Requirements
Digital Product Passport requirements
The requirements come in two layers: the general rules of ESPR articles 9 to 13, which bind every product group, and the delegated act for each group, which fixes the data set and the date. This page lists the first layer and shows where the second slots in.
Identifiers
The GS1 Digital Link fact sheet shows how the GTIN already on most products becomes that resolvable address.
- A unique product identifier, at model, batch or item level as the act decides
- Unique identifiers for the economic operators involved and, where the act requires, for facilities
- A data carrier — a QR code or equivalent — physically on the product, its packaging or its documentation, encoding the product identifier
Data categories (Annex III)
The delegated act chooses, for its product group, which of these categories apply and at what granularity.
- Product identity: name, model, identifiers, manufacturer and the other operators
- Compliance documentation: declaration of conformity, technical documentation, the certificates the act names
- Substances of concern present in the product
- User information: instructions, safety, handling at end of life
- Sustainability and circularity attributes the act selects: durability, reparability, recycled content, carbon footprint, recyclability
- Information for repairers, recyclers and authorities, at the access level the act sets
Access and availability
Information is published in layers: a public tier open to anyone scanning the carrier, and restricted tiers for market-surveillance and customs authorities, recyclers, repairers or other persons with a legitimate interest. The passport must remain available for the period the act sets, be interoperable and machine-readable, and a back-up copy must be held by an independent DPP service provider.
Registry and controls
Before placing the product on the market, the operator files the passport identifier in the EU DPP registry (article 13), operational since 20 July 2026 under Implementing Regulation (EU) 2026/1778. Customs and market-surveillance authorities check that a passport exists and resolves (article 15).
What the delegated act adds
The act for each group fixes the data set, the identifier granularity, the access rights per data point, the availability period and the date of application. Until it is published, the general rules are the plan. The sector pages track that status for textiles and furniture; for batteries the equivalent is already in force — see the battery passport.
How Listrar meets the general layer
The support status per text is shown on each regulation fact sheet, derived from the fields the record actually holds.
- One record per product with a GS1 Digital Link address at /01/{gtin}, at model, batch and item level
- Attribute profiles per regulation: when an act adds a data point, the record gains the field
- A disclosure tier on every field: public, customs, recycler, regulator
- Evidence, source and validity attached to the value they support
- Schema.org Product JSON-LD rendered on every public passport page
Questions this page answers
- Does the passport have to be a QR code?
- The regulation requires a data carrier; the delegated act names the type. A QR code is the usual choice because any phone reads it.
- Does the passport replace the declaration of conformity?
- No. It references or contains the compliance documentation; the declaration remains the manufacturer's own act.
- Who hosts the passport?
- The economic operator, directly or through a DPP service provider, with a back-up copy held by an independent provider.
Official sources
Last verified by Listrar: September 22, 2026