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2026-06-14 · 9 min read · All articles

A Digital Product Passport for Every Product Category — and the Law Behind Each One

The Digital Product Passport is often discussed as a "battery thing", then a "textile thing", then a "packaging thing". That framing is wrong. The ESPR is a framework regulation that reaches almost every physical product placed on the EU market — and alongside it, most product families already carry their own dedicated EU legislation. dpp.gs now supports 14 product categories, each modelled on the law that actually governs it, and each with a live passport you can scan today.

The key idea: there is no single "DPP law". There is the ESPR (the horizontal framework), its category-by-category delegated acts, and a layer of sector regulations — Battery, PPWR, CPR, REACH/CLP, Toy Safety, Machinery, ELV, Cosmetics, FIC, MDR — that predate or sit beside it. A useful passport platform has to speak each of those languages, not just one.

ESPR is a framework, not a product rule

Regulation (EU) 2024/1781 — the Ecodesign for Sustainable Products Regulation — replaced the old Ecodesign Directive and extended its scope from energy-related products to almost all physical goods. It does not, by itself, list every data field for every product. Instead it sets the framework and empowers the Commission to adopt delegated acts per product group, each defining the specific ecodesign and information (DPP) requirements for that group. Batteries got there first via their own regulation; textiles, electronics, furniture, tyres, iron & steel and others follow on a published work-plan through 2030.

So "is my product in scope?" is rarely a yes/no question. It is: which instrument applies first — the ESPR delegated act, or an existing sector regulation that already mandates structured product data? For most categories, the answer is "both, eventually". A passport built on open GS1 Digital Link identifiers lets you carry that data now and extend it as each delegated act lands.

The 14 categories and the law behind each

Every row below is backed by a real, live passport on dpp.gs — scan it or open it from the demo gallery.

CategoryPrimary EU legislationWhat the passport carriesLive demo
BatteriesBattery Regulation (EU) 2023/1542 (Art. 77 + Annex XIII)Chemistry, capacity, state of health, due diligence, recycled content, carbon footprint, disassemblyEV battery
Electronics / ICTEcodesign Reg (EU) 2023/1670 (smartphones & tablets) + EPREL + RoHS/WEEERepairability & durability class, battery endurance, OS/security-update period, spare parts, USB-CSmartphone
TextilesESPR delegated act (in preparation) + Textile Labelling Reg (EU) 1007/2011Fibre composition, fabric weight, microfibre shedding, care, recycled contentFleece
TyresTyre Labelling Reg (EU) 2020/740 + EPREL + ESPR (expected)Fuel efficiency, wet grip, external noise, EPREL deep-linkTyre
FurnitureESPR (Tier-1 priority) + EUDR (EU) 2023/1115 for woodWood composition & traceability, formaldehyde class, VOC, load capacitySofa
PackagingPPWR (EU) 2025/40 (Art. 12 composition, Art. 5 substances)Material composition, recyclability class, PFAS, mono-material, deposit schemeBottle
ConstructionCPR (EU) 305/2011 → revision (EU) 2024/3110 + EN 15804 EPDDeclaration of Performance, essential characteristics, reaction to fire, GWPInsulation
ChemicalsREACH (EC) 1907/2006 + CLP (EC) 1272/2008GHS classification, hazard pictograms, SDS, UFI / Poison Centre, ADR transportAdhesive
ToysToy Safety Directive 2009/48/EC → Toy Safety Regulation (2025)Age grading & warnings, EN 71 conformity, phthalates, button-cell safetyWooden toy
MachineryMachinery Regulation (EU) 2023/1230Essential H&S requirements, safety components, noise/vibration, AI-safety & cybersecurityPower tool
VehiclesELV Directive 2000/53/EC + Type Approval Reg (EU) 2018/858Recyclability ≥85% / recoverability ≥95%, emissions, depollution & dismantlingEV
CosmeticsCosmetics Regulation (EC) 1223/2009INCI list, CPNP reference, 26 allergens, Product Information File, Period After OpeningCream
FoodFood Information to Consumers Reg (EU) 1169/2011Ingredient list, 14 allergens, nutrition table, Nutri-Score, origin, durabilityPasta
Medical devicesMDR (EU) 2017/745 / IVDR (EU) 2017/746UDI (Basic + production), EUDAMED, IFU, implant card, sterility, MR safetyImplant

Three patterns across the table

Look down the legislation column and three patterns emerge — and they explain why a single-sector tool eventually fails.

1. Some categories have a true DPP mandate

Batteries (Reg 2023/1542) and the upcoming ESPR delegated acts for textiles, electronics, furniture and others create an explicit, machine-readable Digital Product Passport obligation. The Battery Passport is mandatory for EV, LMT and industrial batteries from 18 February 2027. The construction sector's revised CPR (2024/3110) likewise introduces a product passport carrying the Declaration of Performance.

2. Some categories already mandate structured data — just not called a "passport"

Cosmetics (CPNP + INCI), food (the FIC nutrition declaration and 14 allergens), chemicals (the Safety Data Sheet, CLP label and Poison Centre / UFI), medical devices (UDI + EUDAMED) and vehicles (the Certificate of Conformity) already require rich, structured information today. None of it is a "DPP" by name — but all of it fits naturally behind one GS1 Digital Link QR code, in the consumer's language, instead of being crammed onto a label. For these categories a passport is a voluntary carrier that turns existing obligations into something a phone can read.

3. Substance and circularity rules cut across everything

REACH SVHCs, RoHS, PFAS restrictions, the EUDR for wood, and recycled-content targets do not respect category boundaries — they apply horizontally. That is why dpp.gs models substances, materials and recycled content as shared building blocks reused by every sector, then layers the category-specific fields on top.

Honest scope note: not every category is under a binding DPP mandate yet — food, cosmetics and medical devices run on their own dedicated systems and are largely outside the ESPR DPP. We say so plainly on each passport. The value today is consolidating the data the law already requires into one scannable, multilingual, open-standard record — and being ready the day a delegated act turns "voluntary" into "mandatory".

Why one platform, not fourteen tools

A brand rarely sells only batteries, or only textiles. A retailer's catalogue spans electronics, packaging, toys, cosmetics and food on the same shelf. Running a separate compliance tool per category multiplies cost, fragments data and breaks the one thing that makes a passport useful: a single, persistent, resolvable identifier per product. Building every category on the same GS1 Digital Link foundation — and the same open standards — means one QR format, one resolver, one data model that grows as the law does.

The passport viewer renders each category in 28 languages, shows only the sections relevant to that product, and exposes the exact regulatory basis for every field. Whether you make EV batteries or breakfast cereal, the workflow is identical: create the product, fill the fields the law asks for, print the QR.

See a live passport for your category

Fourteen categories, one platform, free to start. Open the demo gallery or create your first passport in minutes.

Browse the demo gallery →

Related reading: What is the EU Digital Product Passport? · ESPR compliance guide · Penalties for non-compliance