifecycle. More than just a concept, the DPP is rapidly becoming a mandatory requirement across a growing array of sectors, signalling a profound change for businesses operating within, or looking to enter, the EU market. 

At the forefront of compliance, DPPs are required by regulations such as the Ecodesign for Sustainable Products Regulation (ESPR). But other than the ESPR, numerous sector-specific EU regulations also require a product passport in a digital format. This article provides a comprehensive overview of the key EU regulations that mandate the implementation of digital product passports and what data needs to be included in a DPP. 

This article details the requirements and timelines for the following regulations:

• Ecodesign for Sustainable Product Regulation (ESPR)
• Battery Regulation
• Critical Raw Materials Act (CRMA)
• Detergents Regulation
• Toys Regulation
• End-of-Life Vehicle (ELV) Regulation Revision
• Construction Product Regulation (CPR)

Understanding how these separate pieces are reshaping industrial and commercial practices is important for businesses to stay compliant, seize emerging market opportunities, and contribute to a more sustainable future.

Ecodesign for Sustainable Products Regulation (ESPR)

The Ecodesign for Sustainable Products Regulation (ESPR), part of the 2020 Circular Economy Action Plan and the European Green Deal, introduces the digital product passport (DPP) to transform how products are tracked and managed across their lifecycle. Its primary goal is to enable circular business models by providing detailed, reliable product lifecycle data. 

The DPP also increases transparency across complex global supply chains, giving manufacturers, recyclers, market surveillance authorities, economic operators, and consumers easy access to critical sustainability and product information. Interoperability is essential: the DPP must work with other EU digital systems, including customs databases and platforms like the European Chemicals Agency (ECHA). Ultimately, it empowers consumers and regulators to make informed, environmentally responsible decisions.

On 16 April 2025, the Commission rolled out the first set of products under the ESPR along with two new legal acts establishing horizontal rules. The initial focus covers final products such as textiles, furniture, tyres, and mattresses, as well as intermediate materials like aluminium, iron, and steel. These horizontal requirements standardise sustainability criteria and provide businesses with a clear framework to innovate, compete, and lead in the EU’s rapidly evolving circular economy.

What are the DPP requirements for ESPR?

A distinctive aspect of the ESPR is its emphasis on life-cycle data and product-level granularity, which goes beyond typical traceability measures. This level of detail enables a deeper understanding of a product’s environmental impact throughout its entire life. To comply with the ESPR, the DPP must contain comprehensive data across the following categories:

• Product identification
• Performance information
• Substances of concern 
• Instructions for use, maintenance, and end-of-life treatment
• Sustainability information on recycled and renewable material content, and details on microplastic release
• Modularity and repairability
• Recyclability and circularity

Companies are also required to justify any decision to withhold information they mark as confidential, ensuring a balance between transparency and commercial protection.

Ecodesign for Sustainable Products Regulation (ESPR) timeline and milestones

The ESPR lays the groundwork for the development of future sector-specific digital product passports (DPPs). Its broad scope ensures consistency across various product categories while allowing for tailored requirements through delegated acts. The regulation will be rolled out in stages, with clear timelines for both product-specific and horizontal requirements. Each act will specify the necessary data fields, reporting formats, and methodologies for every product group, ensuring that regulatory expectations match real-world industry practices.

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From 2026, ESPR begins with iron and steel, focusing on emissions, energy efficiency, and resilience. In 2027, aluminium, textiles, and tyres join, with measures for secondary materials, longer product lifespans, and improved recyclability. Repairability rules for electronics are also introduced. By 2028, furniture regulations target resource use and environmental impact, and in 2029, mattresses and electronics face rules on durability, recyclability, and recycled content.

Battery Regulation

The European Union is driving a profound modernisation of its legislative framework for batteries in order to establish a highly resource-efficient and competitive economy. Central to this transformation is the EU Battery Regulation, which introduces a specialised form of the digital product passport (DPP) — the battery passport. 

A battery passport is a comprehensive digital document designed to store critical data throughout a battery's entire lifecycle. While sharing core characteristics with the general DPP under the ESPR, battery passports are meticulously tailored to meet the unique requirements of the battery industry and its complex value chain. 

Recognising the complexity of industry-wide compliance, the EU has opted for a phased implementation approach. This gives businesses space to update their internal systems, workflows, and reporting processes to develop critical digital tools that will underpin compliance. 

In parallel, it supports the creation of a robust third-party verification infrastructure to ensure the reliability of shared data. This phased approach also enables stakeholders to gather, structure, and validate the complex datasets required for full regulatory alignment — a strategy already being put into practice by battery consortiums piloting digital product passports.

What are the DPP requirements for batteries?

The battery passport must include key information to ensure traceability and performance transparency, such as:

• A unique product identifier for access to the battery passport, provided via a QR code printed or engraved on the physical battery
• Basic specifications, including type and model
• Lifecycle data on performance and durability, updated by parties handling repair or repurposing
• The carbon footprint specific to the manufacturing site and battery batch
• Technical documentation on electrochemical performance and durability, including methods used to collect the data, ensuring the battery meets minimum operational and efficiency standards throughout its lifespan

Battery Regulation timeline and milestones

The EU Batteries Regulation (EU 2023/1542) came into force on 17 August 2023, introducing a phased implementation of its provisions, with several measures starting on February 18, 2024. The regulation fully replaced and repealed the previous Battery Directive (2006/66/EC) on 18 August 18 2025, and Member States must also lay down rules on penalties. 

In 2026, two key milestones follow. By 26 July 2026, the deadline for publishing Guidelines has been extended by one year, and by 18 August 2026, the Commission must adopt an implementing act.

From 18 February 2027, a unique Battery Passport, retrievable via a QR code, will be mandatory for all Electric Vehicle (EV) and industrial batteries placed on the EU market with a capacity over 2kWh, regardless of their origin. This requirement extends to a wide range of battery types, including:

• Electric Vehicles (EVs) over 25 kg
• Light Means of Transport (LMT) under 25 kg
• Batteries intended for industrial uses (>5 kg)
• Portable batteries (≤5 kg)
• Starting, Lighting, and Ignition (SLI) automotive batteries.

Additionally, from 18 August 2027, the Omnibus IV due diligence obligations for battery supply chains are postponed by two years. The European Commission must review and report on the effectiveness of the Regulation by 30 June 2031.

Critical Raw Materials Act (CRMA)

Under the Critical Raw Materials Act, manufacturers placing specific products on the EU market must ensure these products carry a permanent magnet label and an associated digital product passport (DPP). This obligation applies to a wide range of goods, which include:

• Motor vehicles
• Light means of transport (e-bikes, scooters)
• Magnetic resonance imaging (MRI) devices
• Wind energy generators
• Electric motors (standalone or integrated)
• Cooling generators and heat pumps
• Dishwashers, washing machines, tumble driers
• Vacuum cleaners and microwaves
• Industrial robots

What are the DPP requirements for critical raw materials?

The digital product passport (DPP) under the CRMA must contain a unique product identifier, as well as the following information:

• Products must include a clearly visible, indelible label that indicates whether the product includes one or more permanent magnets, and if so, which type of magnet is used:
  • Neodymium-iron-boron
  • Samarium-cobalt
  • Aluminium-nickel-cobalt
  • Ferrite
• Name, registered trade name or trademark, and contact details (postal and email) of the responsible party

• For each permanent magnet in the product:
  
  • Weight
  • Location within the product
  • Chemical composition
  • Type of coatings, adhesives, or additives used
  • Guidance for safe access and removal, including required tools, steps, and technologies

The DPP must be complete, accurate, and continuously updated throughout its lifecycle, and maintained for at least the typical lifetime of the product plus an additional ten years. Even in the event of insolvency or if the responsible party ceases operations within the EU, the DPP must remain accessible. Moreover, it must be compatible with the requirements outlined in the Ecodesign for Sustainable Products Regulation (ESPR) or other relevant EU legislation.

Critical Raw Materials Act (CRMA) timeline and milestones

The CRMA entered into force in June 2024. The rollout of the CRMA’s traceability and passport obligations is structured in phased stages, with both legislative and technical preparation underway.

Figure 4: The timeline for the Critical Raw Materials Act (CRMA).

From November 2025, the Commission will adopt the format for permanent magnet labelling.  From 24 May 2027, or two years from the entry into force of the relevant delegated act, products containing permanent magnets over 0.2 kg must disclose the share of critical raw materials recovered from post-consumer waste. And finally, from 24 May 2029, recyclability requirements for permanent magnets will apply to MRI devices, motor vehicles, and L-category light transport vehicles.

Detergents Regulation

The EU’s significant revision of its Detergents Regulation marks a decisive step toward modernising environmental and consumer protection standards. This update forms part of the broader REFIT initiative, which aims to streamline EU legislation while enhancing its effectiveness. 

Detergents commonly contain surfactants, active ingredients essential to their cleaning function. However, the environmental release of these substances presents considerable risks to water quality and ecosystems. The revised regulation therefore establishes harmonised EU-wide rules governing the sale and use of detergents and surfactants. Only products that meet strict biodegradability criteria will be permitted on the market. 

Digital product passports (DPPs) will become mandatory for placing detergent products on the EU market. The DPP will serve as the definitive tool for verifying the ultimate biodegradability of surfactants, whether sold as individual substances or incorporated within detergent formulations. This approach safeguards public health and the environment while fostering a level playing field within the EU’s internal market. 

According to the regulation, manufacturers bear the primary accountability. By creating the DPP, manufacturers formally declare that the detergent complies with all applicable EU regulations, assuming full responsibility for its conformity.

What are the DPP requirements for detergents and surfactants?

The digital product passports (DPP) for detergents should provide granular, accessible data, ensuring transparency across the product lifecycle. Key requirements include:

• A physical data carrier and product identification
• Ingredient transparency
• Biodegradability compliance
• Environmental impact data
• Usage instructions
• End-of-life information
• Data storage, machine-readable format
• Interoperable, searchable, accessible
• Registry and customs integration

Before market entry, detergents must be registered with a central EU registry, linking the unique product identifier to the product's compliance data. Furthermore, customs authorities will verify the unique product identifier during importation to ensure full compliance with the regulation.

Detergents Regulation timeline and milestones

The journey towards this modernised Detergents Regulation has unfolded through several key legislative milestones. The revision of the EU Detergents Regulation began with the publication of the proposal in April 2023, with a provisional agreement reached in June 2025. Looking ahead, from 42 months after the date of entry into force in 2027, all detergents and surfactants placed on the EU market will be required to carry a digital product passport (DPP).

Toys Regulation

The European Union is updating its toy safety regulations to reinforce consumer protection and ensure that all toys sold within its market — whether purchased online, in physical stores, or imported — comply with the highest safety standards. This ambitious regulation has reached a provisional political agreement. Its enactment into law is imminent, pending formal approval by both the European Parliament and the Council.

What are the DPP requirements for toys?

According to this regulation, the digital product passport (DPP) will become mandatory for all toys marketed in the EU. The information mandated for inclusion in a toy's DPP will cover the following:

• Product identifiers and traceability
• Manufacturer and importer contact details (website, or email address)
• Adherence to applicable EU legislation and harmonised standards
• Certification details
• CE Marking
• Presence of allergenic fragrances or other substances of concern
• Safety warnings and usage instructions
• Colour image of the toy

The regulation also aligns with the General Product Safety Regulation (EU) 2023/988, ensuring enhanced communication channels and easier contact for consumers and authorities alike.

Toys Regulation timeline and milestones

The journey towards a safer and more transparent toy market in the EU has steadily progressed since mid-2023, with key milestones defining its development. The proposal was published in July 2023, followed by the European Parliament adopting its position in March 2024. Trilogue negotiations began in November 2024, with a provisional agreement expected in 2025. From 2029/2030 (54 months after publication), toys placed on the market must carry a digital product passport (DPP).

While the regulation has already been finalised, it is still awaiting a formal agreement by both the Parliament and the Council. Once that has happened, it will be published in the Official Journal of the European Union. Following its publication, the Toy Safety Regulation will become legally binding across all EU Member States after a standard 20-day waiting period. Crucially, unlike a directive, this regulation does not necessitate national transposition, ensuring quicker and more uniform implementation throughout the EU.

After the regulation enters into force, a transition period of 30 months will be provided. During this time, toy manufacturers, importers, and regulatory authorities must align their operations with the new requirements. This includes integrating digital product passports, updating chemical testing procedures, and ensuring that all toys meet the revised safety criteria.

End-of-Life Vehicle (ELV) Directive revision  

The EU’s End-of-Life Vehicles (ELV) Directive has long aimed to improve vehicle recycling and promote the use of recycled materials in new vehicles. As part of its broader effort to enhance circularity in the automotive sector, the European Commission has proposed a new regulation to replace the existing ELV Directive. This proposal, a Regulation of the European Parliament and of the Council on circularity requirements for vehicle design and on management of end-of-life vehicles, introduces several transformative measures, including the mandatory introduction of a digital product passport (DPP) for vehicles.

What are the DPP requirements for end-of-life vehicles?

For end-of-life vehicles, the DPP will provide detailed information on vehicle components, materials, and their recyclability. This data will be essential for recyclers, enabling more efficient dismantling and maximising resource recovery. In turn, it will support the integration of secondary raw materials into vehicle manufacturing — an important step toward a circular economy. For instance, the EU is proposing that at least 25% of plastics used in new vehicles must come from recycled sources.

A central element of the new regulatory framework for the automotive industry is the Environmental Vehicle Passport (EVP), a digital record that consolidates key environmental performance metrics for each vehicle. The EVP must include information such as:

• Tailpipe CO₂ emissions and energy consumption: Measured under standardised laboratory and real-world driving conditions.
• Electric range and energy efficiency: Especially for Battery Electric Vehicles (BEVs) and Plug-in Hybrid Electric Vehicles (PHEVs).
• Battery health and degradation metrics: To monitor long-term environmental performance and resource efficiency.
• Lifecycle environmental impacts: Including upstream emissions, material composition, and recyclability where available.

Under the proposed regulation, manufacturers will be required to issue an EVP for every vehicle at the time of registration. This data must be made accessible to vehicle users, either through in-vehicle electronic systems or via scannable methods like QR codes, and must be transferable from onboard to external systems. 

The EVP will help consumers make informed, sustainable mobility choices and will also support regulators and market surveillance bodies in verifying compliance. It is also expected to contribute to efforts around sustainable public procurement, carbon footprint labelling, and the second-hand vehicle market. 

End-of-Life Vehicle Regulation timeline and milestones 

The proposal was published in July 2023 and is currently under negotiation. From 72 months after entry into force, all vehicles placed on the market must carry an Environmental Vehicle Passport (EVP). 

The EVP is being operationalised through delegated and implementing acts stemming from Regulation (EU) 2018/858, which governs vehicle type approval across the EU. The EVP rollout is aligned with the revision of the Type-Approval Framework and the broader push toward digitalisation and decarbonisation in the transport sector.

While the legal foundation is in place, technical specifications — covering data structure, transmission protocols, and interoperability standards — are currently under development. Finalisation of these implementing acts is expected by the end of 2025, in preparation for phased mandatory compliance. 

Construction Product Regulation (CPR)

The European Union is overhauling its framework for regulating construction materials with the Construction Products Regulation (EU) 2024/3110, replacing the earlier Regulation (EU) 305/2011. This regulation aims to ensure the free movement of compliant construction products across the EU while embedding climate, environmental, and safety considerations into product design and documentation.

What are the DPP requirements for construction products? 

Central to the updated framework is the mandatory introduction of the digital product passport (DPP) or material passports for construction products placed on the EU market. Designed to offer robust traceability and comprehensive product data across the product’s lifecycle, the DPP will contain the following essential information:

• Unique product identification: Using globally standardised identifiers (e.g., GS1 GTIN), ensuring consistency and traceability across the supply chain.
• Declaration of Performance (DoP) and Conformity (DoC): Demonstrating compliance with applicable EU harmonised technical specifications and essential characteristics.
• Technical and safety information: Covering installation, use, and handling instructions, as well as safety precautions.
• Environmental and lifecycle data: Including recyclability, resource efficiency, and carbon footprint information aligned with EU circular economy objectives.
• Data carrier requirements: The DPP must be accessible via a physical or digital data carrier (e.g., QR code, RFID chip, barcode, or URL), affixed visibly to the product or packaging and compliant with ISO 15459 standards.
• Electronic availability and access: The DPP must be made available electronically and free of charge to all stakeholders, with tiered access to protect commercially sensitive data.

Additionally, manufacturers and importers will be required to maintain the DPP for at least 10 years following a product’s placement on the market. If a company ceases operation, the data must be transferred to a central registry maintained by the European Commission. All information must be regularly verified, with updates allowed only to correct errors and preserve version history.

Construction Product Regulation (CPR) timeline and milestones

The journey toward smarter and more sustainable construction product regulation has followed a structured rollout, with notable milestones. The regulation was formally adopted on 18 December 2024 and entered into force on 7 January 2025 across all EU Member States. Full implementation of the supporting digital infrastructure, including the DPP registry, APIs, and data-sharing systems, is expected by 2026/2027, with DPPs becoming mandatory 18 months after the system is established.

Beyond compliance: Unlocking the business value of digital product passports

Digital product passports (DPPs) and traceability systems aren’t just about meeting regulatory requirements — they’re a strategic tool to drive value across the business. Companies relying on fragmented or superficial data risk falling behind, while those implementing integrated, interoperable traceability infrastructure gain actionable insights across their supply chains, improve operational efficiency, and strengthen both consumer and investor trust.

As Serena Gariboldi, Public Institutions Affairs Officer at Circularise, pointed out, “There’s growing pressure from financial stakeholders. This isn’t just about regulators anymore; it’s about staying investable.” Without robust traceability, companies risk losing access not only to capital but also to key markets — a setback few can afford in today’s economy.

Circularise has already demonstrated how DPPs can be applied practically in the Circular Foam project, simulating the value chain for multiple products: an Electrolux refrigerator door, a Unilin insulation board, and a Kingspan metal panel. The team created both stakeholder-specific and public-facing DPPs, which allowed companies to securely share critical data while protecting sensitive information. The project illustrates how DPPs can establish effective traceability, improve data reliability, and enable seamless collaboration across supply chains. Explore the Circular Foam case study here.

Studies already indicate that DPPs can double a product’s lifetime value, with businesses capturing around 35% of that value.⁸ Traceability features embedded in DPPs reduce counterfeit risk, boost confidence in resale purchases, and enable engagement with both new and secondary markets.

Beyond increasing market value, the operational and strategic benefits of digital product passports (DPPs) are clear. By providing verified proof of material origins and production practices, DPPs substantiate environmental claims and help companies avoid greenwashing penalties. Centralised regulatory documentation makes for easier audits and automated data sharing, also enabling optimised procurement, better quality management, and more sustainable design decisions across complex supply chains.

Digital product passports can unlock new revenue opportunities by enabling r-strategy practices such as repair, resale, or material recovery. They help products retain value throughout their lifecycle, transforming “waste” into ongoing assets. Companies that proactively adopt DPPs can differentiate themselves in the market, unlock new business models, and position themselves as leaders in sustainability, digital innovation, and supply chain transparency.

Conclusion

The European Union’s push towards a digitally empowered circular economy is no longer a distant policy ambition but a concrete, fast-evolving regulatory reality. The digital product passport (DPP) is rapidly emerging as a cornerstone of EU product governance, unifying disparate streams of environmental, safety, and compliance data into a harmonised digital infrastructure. They’re not just a compliance checkbox — they’re a growth engine, a trust builder, and a pathway to resilient circular supply chains.

As value chains are being nudged towards greater accountability through traceability and verifiable claims, companies must also anticipate future additions to the DPP framework as the European Commission continues to expand its sustainability toolbox. While the compliance burden may appear significant, especially for industries with legacy systems and complex supply chains, early movers stand to benefit enormously. 

Companies that successfully implement robust DPP systems will gain competitive advantages through operational transparency, enhanced brand trust, improved supply chain efficiency, as well as access to green public procurement and sustainability incentives. 

The integration of DPPs represents a transformative opportunity to future-proof operations, enhance product value, and contribute meaningfully to a regenerative economic system. By integrating commercial strategy with regulatory foresight and environmental responsibility, digital product passports are set to become a critical driver of sustainable and successful business in the European market for years ahead.