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# Who Needs a Digital Product Passport?

> Who is affected by Digital Product Passports: the six responsibility groups across the value chain, which products are in scope, and who should prepare now.

## Executive Summary

The [Digital Product Passport](/docs/knowledge-base/glossary/digital-product-passport) is often
described as a manufacturer obligation. That description is too narrow to plan against. The legal
duty attaches to the [economic operator](/docs/knowledge-base/glossary/economic-operator) that
places a product on the European Union market, but the data that fills the passport originates
across the entire value chain, and the passport is read by parties who never had a commercial
relationship with the operator that created it.

This article answers the question most organisations ask first: does this affect us, and if so,
what are we accountable for? It introduces the Digital Product Passport Responsibility Model, which
divides the value chain into six groups and states what each one contributes. It then covers which
products are expected to be in scope, which organisations should start work now, who is indirectly
affected, what the position is for smaller businesses, and which misconceptions cause the most
wasted effort.

It assumes you already know what a passport is. If you do not, read
[What is a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/what-is-a-digital-product-passport)
first, including the four layer framework introduced there, which this article builds on directly.

* Legal responsibility sits with the economic operator placing the product on the EU market.
  Operational responsibility is distributed across six groups. - The passport follows the product,
  not the company. Every party that touches the product may need to read from it or contribute to
  it. - Confirmed today: the ESPR framework (Regulation (EU) 2024/1781) and the battery passport
  (Regulation (EU) 2023/1542) from 18 February 2027. Everything else arrives per product group
  through delegated acts. - Suppliers are affected before their customers are, because the customer
  cannot publish data it has not been given. - Organisations outside the EU are in scope whenever
  their goods are placed on the EU market, usually through an importer that carries the legal duty.
* Small and medium sized enterprises are not exempt from the passport obligation itself, though
  ESPR requires the Commission to consider proportionate treatment and support measures. - The
  useful preparation now is identification, supplier data collection and governance. None of it
  depends on the final field list.

Framework TBF-002

The Digital Product Passport Responsibility Model

Maps the six economic operator groups in a supply chain to the passport duties each one actually
carries.

## Table of Contents

* [Who the Question Really Applies To](#who-the-question-really-applies-to)

* [The Digital Product Passport Responsibility Model](#the-digital-product-passport-responsibility-model)

* [Which Products Are Expected to Require a Passport](#which-products-are-expected-to-require-a-passport)

* [Which Organisations Should Prepare Now](#which-organisations-should-prepare-now)

* [Organisations Likely to Be Indirectly Affected](#organisations-likely-to-be-indirectly-affected)

* [SMEs and Digital Product Passports](#smes-and-digital-product-passports)

* [Common Misconceptions](#common-misconceptions)

* [Practical Preparation Checklist](#practical-preparation-checklist)

* [Frequently Asked Questions](#frequently-asked-questions)

* [Related Articles](#related-articles)

* [Related Glossary Terms](#related-glossary-terms)

* [References](#references)

* [About This Article](#about-this-article)

* [Page Metadata](#page-metadata)

* [Related Docs](#related-docs)

## Who the Question Really Applies To

There are two different questions hiding inside "does this affect us".

The first is legal: who carries the obligation, and who can be sanctioned if the passport is
missing, inaccurate or unavailable. [ESPR](/docs/knowledge-base/glossary/espr) answers this
narrowly. The duty falls on the economic operator that places the product on the EU market. For
goods produced outside the EU, that is normally the importer rather than the non EU manufacturer.

The second is operational: whose [product data](/docs/knowledge-base/glossary/product-data) ends up
inside the passport, and whose work depends on it being right. This is a far wider set of
organisations. A brand owner cannot declare recycled content it cannot evidence. An importer cannot
verify a conformity declaration it has never received. A recycler cannot act on composition data
that was never captured at design time.

Under EU product legislation, the manufacturer, the [authorised representative](/docs/knowledge-base/glossary/authorised-representative), the importer, the
distributor, the fulfilment service provider, or any other natural or legal person subject to
obligations in relation to the manufacture of products, making them available on the market or
putting them into service. The operator that places the product on the EU market carries the
passport obligation.

Confusing the two questions is the most common planning error. Organisations with no direct legal
duty conclude they are out of scope, then discover that their customer's compliance deadline is now
their delivery deadline.

## The Digital Product Passport Responsibility Model

The Responsibility Model is an educational framework, not a legal classification. Its purpose is to
let an organisation locate itself quickly, understand what it owes to the passport, and understand
what it can expect from it. The six groups are arranged around the passport deliberately: the
passport belongs to the product, and each group holds it for part of that product's life.

Digital Product Passport

Follows the product, not the company

Brand Owners

Product information, compliance and lifecycle governance

Manufacturers

Creating and maintaining technical product information

Component & Material Suppliers

Supplying trusted upstream data

Importers & Distributors

Ensuring compliant products enter and move through the market

Retailers

Providing consumer access where required

Service, Repair & Recycling

Contributing lifecycle information where applicable

Mapped against the four layer framework from the previous article, the model divides cleanly. Brand
owners dominate the governance layer. Manufacturers and suppliers dominate the information layer.
Importers, distributors and retailers operate mainly at the point where the regulatory and
technology layers meet the market. Service, repair and recycling organisations are the primary
consumers of the information layer and, over time, contributors to it.

### 1. Brand Owners

Responsible for product information, compliance and
[product lifecycle](/docs/knowledge-base/glossary/product-lifecycle) governance.

The brand owner is usually the organisation whose name appears on the product and, in many
structures, the economic operator that places it on the EU market. That makes it the accountable
party for passport accuracy, completeness, availability and retention, even where every input came
from someone else.

Practical scope of responsibility:

* Deciding what the product claims and ensuring each claim is evidenced.
* Owning the governance layer: who may create, change, approve and publish each attribute.
* Contracting suppliers and manufacturers for the data required, in a structured form and on a
  schedule.
* Keeping the passport current after launch, including corrections and variant changes.
* Ensuring continued availability for the retention period set by the applicable
  [delegated act](/docs/knowledge-base/glossary/delegated-act), including the backup arrangement
  ESPR requires.

#### Treating the passport as a launch artefact

Passport data is not signed off once. Formulations change, suppliers change, standards are
superseded and corrections are issued. Brand owners that fund a launch project but no stewardship
role end up with a passport that was accurate on the day it was published and progressively wrong
afterwards.

### 2. Manufacturers

Responsible for creating and maintaining technical product information.

Manufacturers hold the ground truth about how the product is actually made: bill of materials,
process parameters, test results, part numbers, spare part availability and disassembly sequence.
Where the manufacturer is also the operator placing the product on the EU market, it carries the
legal duty as well.

Practical scope of responsibility:

* Maintaining an accurate, versioned bill of materials with enough
  [product traceability](/docs/knowledge-base/glossary/product-traceability) to tie it to physical
  output.

* Producing and retaining
  [conformity assessment](/docs/knowledge-base/glossary/conformity-assessment) evidence, test
  reports and applicable standards references.

* Supplying repair, spare part and disassembly information in a structured form.

* Binding passport data to the correct production unit, batch or serial, so that a scan resolves to
  the right record.

* Contract manufacturers additionally need to deliver this data to the brand owner in an agreed
  format rather than as unstructured documents.

#### Where contract manufacturing breaks down

A brand owner specifies a product, a contract manufacturer builds it, and a third party laboratory
tests it. The passport requires material composition traced to the batch. The manufacturer holds
the batch records, the laboratory holds the test data, and neither has a contractual obligation to
deliver either in a structured form. The gap is commercial, not technical, and it is resolved in
the supply agreement rather than in the software.

### 3. Component and Material Suppliers

Responsible for supplying trusted upstream data.

Suppliers are the group most often surprised by the passport, and the group whose readiness most
constrains everyone else. A passport attribute such as recycled content, substance of concern, or
material origin is [sustainability data](/docs/knowledge-base/glossary/sustainability-data) that
cannot be published by a brand owner unless a supplier has stated it, evidenced it, and accepted
that it may be relied upon.

Practical scope of responsibility:

* Providing material declarations, substance data and, where applicable, recycled content evidence.
* Providing this data in a machine readable, reusable form rather than as a one off spreadsheet or
  scanned certificate.
* Notifying customers when a specification, source or formulation changes, because a silent change
  invalidates a published passport.
* Being able to answer the same question consistently for many customers, which is why a single
  internal [source of truth](/docs/knowledge-base/glossary/source-of-truth) is cheaper than per customer responses.

> **Suppliers are affected before their customers are**
>
> If a delegated act applies to a finished product from a given date, the supplier data behind it
> must exist well before that date. Suppliers that can answer structured data requests quickly
> become materially easier to buy from, which is a commercial advantage rather than a compliance
> cost.

### 4. Importers and Distributors

Responsible for ensuring compliant products enter and move through the market.

For goods manufactured outside the EU, the importer is normally the economic operator placing the
product on the EU market, and therefore normally the party carrying the passport obligation. This is
the single most under appreciated point in the entire topic. A non EU manufacturer may face no
direct EU duty while its EU importer faces the full one.

Practical scope of responsibility:

* Verifying that a passport exists, is reachable and is complete before the product is placed on the
  market.
* Ensuring the [product identifier](/docs/knowledge-base/glossary/product-identifier) in the
  passport can be checked by customs against the Commission operated registry.
* Holding the data, or a contractual right to it, sufficient to answer
  [market surveillance](/docs/knowledge-base/glossary/market-surveillance) requests.
* Distributors must ensure the passport remains associated with the product as it moves, including
  after repackaging or relabelling, and must not obscure or remove the
  [data carrier](/docs/knowledge-base/glossary/data-carrier).

#### Importers should treat passport availability as a receiving check

Add passport existence, resolvability and data completeness to goods inward acceptance criteria,
alongside conformity documentation. Discovering a missing passport at the border is expensive.
Discovering it during supplier onboarding is not.

### 5. Retailers

Responsible for providing consumers with access to Digital Product Passport information where
required.

Retailers are rarely the accountable operator, but they are the surface where consumers meet the
passport. ESPR anticipates that passport information is accessible at the point of sale, including
in distance selling, which places practical obligations on both physical and online retail.

Practical scope of responsibility:

* Ensuring the data carrier on the product or packaging remains present, legible and scannable in
  store.
* Presenting or linking to the required passport information in online listings, where the
  applicable rules require it for distance selling.
* Not overwriting or replacing manufacturer identifiers with retailer specific codes in a way that
  breaks resolution.
* Own brand and private label retailers are a special case: they are usually brand owners in the
  sense of group one, and carry the full accountability that comes with it.

#### Assuming private label is a retail relationship

A retailer selling a product under its own brand is generally the party placing it on the market
and is therefore the accountable operator. Private label ranges frequently sit in a retailer's
buying function with no compliance ownership assigned to them.

### 6. Service, Repair and Recycling Organisations

Responsible for contributing lifecycle information where applicable.

This group is the reason the passport exists at all. ESPR is
[circular economy](/docs/knowledge-base/glossary/circular-economy) legislation, and its value is
realised when a repairer can find a part reference, a refurbisher can verify provenance, and a
recycler can identify materials and safe disassembly steps without contacting the manufacturer.

Practical scope of responsibility:

* Reading passport data to make repair, reuse, remanufacture and recovery decisions.
* Contributing lifecycle events where the applicable rules provide for it, such as repairs
  performed, parts replaced or refurbishment status.
* Feeding practical failure and disassembly experience back to manufacturers, which improves both
  the product and the passport.

Note the boundary carefully. The right of these organisations to access defined passport data is a
framework principle in ESPR. A general obligation on independent repairers or recyclers to write
into the passport is not established horizontally and would be set, if at all, per product group.
Plan for read access as the near term reality and write access as the direction of travel.

## Which Products Are Expected to Require a Passport

ESPR applies to almost all physical goods placed on the EU market, with limited exclusions
including food, feed, medicinal products, veterinary medicinal products, living plants and
animals, and products of human origin. Being within ESPR scope does not by itself create a
passport obligation. The obligation attaches when a delegated act for the relevant product group
is adopted and applies.

Two categories should be distinguished carefully, because conflating them produces both false alarm
and false comfort.

**Confirmed in law today.** Batteries. Regulation (EU) 2023/1542 requires a battery passport for
light means of transport batteries, industrial batteries above 2 kWh and electric vehicle batteries
from 18 February 2027. This is a separate legal basis from ESPR and should be read from the battery
regulation directly. Construction products are addressed separately again under Regulation (EU)
2024/3110, which establishes its own digital product passport system.

**Expected through future delegated acts.** The ESPR working plan for 2025 to 2030 identifies
priority product groups for the first wave of ecodesign and information requirements, including
textiles and apparel, furniture, iron and steel, aluminium, and tyres, alongside several energy
related product groups carried over from the previous framework. Identification as a priority group
signals intent and sequence. It does not fix the data model, the carrier or the compliance date
until the delegated act is adopted.

| Category                        | Status                            | What is fixed                              | What is not                                 |
| ------------------------------- | --------------------------------- | ------------------------------------------ | ------------------------------------------- |
| Batteries in scope of 2023/1542 | Binding, applies 18 February 2027 | Obligation, date, broad content and access | Detailed implementing specifics             |
| Construction products           | Binding framework under 2024/3110 | A separate passport system exists          | Product family detail and timing            |
| ESPR priority groups            | Announced in the working plan     | Direction and sequencing                   | Field list, carrier, access matrix, date    |
| Other ESPR goods                | In framework scope only           | That ESPR can reach them                   | Whether and when a delegated act will apply |

> **A safe scoping sentence**
>
> "If we place physical goods on the EU market, we should assume a passport obligation will reach us
> eventually, and we should confirm timing only from an adopted delegated act or a directly
> applicable regulation."

## Which Organisations Should Prepare Now

Preparation is warranted where the timing is fixed, where the lead time is long, or where a customer
will impose the requirement earlier than the law does.

1. **Anyone placing batteries in scope of Regulation (EU) 2023/1542 on the EU market.** The date is
   fixed. Work should already be underway.
2. **Manufacturers and brand owners in announced priority groups**, particularly textiles, furniture,
   steel, aluminium and tyres. Supplier data collection in these categories takes longer than the
   likely notice period.
3. **Importers of any regulated category.** The legal duty lands on you rather than on the overseas
   manufacturer, and your remedy is contractual, which means it must be in place before the goods
   are ordered.
4. **Component and material suppliers to any of the above.** You will be asked for structured data
   before your customer's own deadline.
5. **Own brand and private label retailers.** You are the accountable operator for those ranges.
6. **Organisations with long product development cycles.** If a product designed today will still be
   sold when a delegated act applies, the passport data requirements belong in the current design
   process, not in a later retrofit.

#### Prepare for the shape, not the schema

Every plausible delegated act requires the same foundations: a persistent unique identifier per
product, batch or item; structured supplier data with evidence; and governance that keeps both
accurate. None of that is wasted if the final field list differs from your assumption. Field level
mapping is the last step, not the first.

## Organisations Likely to Be Indirectly Affected

Indirect exposure is real exposure when it lands on a customer's timeline.

* **Non EU manufacturers.** No direct duty in most structures, but your EU importer has one and will
  pass the data requirements to you contractually. Suppliers who cannot answer will be replaced by
  those who can.
* **Contract manufacturers and white label producers.** You hold the technical data your customer
  must publish. Expect structured data delivery to become a clause in supply agreements.
* **Logistics, fulfilment and packaging providers.** Handling must not damage, obscure or remove the
  data carrier, and repackaging must preserve the link between product and passport.
* **Marketplaces and online platforms.** Distance selling rules generally require product information
  to be shown before purchase. Platforms will need to surface passport data supplied by sellers.
* **Certification bodies, testing laboratories and auditors.** Your outputs become passport inputs
  and will increasingly be requested in structured, machine readable form.
* **Software, PLM, ERP and PIM vendors.** Customers will require interoperability, open standards and
  export without lock in, which ESPR mandates for the passport itself.
* **Consultancies and compliance advisers.** Demand shifts from document preparation towards data
  governance and supply chain data collection.

## SMEs and Digital Product Passports

There is no general small business exemption from the Digital Product Passport. If an SME places a
product on the EU market that falls under an applicable delegated act, the obligation applies in the
same way as it does to a large enterprise.

What ESPR does provide is proportionality and support. The regulation requires the Commission to
take account of the impact on small and medium sized enterprises when setting requirements, to
consider measures such as guidance, tools and financial support in the design of delegated acts, and
to avoid disproportionate administrative burden. Member States are also expected to provide support
through their own instruments. The practical effect is likely to be found in the transition periods,
guidance and simplified routes within individual delegated acts, rather than in a blanket carve out.

#### Waiting for an exemption that is not coming

Some smaller manufacturers plan on the assumption that they will be excluded. The ESPR framework
does not exclude them. Assuming a proportionality measure that has not been adopted is a
substantial planning risk, and the low cost preparation steps are worth taking regardless.

For a smaller organisation, the pragmatic reading is encouraging. The foundations are inexpensive.
Unique identification, a clean product data record, a supplier data request template and a named
owner cost far less than a large enterprise programme, and a business with fifty products can reach
a defensible position faster than one with fifty thousand.

## Common Misconceptions

#### It only applies to manufacturers

The duty attaches to the operator placing the product on the EU market, which is frequently the
importer or the private label retailer. The data comes from a much wider group again.

#### We are outside the EU, so it does not apply to us

The trigger is placement on the EU market, not the location of the producer. Non EU producers
selling into the EU are reached through their importers, and in practice through their supply
contracts.

#### We sell business to business, so consumers are not involved

Consumer access is only one of several access tiers. Market surveillance authorities, customs,
importers, repairers and recyclers all have defined interests, and business to business products
sit squarely within ESPR scope.

#### Our supplier is responsible for its own data

Suppliers are responsible for supplying accurate data. The operator placing the product on the
market remains accountable for what the passport states. Unverified supplier data does not
transfer accountability.

#### We already have a QR code, so we are covered

A QR code is one part of the technology layer. Without a persistent unique identifier, structured
data, access tiering and governance, it resolves to a marketing page rather than to a passport.

#### Nothing is confirmed, so there is nothing to do

The battery obligation has a fixed date. The framework duties are already law. The preparation
with the longest lead time, which is supplier data collection, is also the part that is completely
independent of the pending detail.

## Practical Preparation Checklist

Work through this in order. Each step is useful on its own and none depends on an unadopted
delegated act.

1. **Locate yourself in the Responsibility Model.** Write down which of the six groups you occupy,
   for which product lines. Many organisations occupy more than one.

2. **Establish whether you are the operator placing goods on the EU market.** Confirm it per legal
   entity and per route to market, including private label and marketplace sales.

3. **Assign a named owner.** One accountable person for passport readiness, with authority across
   product, compliance, procurement and technology.

4. **Inventory your products and variants.** Determine what a passport would need to be issued
   against: model, batch or individual item.

5. **Establish unique identification.** A persistent identifier per product, and per batch or serial
   where it matters, that will not be reused or reissued. Most organisations use
   [GS1](/docs/knowledge-base/glossary/gs1) keys expressed as a
   [GS1 Digital Link](/docs/knowledge-base/glossary/gs1-digital-link) address.

6. **Audit the data you already hold.** Map existing attributes to the passport categories and mark
   each as present and structured, present but unstructured, or missing.

7. **Identify your supplier data gaps.** These are almost always the critical path. Rank suppliers by
   how much passport relevant data they hold.

8. **Update contracts and onboarding.** Add structured data delivery, change notification and
   evidence retention to supply agreements before the deadline, not after.

9. **Define governance.** For each attribute: source, owner, approver, update trigger, evidence and
   retention.

10. **Run one product family end to end.** Identifier, data collection, publication, resolution and
    access tiering, on a single family, before scaling.

11. **Choose technology on interoperability grounds.** ESPR requires open standards and no vendor
    lock in. Require data export as an acceptance criterion.

12. **Monitor the delegated acts for your product groups.** Assign this to a named person with a
    recurring review, and treat adoption as the trigger for field level mapping.

#### A supplier that turned the obligation into an advantage

A mid sized textile component supplier built one internal record per material covering
composition, recycled content, substances of concern and origin, with evidence attached. When
brand customers began issuing passport data requests, it answered in days rather than months from
a single source, and was added to two preferred supplier lists as a direct result. The work was
data governance, not software.

## Frequently Asked Questions

#### Does the Digital Product Passport apply to my organisation?

If you place physical goods on the EU market and a delegated act or a directly applicable
regulation covers your product group, yes, and you are the accountable operator. If you supply,
import, distribute, sell, repair or recycle those goods, you are affected operationally even
where you carry no direct duty.

#### We are a non EU manufacturer. Are we in scope?

Usually not directly. Your EU importer normally carries the legal obligation. In practice the
data requirements reach you through that importer's supply contract, so the commercial effect is
the same.

#### Who is legally responsible when several parties are involved?

The economic operator that places the product on the EU market. Contributions from
manufacturers, suppliers and laboratories do not transfer that accountability, which is why
contractual data obligations matter.

#### Are small businesses exempt?

No. There is no general SME exemption from the passport obligation. ESPR requires the Commission
to consider SME impact and support measures when setting requirements, so proportionate
treatment is likely to appear inside individual delegated acts rather than as a blanket
exclusion.

#### Do retailers need their own passport system?

Not usually, unless they sell own brand or private label goods, in which case they are the
accountable operator. Otherwise the retail responsibility is to keep the data carrier intact and
to make the required information accessible at the point of sale, including online.

#### Do repairers and recyclers have to update the passport?

Access for these groups is a framework principle in ESPR. A horizontal obligation on independent
operators to write into the passport is not established, and any such duty would be set per
product group. Plan for read access now.

#### Which products are confirmed today?

Batteries under Regulation (EU) 2023/1542, applying from 18 February 2027, and a separate
passport system for construction products under Regulation (EU) 2024/3110. Other product groups
follow through ESPR delegated acts.

#### What should we do if our product group has no delegated act yet?

Establish unique identification, begin structured supplier data collection and put governance in
place. These are prerequisites under every plausible field list, and they are the steps with the
longest lead time.

## Related Articles

* [What is a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/what-is-a-digital-product-passport)
* [What Information Does a Digital Product Passport Contain?](/docs/knowledge-base/digital-product-passports/what-information-does-a-digital-product-passport-contain)
* [How Does a Digital Product Passport Work?](/docs/knowledge-base/digital-product-passports/how-does-a-digital-product-passport-work)
* [Digital Product Passport](/docs/knowledge-base/glossary/digital-product-passport)
* [What Are Delegated Acts?](/docs/knowledge-base/regulations/what-are-delegated-acts)
* [What is the Ecodesign for Sustainable Products Regulation (ESPR)?](/docs/knowledge-base/regulations/what-is-the-ecodesign-for-sustainable-products-regulation-espr)
* [When Will Digital Product Passports Become Mandatory?](/docs/knowledge-base/regulations/when-will-digital-product-passports-become-mandatory)
* [What Are the Benefits of a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/what-are-the-benefits-of-a-digital-product-passport)

## Related Glossary Terms

Definitions of record for the terms used above live in the
[glossary](/docs/knowledge-base/glossary/overview).

* [Economic Operator](/docs/knowledge-base/glossary/economic-operator)
* [Digital Product Passport](/docs/knowledge-base/glossary/digital-product-passport)
* [ESPR](/docs/knowledge-base/glossary/espr)
* [Delegated Act](/docs/knowledge-base/glossary/delegated-act)
* [Market Surveillance](/docs/knowledge-base/glossary/market-surveillance)
* [Conformity Assessment](/docs/knowledge-base/glossary/conformity-assessment)
* [Product Traceability](/docs/knowledge-base/glossary/product-traceability)
* [Sustainability Data](/docs/knowledge-base/glossary/sustainability-data)

## References

* Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for
  sustainable products (ESPR), Official Journal of the European Union:
  [https://eur-lex.europa.eu/eli/reg/2024/1781/oj](https://eur-lex.europa.eu/eli/reg/2024/1781/oj)
* Regulation (EU) 2023/1542 concerning batteries and waste batteries, Official Journal of the
  European Union: [https://eur-lex.europa.eu/eli/reg/2023/1542/oj](https://eur-lex.europa.eu/eli/reg/2023/1542/oj)
* Regulation (EU) 2024/3110 laying down harmonised rules for the marketing of construction products,
  Official Journal of the European Union: [https://eur-lex.europa.eu/eli/reg/2024/3110/oj](https://eur-lex.europa.eu/eli/reg/2024/3110/oj)
* Regulation (EU) 2019/1020 on market surveillance and compliance of products, Official Journal of
  the European Union: [https://eur-lex.europa.eu/eli/reg/2019/1020/oj](https://eur-lex.europa.eu/eli/reg/2019/1020/oj)
* European Commission, ESPR working plan 2025 to 2030:
  [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025DC0187](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025DC0187)
* European Commission, Ecodesign for Sustainable Products Regulation policy pages:
  [https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation\_en](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en)
* CEN-CENELEC Joint Technical Committee 24 (JTC 24), Digital Product Passport standardisation
  work programme: [https://www.cencenelec.eu/areas-of-work/cen-cenelec-topics/digital-product-passport/](https://www.cencenelec.eu/areas-of-work/cen-cenelec-topics/digital-product-passport/)

## About This Article

About This Article

<dl>
  <dt>
    Last Reviewed
  </dt>

  <dd>
    2026-08-07
  </dd>

  <dt>
    Next Scheduled Review
  </dt>

  <dd>
    2027-08-07
  </dd>

  <dt>
    Article Version
  </dt>

  <dd>
    1.0
  </dd>
</dl>

tieback Knowledge is a continuously maintained reference library covering Digital Product
Passports, product traceability, product compliance and related regulations. Articles are
reviewed regularly as legislation, standards and implementation guidance evolve.

## Page Metadata

| Field         | Value                                                                                        |
| ------------- | -------------------------------------------------------------------------------------------- |
| Published     | 2026-08-07                                                                                   |
| Last Reviewed | 2026-08-07                                                                                   |
| Reading Time  | 16 min                                                                                       |
| Difficulty    | beginner                                                                                     |
| Author        | tieback                                                                                      |
| Category      | Digital Product Passports                                                                    |
| Tags          | Digital Product Passport, DPP, ESPR, Economic Operators, Supply Chain, EU Product Compliance |

## Related Docs

* [What Is a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/what-is-a-digital-product-passport)
* [Digital Product Passports](/docs/knowledge-base/digital-product-passports/overview)
* [Regulations](/docs/knowledge-base/regulations/overview)
* [Implementation](/docs/knowledge-base/implementation/overview)