The EU's Digital Product Passport Registry went live on 20 July 2026, and the first legally binding passport deadline lands on 18 February 2027 for certain large batteries. Between those two dates sits a gap that almost every published explainer leaves open: what is actually inside one of these things when a person scans it. The Commission's own launch announcement lists the product families the registry will support and one hard date, and says nothing about the fields.
The DPPAutomate team read the passport provisions of six EU instruments end to end, plus the Commission's own DPP guidance, its per-sector pages and the ESPR working plan timeline, and built eight worked Digital Product Passport examples out of them. Every field below is traced to an article, an annex or a named Commission page. Where a product group has no adopted delegated act, we say so instead of inventing a date. All sources were checked against their current published texts on 27 August 2026.
What is a Digital Product Passport, in one paragraph? It is a structured, machine-readable record of a product, connected through a data carrier to a persistent unique product identifier, that different actors can read at different depths depending on who they are. Regulation (EU) 2024/1781, the Ecodesign Regulation known as the ESPR, sets that framework in Articles 9 to 11 and lists the candidate data elements in Annex III. Our complete explainer of the concept, why the EU built it and who it is for lives at what is a Digital Product Passport. This article does not repeat it. This article shows you eight.
How we chose and checked these 8 Digital Product Passport examples
There is no single canonical Digital Product Passport, and anyone who shows you one screen and calls it "the DPP" is showing you a product demo, not a legal requirement. The eight examples below were selected and built against six criteria, in this order.
- A named instrument, not a trend piece. Each example is anchored to a regulation with a number and an article. Battery, toy and construction passports come from their own regulations rather than from an ESPR delegated act. The rest come from the ESPR framework plus that product group's stated position in the working plan.
- Adopted status, stated plainly. For each group we checked whether a delegated act fixing the data list exists. Two of the eight have a complete data list written into law today. A third, construction products, has its content fixed but not the system that carries it. The remaining five have neither, and each of those entries says so in its own line rather than borrowing a neighbour's certainty.
- Identifier level. ESPR Article 9(2), point (d), requires the delegated act to state whether the passport sits at model, batch or item level. That single choice changes the entire integration, so it is a fixed field in every entry.
- The data carrier and how it resolves. ESPR Article 10(1), points (a) and (b), require the passport to be connected through a data carrier to a persistent unique product identifier, and the carrier to be physically present on the product, its packaging or its accompanying documentation.
- Real data elements, not categories. Each example lists five to eight concrete fields drawn from the instrument's own annex or from the Commission's own published expectation for that sector. No field appears below unless a cited document names it.
- The access tier each element sits in. This is the part almost every competing page skips, and it is the part that decides what a consumer sees versus what a recycler or a market surveillance authority sees.
The three access tiers inside a Digital Product Passport
Read ESPR Article 10 carefully and you will notice something that matters for planning: the ESPR does not itself name three tiers. Article 10(1), point (g), says access "shall be regulated ... with the specific access rights at product group level as specified in the applicable delegated act". Article 11, point (b), lists the actors who get free and easy access "based on their respective access rights set out in the applicable delegated act". Recital 84 states the design principle, that the passport must allow differentiated access depending on the type of data and the typology of stakeholders. The framework mandates tiering and delegates the tiers.
The concrete tiering that already exists in law is in the Battery Regulation. Regulation (EU) 2023/1542, Article 77(2), splits battery passport content three ways, and Annex XIII fills each bucket: information accessible to the general public (Annex XIII point 1), information accessible only to persons with a legitimate interest and the Commission (points 2 and 4), and information accessible only to notified bodies, market surveillance authorities and the Commission (point 3). That is the working model this article uses for all eight examples:
- Public. Anyone who scans, with no login. The Commission states in its own DPP guidance that general access to product information is anonymous, without a need for identification. Regulation (EU) 2025/2509, Article 20(4), goes further for toys and forbids asking a consumer to register or provide a password.
- Restricted. Named value-chain actors: professional repairers, refurbishers, remanufacturers, recyclers, second-life operators, dealers. In battery language these are "persons with a legitimate interest", and Regulation (EU) 2023/1542, Article 77(9), requires the Commission to specify by implementing act who qualifies and what they may download, share, publish and re-use.
- Authorities. Market surveillance authorities, customs authorities, notified bodies and the Commission. ESPR Article 13(6) gives the Commission, competent national authorities and customs authorities access to the registry for their duties.
Two practical consequences. First, a passport is not one document, it is one identifier resolving to a filtered view per credential, which is why ESPR Article 11 anticipates implementing acts on issuing and verifying the digital credentials of actors with access rights. Second, your product data model has to carry a tier attribute per field from day one, because retrofitting one later means re-publishing every passport you have already issued. In DPPAutomate, the tier is a property of the field in the passport template rather than a property of the page, so the same record renders a public view, a repairer view and an auditor view without a second data entry pass. The full tier mechanics get their own deep dive; here we use the three labels consistently across all eight examples. The framework itself is covered on our ESPR pillar page.
The 8 Digital Product Passport examples at a glance
DPPAutomate issues passports across batteries, textiles, electronics, furniture, toys, packaging, tyres and steel, which means we read these annexes for a living rather than for an article. Here is the full list before the detail.
- Electric vehicle, industrial and LMT batteries
- Textile apparel and fashion
- Consumer electronics and ICT
- Furniture
- Toys
- Construction products
- Tyres
- Iron and steel
Now let's review each Digital Product Passport example in detail.
Digital Product Passport examples, product group by product group
Each entry carries the same five Highlights fields and one field-level table. In the tables, "Access tier" uses the three labels defined above. Where a delegated act has not been adopted, the tier shown is the expected placement, not a binding one.
Electric vehicle, industrial and LMT batteries
The digital battery passport is the only one of the eight whose data list is written into a regulation rather than into a future delegated act, which makes it the most concrete Digital Product Passport example available anywhere today. Regulation (EU) 2023/1542, Article 77(1), requires each LMT battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the market or put into service from 18 February 2027 to have an electronic record. It is also the only one with an item-level obligation baked into the text.
Article 77(3) makes the passport accessible through the QR code required by Article 13(6), which links to a unique identifier attributed by the economic operator placing the battery on the market. That QR code and identifier must comply with ISO/IEC 15459-1:2014 and ISO/IEC 15459-6:2014, or their equivalent. Article 77(8) then does something no other instrument does: the battery passport ceases to exist once the battery has been recycled.
For anyone modelling this, the useful detail is that the record mixes two granularities in one view. Model-level chemistry and carbon footprint sit alongside individual-battery state of health and cycle history, which is why the battery passport data model is the hardest of the eight to retrofit onto a PIM.
| Field | What it carries | Access tier |
|---|---|---|
| Unique battery identifier and model identifier | Item-level ID attributed by the operator placing the battery on the market, resolved from the QR code (Art. 77(3)) | Public |
| Material composition | Chemistry, hazardous substances other than mercury, cadmium and lead, critical raw materials (Annex XIII, 1(b)) | Public |
| Carbon footprint and recycled content | Carbon footprint per Art. 7(1) and (2); recycled content per Art. 8(1) (Annex XIII, 1(c), 1(e)) | Public |
| Rated capacity and expected lifetime | Rated capacity in Ah, expected lifetime in cycles with the reference test used (Annex XIII, 1(g), 1(j)) | Public |
| EU declaration of conformity | As referred to in Art. 18 (Annex XIII, 1(r)) | Public |
| Detailed composition | Materials used in the cathode, anode and electrolyte (Annex XIII, 2(a)) | Restricted |
| Dismantling information | Exploded diagrams, disassembly sequences, fastening types, tools required, damage warnings, cell count and layout (Annex XIII, 2(c)) | Restricted |
| State of health and use history | State of health per Art. 14, charge and discharge cycles, negative events, recorded operating temperature (Annex XIII, 4) | Restricted |
| Test reports | Results proving compliance with the Regulation and its delegated or implementing acts (Annex XIII, 3) | Authorities |
Highlights:
- Instrument: Regulation (EU) 2023/1542, Article 77 and Annex XIII
- Identifier level: Item, with model-level data carried alongside
- Data carrier: QR code under Article 13(6), printed or engraved on the battery
- Binding data list: Yes, Annex XIII
- Date that binds: 18 February 2027
Battery Passport Data Model: Model, Batch and Individual Battery Data
The battery passport is the one case where model data, batch data and per-unit telemetry share a single record, and where the record dies when the battery is recycled. That post walks the whole Annex XIII structure and shows where each field usually comes from in an existing system. Continue reading.
Textile apparel and fashion
A Digital Product Passport for textiles is the highest-volume question in this market and the one with the least settled answer. The Commission's own textile apparel DPP page states the position without hedging: textile-specific DPP requirements will be defined through the same future delegated act that will introduce the ecodesign requirements themselves. No binding DPP data list exists for textiles at the time of writing, because that delegated act has not been adopted. The Commission's published indicative timeline is Q4 2027 for adoption.
What is knowable today is the shape. The Commission lists what the textile passport "may include" beyond sustainability data: product identification and characteristics, fibre composition as required under the Textile Labelling Regulation, information supporting use, repair and maintenance, information relevant to reuse, resale, disassembly, refurbishment, disposal and recycling, origin information, and identification of relevant economic operators. Those categories map onto ESPR Annex III cleanly, which is what makes a defensible mock-up possible.
For anyone building a Digital Product Passport for fashion the planning consequence is specific rather than abstract: fibre composition, origin and economic operator identity are supplier-held fields, not brand-held fields, so the collection workflow has to exist before the data list is published. The sector's obligation list is covered separately in our textile DPP pillar.
| Field | What it carries | Access tier |
|---|---|---|
| Unique product identifier | Persistent ID connected through the data carrier (ESPR Art. 10(1)(a)) | Public |
| GTIN or equivalent | Global Trade Identification Number per ISO/IEC 15459-6 or equivalent (ESPR Annex III, (c)) | Public |
| Fibre composition | As required under the Textile Labelling Regulation, where relevant for the passport | Public |
| Origin information | Named by the Commission as a candidate element for the textile passport | Public |
| Use, repair and maintenance | Instructions supporting use, repair and maintenance | Public |
| Substances of concern | Name or numerical code, location within the product, concentration (ESPR Art. 7(5)) | Public and Restricted |
| End-of-life handling | Information relevant to reuse, resale, disassembly, refurbishment and recycling | Restricted |
| Compliance documentation | Declaration of conformity and technical documentation (ESPR Annex III, (e)) | Authorities |
Highlights:
- Instrument: Regulation (EU) 2024/1781, Articles 9 to 11 and Annex III; product rules pending
- Identifier level: To be set by the delegated act (ESPR Art. 9(2)(d))
- Data carrier: To be set by the delegated act; the Commission describes a data carrier on the product itself, such as a QR code
- Binding data list: No. Delegated act not adopted, checked 27 August 2026
- Date that binds: None yet. Commission indicative adoption Q4 2027
Textile Industry DPP Requirements
What the textile sector's obligations look like once you separate the ESPR framework from the sector rules that already apply. That post covers the requirement list; this one covers the passport screen. Continue reading.
Consumer electronics and ICT
Electronics is the group where a partial passport already exists under a different name. Commission Regulation (EU) 2023/1670 has set ecodesign requirements for smartphones, mobile phones, cordless phones and slate tablets since 20 June 2025, with an information set that reads like a passport and is published through the EPREL product database rather than through a data carrier on the device.
Under the ESPR itself, ICT products carry an indicative timeline of 2029 in the Commission's published schedule, with energy-related products spread across 2026 to 2029, plus horizontal measures on repairability and recycled content for electrical and electronic equipment named in the working plan. No ESPR delegated act fixing a Digital Product Passport data list for electronics has been adopted at the time of writing. So the table below is the real, binding 2023/1670 information set, which is the closest thing to a Digital Product Passport for electronics that exists in EU law today, rather than a speculative one.
The reason it matters commercially is that most of these fields already exist somewhere in a manufacturer's technical documentation. The work is not generating them, it is exposing them per audience. Our electronics DPP pillar covers the sector view.
| Field | What it carries | Access tier |
|---|---|---|
| Model identifier and EPREL registration | Model-level identity, registered in the product database | Public |
| Battery endurance in cycles | Charge and discharge cycles until usable capacity reaches 80 % of rated capacity | Public |
| Reliability parameters | Resistance to accidental drops, scratch resistance, protection from dust and water | Public |
| Operating system upgrade availability | Availability of operating system version upgrades | Public |
| Indicative spare part prices | Indicative pre-tax price per spare part, published on a free access website | Public |
| Spare parts availability | Listed spare parts made available to professional repairers for at least 7 years after the end of placing on the market | Restricted |
| Disassembly and recycling information | Information provided for repairers and recyclers | Restricted |
| Technical documentation | Held for market surveillance, referable to the product database entry | Authorities |
Highlights:
- Instrument: Commission Regulation (EU) 2023/1670 today; Regulation (EU) 2024/1781 for the future passport
- Identifier level: Model today; item or batch possible under a future delegated act
- Data carrier: Energy label with a QR link to EPREL today; passport carrier to be set by the delegated act
- Binding data list: No DPP data list. The 2023/1670 information requirements bind since 20 June 2025
- Date that binds: None yet. ESPR indicative 2029 for ICT products, 2026 to 2029 for energy-related products
Electronics DPP: Repairability and Recycling
Repairability scores, spare-part obligations and recycler-facing data are where the electronics passport gets contentious. That post takes the sector's requirement set apart field by field. Continue reading.
Furniture
A Digital Product Passport for furniture sits at an indicative 2028 in the Commission's published DPP timeline, alongside mattresses at 2029. The Commission is explicit that inclusion in the working plan does not make a passport mandatory: it means the group is scheduled for an in-depth study and impact assessment, which then determines whether a passport is the right instrument and what the compliance date is. No binding DPP data list exists for furniture at the time of writing, because its delegated act has not been adopted.
The table below is therefore built strictly from ESPR Annex III and Article 7(5), which apply to any product group once its delegated act names them, rather than from a sector wish list. That is the honest maximum you can plan against today, and it is enough to start: substance data, disassembly data and supplier identity are the three that take longest to collect.
Furniture is also the clearest case for planning the identifier level early. A sofa model and a batch of flat-pack cabinets pull the answer in opposite directions, and ESPR Article 9(2), point (d), leaves the choice to the delegated act. Our furniture DPP pillar tracks the group's status.
| Field | What it carries | Access tier |
|---|---|---|
| Unique product identifier | Persistent ID connected through the data carrier (ESPR Art. 10(1)(a)) | Public |
| Materials and components | Material types and recycled content share, as candidate ecodesign parameters | Public |
| Substances of concern | Name, location within the product, concentration or concentration range (ESPR Art. 7(5)) | Public and Restricted |
| Durability, repair and spare parts | Information for installation, use, maintenance and repair (ESPR Art. 7(2)(b)) | Public |
| Disassembly information | Information for treatment facilities on disassembly, reuse, refurbishment and recycling (ESPR Art. 7(2)(b)) | Restricted |
| Economic operator identifiers | Manufacturer unique operator identifier and the EU responsible person (ESPR Annex III, (g), (k)) | Public |
| Unique facility identifiers | Where required by the delegated act (ESPR Annex III, (i)) | Restricted |
| Compliance documentation | Declaration of conformity, technical documentation, conformity certificates (ESPR Annex III, (e)) | Authorities |
Highlights:
- Instrument: Regulation (EU) 2024/1781, Articles 9 to 11 and Annex III
- Identifier level: To be set by the delegated act (ESPR Art. 9(2)(d))
- Data carrier: To be set by the delegated act (ESPR Art. 9(2)(b) and (c))
- Binding data list: No. Delegated act not adopted, checked 27 August 2026
- Date that binds: None yet. ESPR working plan indicative 2028
Toys
Toys is the second product group with its data list fixed in law, and almost nobody has noticed. Regulation (EU) 2025/2509 on the safety of toys, published on 12 December 2025, requires the manufacturer to create a Digital Product Passport before placing a toy on the market (Article 19(1)) and fixes its minimum content in Annex VI, Part I. The Regulation applies from 1 August 2030, with Articles 28 to 44 and 49 to 55 applying from 1 January 2026.
What makes the toy passport structurally different is that it replaces the EU declaration of conformity. Article 19(4) states that by creating the passport, the manufacturer assumes responsibility for the toy's compliance, and Article 19(5) lets a single passport discharge declaration-of-conformity obligations under several other instruments at once. The passport must correspond to a specific toy model (Article 19(2)(a)), be available for 10 years after the toy is placed on the market including after insolvency (Article 19(2)(g)), and display a link to the Safety Gate portal when accessed (Article 19(11)).
The carrier rule is unusually strict. Article 19(7) requires the data carrier to be physically present on the toy or on an affixed label, moving to packaging or accompanying documentation only where size or nature does not allow it, and to be clearly visible before purchase including in distance sales. Our toys DPP pillar tracks the group.
| Field | What it carries | Access tier |
|---|---|---|
| Unique product identifier of the toy | Annex VI, Part I, (a) | Public |
| Manufacturer identity | Name, address and unique operator identifier, plus authorised representative where applicable (b) | Public |
| EU responsible person | Name, address and unique operator identifier of the operator under Art. 4 of Regulation (EU) 2019/1020 (c) | Public |
| Colour image of the toy | Of sufficient clarity to enable identification and traceability (e) | Public |
| Union law complied with | References to all Union law the toy conforms to, plus harmonised standards or common specifications used (g), (i) | Public |
| Notified body details | Name, number and certificate reference where a notified body intervened (j) | Public |
| Allergenic fragrances | List of allergenic fragrances present that carry specific labelling requirements (l) | Public |
| Commodity code | Under Regulation (EEC) No 2658/87, at the moment the passport is created (f) | Authorities |
Highlights:
- Instrument: Regulation (EU) 2025/2509, Article 19 and Annex VI
- Identifier level: Model, with batch permitted where other Union law requires it (Art. 19(9))
- Data carrier: On the toy or an affixed label; packaging or documentation only where size or nature does not allow (Art. 19(7))
- Binding data list: Yes, Annex VI, Part I
- Date that binds: 1 August 2030
Construction products
Construction has a passport chapter in force and no passport obligation yet, which is a distinction worth getting right. Regulation (EU) 2024/3110 devotes Chapter X, Articles 75 to 79, to the construction Digital Product Passport, and Article 76(2) already fixes what the passport contains. What is missing is Article 75(1)'s delegated act, which sets up the construction digital product passport system itself. That delegated act has not been adopted at the time of writing, so no binding date exists for construction passports yet.
The trigger is written as an offset rather than a calendar date. Article 22(7) requires the manufacturer to make the passport available through the construction system within 18 months after the entry into force of the Article 75(1) delegated act, connected to a data carrier under Article 18(2), point (g). Once the clock starts, it runs fast.
The construction passport is also the clearest example of a passport built at type level rather than unit level. Article 77(1), point (a), connects it through one or more data carriers to a persistent unique identification code of the product type, and Article 76(2), point (d), ties the passport to that type. Notably, Article 76(2), point (a)(vii), asks the passport to carry the data carriers of key parts that have passports of their own, which is the first explicit passport-to-passport nesting requirement in EU law.
| Field | What it carries | Access tier |
|---|---|---|
| Declaration of performance and conformity | Art. 76(2)(a)(i) | Public |
| General product information | Instructions for use and safety information under Art. 22(6), Art. 76(2)(a)(ii) | Public |
| Product type and identification code | The manufacturer-specific unique identification code of the product type, Art. 76(2)(d) | Public |
| The product label | Under Art. 22(9), Art. 76(2)(a)(iv) | Public |
| Unique identifiers | Issued under Art. 79(1), Art. 76(2)(a)(v) | Public |
| Data carriers of key parts | Carriers of key parts for which a passport is available, Art. 76(2)(a)(vii) | Restricted |
| Documentation under other Union law | Art. 76(2)(a)(vi) | Restricted |
| Technical documentation | Under Art. 22(3), including sections required by Arts. 59 to 61, Art. 76(2)(a)(iii) | Authorities |
Highlights:
- Instrument: Regulation (EU) 2024/3110, Articles 75 to 79
- Identifier level: Product type, via a persistent unique identification code (Art. 77(1)(a))
- Data carrier: One or more carriers affixed under Article 18(2), point (g)
- Binding data list: Partly. Article 76(2) fixes the content; the system needs the Article 75(1) delegated act, not adopted, checked 27 August 2026
- Date that binds: 18 months after the Article 75(1) delegated act enters into force (Art. 22(7))
Tyres
Tyres carry an indicative 2027 in the Commission's published DPP timeline, alongside textiles and aluminium, and no ESPR delegated act setting a tyre passport data list has been adopted at the time of writing. But tyres already run a working two-tier product record, which makes them the best available preview of how a tiered passport behaves in the field.
Regulation (EU) 2020/740 splits tyre data into two parts of the product database, and Annex VII of that Regulation says exactly what goes in each. The public part carries the supplier's legal identification, the tyre type identifier, the electronic tyre label and its classes. The compliance part carries the test protocols, the measured technical parameters and the calculations behind them, and is available to market surveillance authorities and the Commission. That is a public tier and an authorities tier resolving from one printed label, already deployed across every tyre sold in the EU.
Tyres are also one of the four value chains in CIRPASS-2, the Commission-funded Digital Europe Programme project running from May 2024 to April 2027 that is piloting passports across textiles, electrical and electronic equipment, construction products and tyres. Our tyres DPP pillar tracks the group's status.
| Field | What it carries | Access tier |
|---|---|---|
| Supplier legal identification | Trade name or trademark, address, contact details (Annex VII, 1(a)) | Public |
| Tyre type identifier | Registered type identity in the product database (Annex VII, 1(b)) | Public |
| Tyre label and its classes | Electronic label plus the fuel efficiency, wet grip and external rolling noise classes and other label parameters (Annex VII, 1(c), (d)) | Public |
| Product information sheet | Parameters in electronic format (Annex VII, 1(e)) | Public |
| Equivalent tyre types | Identifiers of equivalent types already on the market (Annex VII, 2(a)) | Authorities |
| Test and grading protocols | Protocols of testing, grading and measurement of the Annex I parameters (Annex VII, 2(c)) | Authorities |
| Measured technical parameters | Measured values and the calculations performed with them (Annex VII, 2(e), (f)) | Authorities |
| Material composition and retreadability | Expected under a future ESPR delegated act, not binding today | Restricted |
Highlights:
- Instrument: Regulation (EU) 2020/740 today; Regulation (EU) 2024/1781 for the future passport
- Identifier level: Tyre type today; passport level to be set by the delegated act
- Data carrier: QR code printed on the tyre label, giving direct access to the public part of the product database
- Binding data list: No DPP data list. Delegated act not adopted, checked 27 August 2026
- Date that binds: None yet for the passport. ESPR working plan indicative 2027
Iron and steel
Iron and steel is the first ESPR product group in the queue, with a published indicative adoption date of Q4 2026 for its delegated act, and it is the least consumer-facing of the eight. Nobody scans a steel coil in a shop. The passport here is a business-to-business record that has to survive being cut, formed and welded into somebody else's product.
The Commission's iron and steel DPP page sets out what the passport may carry once the delegated act defines it: product identification and classification, technical and material data, information supporting circularity such as recycled content, sustainability-related product information, and documentation relevant to compliance and traceability. No binding data list exists yet, because that delegated act has not been adopted at the time of writing. The Commission is equally explicit that recyclers, downstream operators and public authorities may have access in line with the access rights defined in the delegated act.
The structural detail worth planning for is nesting. ESPR Article 11, point (d), requires a new passport created for a product that already has one to be linked to the original, and Regulation (EU) 2024/3110, Article 76(2), point (a)(vii), asks a construction passport to carry the data carriers of its key parts. A steel passport is therefore an input to other passports, not just an output. Our steel and aluminium DPP pillar tracks the group.
| Field | What it carries | Access tier |
|---|---|---|
| Product identification and classification | Named by the Commission as a candidate element | Public |
| Technical and material data | Named by the Commission as a candidate element, for example grade and dimensional data | Public and Restricted |
| Recycled content | Named by the Commission under information supporting circularity | Public |
| Sustainability-related product information | Named by the Commission as a candidate element | Public |
| Manufacturer unique operator identifier | ESPR Annex III, (g) | Public |
| Unique facility identifier | ESPR Annex III, (i) | Restricted |
| Link to downstream passports | New passports must link to the original passport (ESPR Art. 11(d)) | Restricted |
| Compliance and traceability documentation | Named by the Commission as a candidate element | Authorities |
Highlights:
- Instrument: Regulation (EU) 2024/1781, Articles 9 to 11 and Annex III
- Identifier level: To be set by the delegated act (ESPR Art. 9(2)(d))
- Data carrier: To be set by the delegated act; ESPR Article 10(1)(b) permits accompanying documentation where the product allows
- Binding data list: No. Delegated act not adopted, checked 27 August 2026
- Date that binds: None yet. Commission indicative adoption Q4 2026
Comparison table of the 8 Digital Product Passport examples
Read as prose, these eight sound similar. Read as a table, they diverge on the two things that decide your build: what level the identifier sits at, and whether a data list exists at all. Two of the eight have a binding data list today, one has its content fixed but not yet the system that carries it, and five have neither. Our deadline tracker keeps the dates current as delegated acts land.
| Product group | Instrument | Identifier level | Data carrier | Binding data list | Date that binds |
|---|---|---|---|---|---|
| EV, industrial and LMT batteries | Reg. (EU) 2023/1542, Art. 77, Annex XIII | Item, with model data | QR code under Art. 13(6) | Yes | 18 February 2027 |
| Textile apparel and fashion | Reg. (EU) 2024/1781, Arts. 9 to 11 | Set by delegated act | Set by delegated act | No | None yet, indicative Q4 2027 |
| Consumer electronics and ICT | Reg. (EU) 2023/1670 today | Model | Energy label QR to EPREL | No DPP list | Indicative 2029 for ICT |
| Furniture | Reg. (EU) 2024/1781, Arts. 9 to 11 | Set by delegated act | Set by delegated act | No | None yet, indicative 2028 |
| Toys | Reg. (EU) 2025/2509, Art. 19, Annex VI | Model, batch where required | On the toy or affixed label | Yes | 1 August 2030 |
| Construction products | Reg. (EU) 2024/3110, Arts. 75 to 79 | Product type | Carrier under Art. 18(2)(g) | Content yes, system pending | 18 months after Art. 75(1) act |
| Tyres | Reg. (EU) 2020/740 today | Tyre type | QR on the printed tyre label | No DPP list | None yet, indicative 2027 |
| Iron and steel | Reg. (EU) 2024/1781, Arts. 9 to 11 | Set by delegated act | Set by delegated act | No | None yet, indicative Q4 2026 |
How to look at a real Digital Product Passport yourself
Three routes, in ascending order of usefulness.
Scan something that already has a two-tier record. Any tyre sold in the EU carries a label whose QR code resolves to the public part of the EPREL product database under Regulation (EU) 2020/740. Scan it, then note what you cannot see. That gap is the restricted and authority tiers.
Read the registry rules. Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 lays down the implementation arrangements for the DPP registry set up under ESPR Article 13, and entered into force on 6 August 2026. Its recital 14 answers a question most vendors will not: where a passport is created at item level, the corresponding batch and model identifiers must be registered alongside it, and where several instruments require different levels for the same product, the passport is registered at the most granular of them. The registry itself, plus a testing environment, went live on 20 July 2026.
Issue one and scan it. Reading an annex tells you what a passport contains. Scanning one you issued tells you what a consumer, a repairer and an auditor each see from the same record, which is the part no annex conveys. DPPAutomate offers a free Sandbox workspace where you can build a passport template against any of the eight structures above, publish it, scan the carrier from your phone and switch between the three access views. If you are costing a rollout rather than exploring one, pricing is a subscription tier with an included active-passport capacity and metered overage above it, with CSV import from the Starter tier and API and webhook access from the Operator tier upward.
One dependency worth resolving early, whichever route you take: how the carrier resolves. GS1 Digital Link is the standardised method for encoding GS1 identifiers such as GTINs, along with batch and serial numbers, so that a single 2D barcode both scans at point of sale and redirects to online content, with the brand owner able to change the destination without reprinting packaging. GS1's own standard page lists the URI syntax standard at version 1.7.0 as of August 2026. ESPR Annex III requires the data carrier and identifiers to comply with the ISO/IEC 15459 series or equivalent, which is the family GS1 identifiers belong to, so this is the compatible path rather than a competing one.
What to do on Monday morning
The two decision factors that matter most in these eight examples are the ones that cost the most to change later: the identifier level, and whether each field has an access tier attached to it. Everything else, the field names, the units, the carrier artwork, moves cheaply. A passport built at model level cannot be split to item level without reissuing every record, and a passport with no tier attribute per field cannot be shown to a repairer without showing the same screen to a competitor. Decide both before you decide anything else.
The third factor is honesty about status. Five of these eight product groups have no binding data list at all today, and a sixth has its content fixed but not the system that carries it, and any vendor telling you otherwise is selling you a schema that a delegated act will overwrite. The correct posture is to build the collection workflow now, against ESPR Annex III and your sector's published candidate elements, and let the field list stay editable until the delegated act lands. That is exactly what DPPAutomate is built to do: issue passports at scale from a single workspace, capture supplier declarations for the fields you do not own, log lifecycle events, and hand auditors a read-only window, with an API and webhooks so the schema can change without a migration project.
See what a passport looks like before you commit. Start free with a Sandbox workspace.
This article is general information about EU product regulation, not legal advice. Delegated acts change what applies to your products and when. Confirm your own obligations against the current text of the instruments cited above, or with your legal counsel.
