ESPR Digital Product Passport requirements: a checklist for businesses

The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, makes Digital Product Passports (DPPs) a condition of selling many products in the EU. Each passport must link a product to a unique identifier and carry the sustainability, composition and compliance data the EU sets for that product group. Requirements arrive product group by product group through delegated acts, so the businesses that start organizing their product and supplier data now will have the shortest path to compliance.

This checklist from 3E explains what ESPR requires from a DPP, which dates to track and the steps to take today.

What ESPR requires from a Digital Product Passport

ESPR sets the framework for every DPP. The detailed data requirements for each product group come later, in product-specific delegated acts. Across all product groups, a DPP must:

• Be linked to a persistent unique product identifier and reached through a data carrier on the product, its packaging or its documentation, such as a QR code.
• Contain the information set out in the delegated act for that product group. This can include materials and substances of concern, recycled content, durability, repairability, carbon or environmental footprint, and compliance documentation.
• Be built on open, interoperable standards so data can move between systems across the value chain. European standards for identifiers, data carriers and data storage (EN 18219, EN 18220 and EN 18221) were published in May 2026.
• Be stored by the economic operator responsible for creating it, or by a service provider acting for them.
• Give the right people the right access. Customers, market surveillance authorities and other listed actors must be able to access the information they are entitled to, free of charge. Commercially sensitive data can be restricted.
• Be registered. The unique identifiers are recorded in the EU digital product passport registry.

A DPP is a live record that has to stay accurate as products, suppliers and regulations change.

Key ESPR and DPP dates

The battery passport is set by the EU Battery Regulation rather than ESPR, but it is the first mandatory passport most companies will meet, and it shows what ESPR passports will ask for. See EU battery passport requirements for details.

Who is responsible for the DPP

The company that places a product on the EU market creates and registers its DPP. For the EU battery passport, that means the company that places a battery on the EU market. A supplier outside the EU doesn’t submit a passport; it gives the importer the data to do it. Distributors must check that a passport is in place before making a product available.

Most of the data a DPP needs sits with suppliers, not with the company that publishes the passport. That makes DPP readiness a supply chain data problem first.

ESPR Digital Product Passport requirements checklist

Use these 10 steps to prepare before the delegated act for your product group is final.

1. Map your products to ESPR priority groups. List which of your products fall into the working plan’s priority groups and which EU markets they are sold in. Start with the groups closest to a delegated act.
2. Track the delegated acts for your product groups. Follow the Commission’s drafts and consultations so you know which data points, formats and deadlines will apply.
3. Assign ownership. Name who owns DPP readiness across compliance, sustainability, product, IT and procurement. DPPs fail when everyone holds part of the data and no one owns the passport.
4. Build an inventory of the data a passport will need. Typical fields include materials and composition, substances of concern, recycled content, durability and repairability information, footprint data, and declarations of conformity.
5. Find out which data you already have. Check what exists in PLM, ERP and compliance systems, and how current it is. Flag what is missing, outdated or only in PDFs and spreadsheets.
6. Identify which suppliers hold the missing data. For each gap, trace which supplier, and which tier, can provide it.
7. Collect supplier data in a structured, validated way. Use standardized surveys with built-in checks rather than one-off email requests, so responses are complete and usable the first time. A structured supply chain data collection process keeps this repeatable as you add products.
8. Assign unique identifiers and plan your data carrier. Decide how each product, batch or item will be identified and how the QR code or other carrier will point to the passport.
9. Set access and permission rules. Decide which information is public and which is restricted to authorities, customers or recyclers, and protect confidential business information.
10. Plan how passports will stay current. Set a process to update passports when a product, a supplier or a regulation changes, and to keep records available for the period the delegated act requires.

Common mistakes to avoid

• Treating the DPP as a QR code project. The carrier is the easy part. The hard part is collecting complete, verified data from suppliers.
• Waiting for the final delegated act. Supplier data collection takes months. Companies that start now can adjust to the final requirements instead of starting from zero.
• Building a separate data effort for every regulation. Much of the same supplier data supports ESPR, the Battery Regulation, the Packaging and Packaging Waste Regulation (PPWR), REACH and sustainability reporting. Collect it once and reuse it.

How 3E Exchange helps you prepare

3E Exchange helps compliance, sustainability and supply chain teams collect, validate and act on supplier and product compliance data at scale. For Digital Product Passports, 3E Exchange helps you:

• Collect supplier data through structured supplier surveys with validation and plausibility checks built in, backed by a network of more than 200,000 suppliers.
• Check data against regulatory intelligence from more than 200 regulatory lists maintained by 3E experts, so you know what is missing and what matters.
• Publish 3E Digital Product Passports with public, restricted or unlisted visibility, and share them with customers through permissioned access.
• Keep passports current as approved supplier responses update the underlying product data.
• Reuse the same supplier data across compliance, sustainability and ESG obligations instead of asking suppliers again.

You can also search more than 1 million existing passports in the free 3E Digital Product Passport library. For a step-by-step look at getting your data ready, read Digital Product Passports: achieving data readiness for DPPs and beyond. To build the internal case for investing now, see The ROI of Digital Product Passports.