Who needs a Digital Product Passport?

The obligation to have a Digital Product Passport (DPP) depends on the product, not on the size of your company. The EU Ecodesign Regulation (ESPR, Regulation (EU) 2024/1781) applies in principle to almost all physical products placed on the EU market. For each product group, however, the Commission first decides in a separate delegated act whether and which information a passport must contain.

Who is responsible?

• Manufacturers who place products on the EU market.
• Importers who bring products from third countries into the EU: they take over the manufacturer’s obligations.
• Retailers must check that the passport is present and may not pass on products without a passport where one is required.

Which products are exempt?

Under the ESPR, food, feed, medicinal products, living plants and animals and vehicles that are covered by their own rules are among the exemptions. Batteries have their own framework with a separate battery passport under the EU Battery Regulation.

What should you do now?

• Check which product group your products belong to (textiles, furniture, electronics, batteries, other).
• Start collecting data from your suppliers: materials, origin, recycled content.
• Create a first passport and practise the process before the obligation applies.

Whether your specific product is subject to an obligation should be clarified with your chamber of commerce, trade association or legal counsel. DPP Creator is not a substitute for legal advice.