The Digital Product Passport – New Rules for Product Data

The digital product passport is set to become a key element of the European Union's regulatory toolkit, with far-reaching implications for companies active in the European market and consumers purchasing products in the EU – however many are not yet familiar with it. This article provides an overview of the key topics: the digital product passport and its purpose, the regulatory framework, and the products and industries affected in the near future.

These topics will also be explored from a practical perspective at an upcoming event that we are hosting on 3 September 2026, organised in collaboration with the Finnish Fashion Law Association and Ovido Oy. The event discusses compliance and data in the textile and fashion industries. Read more about the event and sign up at the end of this article.

Background for the digital product passport

Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products ("ESPR") entered into force in July 2024. One of the first concrete measures already took effect 19 July 2026 in the form of a ban applicable to large companies on destroying unsold consumer goods (find out more about the ban on the European Commission's website). The ESPR significantly expands the scope of its repealed predecessor, the so-called Ecodesign Directive, and imposes ecodesign, transparency and traceability obligations covering nearly all products entering the EU market. As a regulation, it is directly applicable in all EU member states. However, it functions as a framework regulation, with detailed product requirements introduced gradually through delegated acts adopted by the European Commission.

The ESPR sets out criteria for prioritising products based on factors such as the product's potential to contribute to EU climate, environmental and energy efficiency objectives, gaps in existing EU law, sales and trade volumes, and value chain impacts.

The Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025–2030, adopted by the Commission in April 2025, confirmed the following priority product groups:

• textiles and apparel,
• furniture,
• mattresses,
• tyres,
• iron and steel,
• aluminium, and
• introduced additional horizontal rules on repairability and recyclability on certain electronics.

Over time, the ESPR regime is expected to cover practically all products placed on the EU market, including components and intermediate products, with only a narrow list of exemptions (such as food, feed, medicinal products, living plants, animals and micro-organisms, products of human origin and certain vehicles). The ESPR requirements cover two aspects: product performance (for example durability, availability of spare parts and minimum recycled content) and product information (for example key product features and the product's carbon/environmental footprint), which will mainly be made available via the digital product passport.

What is the digital product passport?

The digital product passport ("DPP") is the tool the ESPR uses to make its sustainability requirements tangible. Every product for which ecodesign measures are adopted will have a DPP, unless an equivalent alternative digital system is already in place – for example, the energy labelling database that covers products carrying an energy label. The DPP is a digital record, accessed, for example, via a QR code or similar data carrier, that follows a product throughout its value chain and provides information, such as, its materials, origin, carbon footprint, durability, repairability and recyclability. It will open up data access on a need-to-know basis for businesses, consumers and public authorities.

The information to be collected and made available in the DPP will be specified in product-specific delegated acts under the ESPR, and possibly under other legislation where applicable. Information on product qualities and composition will be included, together with information on how the product can be safely used, recycled and disposed of. Having access to this information, it is intended that consumers will be able to make more informed and sustainable purchase decisions based on reliable and clear data.

The DPP will also ensure traceability along the value chain, with implications beyond EU borders. In practice, different actors will gain access to the DPP for different purposes: 

• customs and market surveillance authorities in the EU will use it to monitor compliance,
• consumers to make more informed purchasing decisions, and 
• other participants (such as suppliers and repairers) to access and add to the detailed product information. 

Once implemented, the DPP is intended to become a standard feature of nearly all products entering the EU market, affecting a very large number of manufacturers, importers and distributors, including those based outside the EU.

As for the technical implementation, the European Commission has tasked European standardisation bodies CEN and CENELEC with developing a set of harmonised standards governing the DPP's practicalities, including unique identifiers, data carriers, data exchange, storage, APIs and interoperability (more information on the standards on CEN's website). Six of the planned eight standards have been formally cited in the EU Official Journal in July 2026, while the two remaining standards on data security and authenticity are expected to follow later in 2026. The DPP Registry, the EU's central registry for digital product passports, which will store DPPs and make them discoverable, was also published in July 2026, although companies will only need to register product data once the delegated act applicable to their products takes effect. The DPP Registry can be found on the European Commission's website.

The DPP concept is not only limited to the ESPR regime. Under Regulation (EU) 2023/1542 concerning batteries and waste batteries, in force since August 2023, a digital battery passport becomes mandatory from 18 February 2027 for electric vehicle, light-transport and industrial batteries above 2 kWh, and will serve as the first mandatory DPP under EU law and a practical blueprint for how the technical and data-sharing infrastructure will work under the ESPR. It has also been suggested the DPP could in future be used to provide product information required under other EU product legislation.

Textiles among the first priority of finished products

Textiles and apparel sit at the top of the priority list and are among the first finished products to be subject to a delegated act under the ESPR. The textile sector is one of the most resource and emissions-intensive consumption categories in the EU, with high disposal rates of clothing and unsold textiles. The rise of "fast fashion", inexpensive garments designed for short-term use, combined with unnecessarily high production volumes and increase of online sales has driven overconsumption and significant waste, water, land and climate impacts, making textiles a natural early target for the EU's ecodesign and transparency agenda. In the 2025 working plan, textiles were assessed as having high potential to improve product lifetime extension and material efficiency, while reducing impacts on water, waste generation, climate change and energy consumption.

The EU is not alone in this focus: parallel initiatives in the UK and the US reflect a growing global recognition that the textile sector requires greater transparency and accountability worldwide. Footwear, although related, is treated as a separate product category and will be subject to a separate Commission study assessing its potential for improved environmental sustainability under the ESPR.

The textile-specific delegated act is expected to be adopted by the Commission in 2027, with mandatory compliance likely to follow after 18 months. In the meantime, the ESPR already requires large companies (generally, enterprises with 250 or more employees) to report on discarded goods, and the ban on destroying unsold apparel, clothing accessories and footwear entered into force for them on 19 July 2026. The ban will extend to medium-sized enterprises (broadly, those with 50–249 employees) from 2030, while micro and small enterprises are exempted. Going forward, destruction is permitted only in limited cases, such as when items are unsafe or damaged, counterfeit or infringing intellectual property rights, or have been rejected by charities or donation schemes. Companies relying on these exemptions must provide proof and publish annual reports on what they have discarded, and national authorities can impose fines for non-compliance.

If you have any questions, our Technology & Data team will be happy to discuss more.

Curious to learn more? Register to our upcoming event by 27 August

If you are interested in learning more about compliance and data in the context of the textile and fashion industry, please sign up for our event Datan hyödyntäminen muoti- ja tekstiiliteollisuudessa organised in collaboration with the Finnish Fashion Law Association and Ovido Oy. The event will be held in Finnish.

When: Thursday 3 September 2026 | 17:00– 19:30
Where: Krogerus office, Fabianinkatu 9, 00130 Helsinki

Register to the event: Sign up via the following email: muotioikeus@gmail.com (register by 27 August)

The event explores how data can be leveraged in the fashion and textile industries, the opportunities and challenges associated with its effective use, and the implications of new regulation, such as the Ecodesign Regulation and the DPP.