Digital Product Passport (DPP) — The Complete EU ESPR Guide

The Digital Product Passport (DPP) is a structured digital record that contains information about a product’s materials, origin, repairability, and end-of-life instructions. Under the EU Ecodesign for Sustainable Products Regulation (ESPR) 2024/1781, the European Commission is introducing DPP requirements for specific product categories through delegated acts. When a delegated act applies to your product category, you will need to provide the required product information digitally — typically through a data carrier such as a QR code — linking to a structured DPP data record. AuraDPP makes this straightforward: create your DPP in minutes, get your QR code, stay compliant. Free plan available. Paid plans from €19/month.

What Is a Digital Product Passport?

A Digital Product Passport is a machine-readable, structured data record linked to a specific product or product batch. It is designed to make product information accessible throughout the entire product lifecycle — from manufacturing through retail to end-of-life. The DPP is not a document you print and attach to a product. It is a data record stored in a compliant system and accessed via a data carrier (typically a QR code, RFID tag, or NFC chip) attached to the product or its packaging.

The concept of the DPP was introduced as part of the EU’s Circular Economy Action Plan and is being implemented through the ESPR Regulation (EU) 2024/1781, which entered into force on 18 July 2024. The ESPR replaces the previous Ecodesign Directive 2009/125/EC and significantly expands the scope of ecodesign requirements to include sustainability, repairability, and traceability obligations — of which the DPP is a central component.

ESPR and the DPP: The Legal Framework

The ESPR Regulation (EU) 2024/1781 is the primary legal basis for DPP requirements in the EU. However, the ESPR itself does not directly mandate a DPP for any specific product category. Instead, it establishes the framework and empowers the European Commission to adopt delegated acts for specific product categories. Each delegated act will define the exact DPP data requirements, the data carrier format, and the compliance deadline for that category.

This means that the DPP requirement is not yet in force for all products. It becomes mandatory only for product categories covered by an adopted delegated act. As of 2025, the European Commission has published its Working Plan 2025–2030 identifying priority product categories, and the first delegated acts are expected to apply from 2027 onwards. Manufacturers, importers, and sellers in affected categories should begin preparing now.

The ESPR also establishes the European Product Passport Registry, a central EU infrastructure for storing and accessing DPP data. AuraDPP is designed to be compatible with the registry requirements as they are finalised.

Which Product Categories Are Affected?

The ESPR Working Plan 2025–2030 identifies the following priority product categories for DPP delegated acts. These are the categories for which the European Commission is actively developing DPP requirements:

Product CategoryDPP Expected FromStatus
Batteries & AccumulatorsFebruary 2027Battery Regulation (EU) 2023/1542 — separate regulation
Textiles & ClothingJuly 2027Delegated act in preparation
Electronics & ICT Equipment2028Delegated act in preparation
Furniture2028Delegated act in preparation
Construction Products2028–2030Delegated act in preparation
Steel, Aluminium, Chemicals2029–2030Under assessment

Note: The Battery Passport for industrial and EV batteries is governed by the separate Battery Regulation (EU) 2023/1542, not ESPR. The two systems are related but legally distinct. For DPP-specific information on textiles, see Digital Product Passport for Textiles. For electronics, see Digital Product Passport for Electronics.

Expected Rollout and Delegated Acts

The ESPR Working Plan 2025–2030 sets out the European Commission’s priorities, but the actual DPP requirements for each category will only become legally binding when the corresponding delegated act is adopted and its transition period expires. The timelines above are based on the Commission’s published Working Plan and are subject to change. Sellers and manufacturers should monitor the EUR-Lex database and the European Commission’s ESPR website for updates.

The practical implication is that no product currently requires a DPP under ESPR based on an adopted delegated act, but the preparation window is now. Companies that build DPP infrastructure early will be better positioned when delegated acts enter into force. AuraDPP allows you to create DPPs today and update them as requirements are finalised.

What Data Does a DPP Contain?

The exact data fields required in a DPP will be specified by each delegated act for each product category. However, the ESPR framework and the Commission’s preparatory work indicate that DPPs will typically include some or all of the following data points:

  • Product name, model identifier, GTIN/EAN barcode, batch number
  • Manufacturer name, address, and EU Authorized Representative details
  • Country of origin and manufacturing location
  • Materials composition, including hazardous substances (SVHC under REACH)
  • Carbon footprint and environmental impact data
  • Recycled content percentage
  • Repairability score, spare parts availability, and repair manual links
  • Energy efficiency class and consumption data (where applicable)
  • End-of-life instructions, disassembly information, and recycling codes
  • Certifications, conformity declarations, and test reports
  • Warranty information and product lifespan data

AuraDPP’s DPP creation tool covers all standard ESPR data fields and is updated as delegated acts are finalised.

QR Code and Data Carrier Requirements

Under the ESPR framework, the DPP must be accessible via a data carrier attached to the product, its packaging, or its accompanying documentation. The ESPR specifies that the data carrier must be a machine-readable format such as a QR code, RFID tag, or NFC chip. The QR code (or other carrier) must link to the DPP data record in a way that allows market surveillance authorities, customs officials, and consumers to access the information.

AuraDPP automatically generates a compliant QR code for every DPP you create. The QR code links to a hosted DPP data page that is accessible without requiring the scanner to have a specific app or account. You can download the QR code as a PNG or SVG file and print it on your product label, packaging, or hang tag.

Who Is Responsible for Creating a DPP?

Under the ESPR framework, the primary responsibility for creating and maintaining the DPP rests with the manufacturer. For products manufactured outside the EU and placed on the EU market, the responsibility passes to the importer or the EU Authorised Representative designated by the manufacturer. This means that non-EU sellers who place products on the EU market — whether through Amazon, Shopify, Etsy, or their own website — are responsible for ensuring their products have a valid DPP when the applicable delegated act enters into force for their product category.

Non-EU Seller Implications

For non-EU manufacturers and sellers, the DPP requirement adds a new layer of EU compliance on top of existing obligations such as GPSR (General Product Safety Regulation) and CE marking. The key practical implications are:

  • You are responsible: As the importer or the entity placing the product on the EU market, you are responsible for the DPP when your product category is covered by a delegated act.
  • You need an EU Authorized Representative: The DPP must include the name and address of the EU Authorised Representative. If you do not have an EU-established importer or fulfillment partner, you will need to appoint one. AuraDPP provides both the DPP and the EU AR service. See EU Authorized Representative Service.
  • Prepare early: The delegated acts for textiles (2027) and electronics (2028) are approaching. Setting up your DPP infrastructure now avoids last-minute compliance pressure.

Amazon and Shopify Relevance

Amazon and Shopify are expected to enforce DPP compliance as delegated acts enter into force, similar to how they now enforce GPSR Responsible Person requirements. Sellers who cannot demonstrate a valid DPP for covered product categories risk listing deactivation. AuraDPP integrates with Shopify to automate DPP creation and QR code embedding in product listings. For Amazon-specific DPP guidance, see Digital Product Passport for Amazon Sellers. For Shopify, see Digital Product Passport for Shopify Sellers.

DPP vs GPSR vs EU AR: Key Differences

Non-EU sellers often encounter three overlapping EU compliance requirements. Here is how they differ:

RequirementRegulationWhat It RequiresWho Needs It
Digital Product Passport (DPP)ESPR (EU) 2024/1781Structured digital product data record + QR codeManufacturers/importers of covered product categories (phased from 2027)
GPSR Responsible PersonGPSR (EU) 2023/988EU-established contact point for market surveillanceNon-EU sellers without EU importer/FSP (in force since Dec 2024)
EU Authorized Representative (EU AR)ESPR, PPWR, Cosmetics Reg., WEEEEU-established representative for product regulationsNon-EU manufacturers under applicable product regulations

The DPP is a data record about your product. The GPSR Responsible Person / EU AR is a legal representative for your business in the EU. Both are required for non-EU sellers in covered product categories, but they serve different purposes. AuraDPP provides both services on one platform. See GPSR Responsible Person and EU Authorized Representative Service for details.

How to Create a Digital Product Passport with AuraDPP

  1. Create a free account at auradpp.com — no credit card required, free plan available for up to 10 products.
  2. Add your product — enter the required ESPR data fields (product name, materials, origin, certifications). AuraDPP guides you through each field with plain-language explanations.
  3. Generate your QR code — AuraDPP automatically creates a compliant QR code linking to your hosted DPP data page. Download as PNG or SVG.
  4. Attach the QR code — print it on your product label, packaging, or hang tag. For Shopify sellers, AuraDPP can embed the QR code directly in your product listing.
  5. Keep your DPP updated — update your DPP whenever product information changes (new materials, new supplier, updated certifications).

DPP Pricing

AuraDPP offers the most affordable DPP solution for non-EU sellers and SMEs:

PlanPriceProductsKey Features
Free€0/monthUp to 10Basic DPP fields, QR code, hosted DPP page
Starter€19/monthUp to 25All ESPR fields, custom branding, CSV export
Growth€49/monthUp to 250API access, Shopify integration, bulk import
Scale€129/monthUnlimitedWhite-label, dedicated account manager, SLA

All plans are billed monthly in EUR. No long-term contract. Cancel anytime. See full pricing details →

Frequently Asked Questions

Is the Digital Product Passport mandatory right now?
No product category currently requires a DPP under an adopted ESPR delegated act. The DPP becomes mandatory only for product categories covered by an adopted delegated act. The first delegated acts are expected to apply from 2027 (textiles, batteries). Manufacturers and sellers in these categories should begin preparing now.
What is the difference between a DPP and a battery passport?
The battery passport is governed by the Battery Regulation (EU) 2023/1542, not ESPR. While both use a similar QR code and data record concept, they are separate legal requirements with different data fields, timelines, and compliance systems. AuraDPP covers ESPR-based DPPs; battery passports require a separate compliance process.
Does the DPP replace the CE marking?
No. The DPP is a data record, not a conformity marking. CE marking (where required) remains mandatory and can be referenced inside the DPP. Both requirements are separate and must be met independently.
Do I need a DPP if I sell on Amazon or Shopify?
When the applicable delegated act enters into force for your product category, yes. Amazon and Shopify are expected to enforce DPP compliance as they now enforce GPSR requirements. AuraDPP integrates with Shopify and provides Amazon-compatible DPP documentation. See Shopify DPP and Amazon DPP.
What happens if I don’t have a DPP when required?
Products without a valid DPP can be blocked at EU customs, removed from marketplace listings (Amazon, Etsy, Shopify), and result in fines under applicable EU member state law. The exact penalty amounts will be defined by each member state’s enforcement legislation.
Can I create a DPP for free?
Yes. AuraDPP offers a free plan for up to 10 products. You can create your first Digital Product Passport at no cost and upgrade when you need more products or additional features.
Do I also need an EU Authorized Representative for DPP compliance?
The DPP must include the name and address of the EU Authorised Representative (or EU-established importer). If you do not have an EU-established importer or fulfillment partner, you will need to appoint an EU AR. AuraDPP provides EU AR services from €99/month alongside the DPP service. See EU Authorized Representative Service.

Start your Digital Product Passport today at auradpp.comGoran Matejic, LIMASE s.r.o. (AuraDPP), Bratislava, Slovakia