Compliance
Digital Product Passport compliance
A product is compliant when it carries a passport that meets its delegated act, resolves from its carrier, is filed in the registry and is kept current. Customs and market surveillance check it; customers and their agents read it. Here is the path in the order operators walk it.
1. Establish which act applies, and from when
Batteries: Regulation (EU) 2023/1542, passport from 18 February 2027. Every other group: the ESPR delegated act for that group, applying at least 18 months after it enters into force. Nothing else creates the duty, and nothing else sets the date.
2. Fix the identifiers
A unique product identifier at the granularity the act requires — model, batch or individual item — plus the operator and facility identifiers. Decide the carrier and the resolution address now: they are printed on products that will outlive the first version of the passport.
3. Build the data set, with evidence
Collect the Annex III categories the act selects, from your own documentation and from suppliers. Each value that supports a claim — recycled content, carbon footprint, substance declarations, country of origin — needs its source, its issuer and its validity, because the green-claims rules and REACH article 33 already ask for them today.
4. Publish, file, control access
Four things happen before the product is placed on the market.
- Render the passport from the record: a page and machine-readable data at the carrier's address
- File the identifier in the EU DPP registry
- Set the access tier of each data point as the act prescribes
- Keep a back-up copy with a DPP service provider
5. Keep it current
A passport follows the product: a changed supplier, an expired certificate, a repair, a second life for a battery. The record has to be updated, the previous versions kept, and the page has to resolve for the whole availability period.
How Listrar structures it
In Listrar the evidence sits on the field, the disclosure tier on the value, and the passport is published as a frozen version of the canonical record — so what customs reads is what was published, not a live draft. The methodology page says what each status means, and what it does not.
Questions this page answers
- Does compliance require a certification?
- No body certifies a passport. Conformity assessment stays where the product legislation puts it; the passport carries its documentation.
- Can a supplier's data be used as supplied?
- It can be recorded as supplied — and read as self-declared until a document or a verifier backs it. A passport should show that difference rather than hide it.
Official sources
Last verified by Listrar: September 22, 2026