DPP glossary: the key terms around the Digital Product Passport

A person or company established in the EU that a manufacturer appoints in writing to carry out defined conformity tasks on its behalf. Where the manufacturer is based outside the EU, there has to be such a contact within the single market – alternatively the importer or a fulfilment service provider takes on that role. The requirement follows from Article 4 of the Market Surveillance Regulation (EU) 2019/1020; without it the product may not be placed on the market.

The Digital Product Passport for batteries under the EU Battery Regulation (EU) 2023/1542. It is mandatory from 18 February 2027 for traction batteries in electric vehicles, industrial batteries above 2 kWh and LMT batteries – e-bike and e-scooter batteries among them. The battery passport does not arise from the ESPR but from a separate set of rules with a key date that is already fixed, which makes it the first binding DPP obligation in the EU.

The marking with which a manufacturer declares, on its own responsibility, that its product complies with all relevant EU legislation. It is not a quality seal and is not awarded by any authority; the manufacturer affixes it itself, on the basis of the declaration of conformity. The Digital Product Passport does not replace the CE marking; the two exist side by side, with the passport making the underlying information accessible.

An economic model that keeps products and materials in circulation for as long as possible – through longer use, repair, reuse and high-quality recycling instead of disposal. It is the declared goal of the ESPR. The Digital Product Passport is not an end in itself but the information instrument: it supplies data to those who are meant to repair, resell or dismantle a product years later.

An EU-funded preparatory project that developed the technical groundwork for the Digital Product Passport: a cross-sector data model, common terminology and implementation roadmaps for electronics, batteries and textiles. It was succeeded in 2024 by CIRPASS-2, a project under the Digital Europe programme running until April 2027 with 13 pilots across four value chains. Important for context: CIRPASS does not set law – its results are preparatory work for standardisation and legislation, not binding in themselves.

The element on the product, its packaging or its accompanying documents that carries the unique product identifier – in practice usually a QR code, alongside Data Matrix or RFID/NFC. The ESPR does not prescribe a particular technology, but it does require the information to be easily accessible by scanning. How data carriers are built and attached to the product is set out in the European standard EN 18220.

The manufacturer's written declaration that a product meets the applicable EU requirements; it names the product, the legal bases, the standards applied and the responsible party. It is the basis for the CE marking and must be produced to market surveillance on request. Under the EU Toy Regulation the Digital Product Passport will take over this function – a model that is being discussed for further product groups.

A legal act that the European Commission adopts itself, on an empowerment given by a regulation, in order to supplement that regulation's framework with technical detail; Parliament and Council can only reject it, no longer amend it. For the product passport this is the decisive lever: only the delegated act for a product group determines what information a passport must contain, in what format and from when. As of September 2026 no such act had been adopted for any of the priority ESPR product groups – textiles, furniture, tyres, mattresses.

The prohibition on destroying unsold consumer products, laid down in Article 25 of the ESPR. Since 19 July 2026 it has applied to large companies and covers unsold clothing, clothing accessories and footwear; medium-sized companies follow on 19 July 2030, and micro and small enterprises are exempt. Narrowly defined exceptions – for damaged, dangerous or counterfeit goods, for instance – remain permissible, but must be documented and evidenced.

Selling without the simultaneous physical presence of seller and buyer – in practice, online and mail-order trade. This matters for the product passport because access to the prescribed information has to exist in the online offer itself, not only after delivery. A QR code that is only stuck on the delivered product is therefore not enough in distance selling.

An economic operator in the supply chain that makes a product available on the market without being the manufacturer or the importer. Distributors do not have to create the product passport, but before offering a product they must check that a required passport exists and is accessible to customers; where they have doubts about conformity, they may not offer the product. Anyone selling third-party goods under their own name or brand, or substantially modifying a product, slides into the manufacturer's role – with its full set of obligations.

A structured, machine-readable data set about a product, retrievable via a data carrier on the product, that brings together information on material, origin, repair, recycling and conformity. It addresses several audiences at once: end customers, retail, repair and recycling businesses, and market surveillance. The passport is not a single document but an infrastructure made up of identifier, data carrier, data storage and query interface.

The product-related specifications that a delegated act under the ESPR can lay down. A distinction is drawn between performance requirements – minimum values for durability, energy efficiency or recycled content, for example – and information requirements, which is where the Digital Product Passport belongs. Products that do not meet the requirements for their group may not be placed on the market in the EU.

The work programme in which the European Commission sets out which product groups it will next develop ecodesign requirements and product passports for. The first working plan under the ESPR was presented in April 2025 and covers the period to 2030; the priorities are textiles and clothing, furniture, tyres and mattresses, plus iron, steel and aluminium as intermediate products. The plan is a statement of intent with dates attached – a requirement only becomes legally binding with the relevant delegated act.

The collective term for every role in the supply chain that can be subject to product law obligations: manufacturer, authorised representative, importer, distributor, fulfilment service provider and providers of online marketplaces. Which obligations apply depends not on the type of company but on the role in the specific transaction – the same company can be a manufacturer for its own brand and merely a distributor for third-party brands. The economic operator registered in the EU DPP registry is always the one placing the product on the market.

The European standard for the data exchange protocols of the Digital Product Passport: it determines the technical routes by which passport data is transferred between systems – the precondition for third-party software being able to query a manufacturer's passport at all. It was developed by the joint committee CEN-CLC/JTC 24; it was published on 27 May 2026 and cited in the Official Journal of the EU on 15 July 2026. It gives its name to the eight-part standards series EN 18216 ff.

The European standard for unique identifiers in the Digital Product Passport – for products, economic operators and locations. It answers the question of how two systems recognise that they are talking about the same product. Published on 27 May 2026, listed in the Official Journal of the EU since 15 July 2026 and thus a harmonised standard.

The European standard for data carriers of the Digital Product Passport: QR code, Data Matrix and RFID/NFC, together with how they are attached to the product. It is the technical substantiation of what the ESPR describes only in general terms as a data carrier. Published on 27 May 2026 and listed in the Official Journal of the EU since 15 July 2026.

The EU ecodesign regulation for sustainable products, Regulation (EU) 2024/1781, in force since 18 July 2024. It replaces the old Ecodesign Directive, covers almost all physical products and creates the framework for ecodesign requirements, the Digital Product Passport and the destruction ban. As a regulation it applies directly in all member states, without national transposing legislation; concrete obligations per product group, however, only arise through delegated acts.

Regulation (EU) 2023/1542 on batteries and waste batteries. It governs sustainability, labelling, take-back and due diligence across the whole life cycle and prescribes the digital battery passport from 18 February 2027. Batteries therefore have their own legal framework, independent of the ESPR – with the advantage that the key date is already fixed and does not depend on a delegated act.

The central registry for Digital Product Passports operated by the European Commission, in service since 20 July 2026; the legal basis is Articles 12 and 13 of the ESPR. Only the unique identifiers of the passports and a few items of metadata are stored there – the passport content stays decentralised, with the company or its service provider. The registry is therefore an index, not a product database: an entry makes a passport findable but says nothing about whether its content is compliant.

Regulation (EU) 2025/2509 on the safety of toys, in force since 1 January 2026 and applicable from 1 August 2030; until then toys may still be placed on the market under the previous Toy Safety Directive 2009/48/EC. For toys the product passport comes not via the ESPR but via this separate set of rules. The particular feature: there the passport replaces the previous EU declaration of conformity, so it is not merely an additional obligation but a precondition for market access.

A company that handles warehousing, packaging, addressing or dispatch of goods without owning them. Where the manufacturer is based outside the EU and there is neither an importer nor an authorised representative, the fulfilment service provider can become the responsible economic operator under Article 4 of the Market Surveillance Regulation (EU) 2019/1020 – with the obligations towards market surveillance that go with it.

A standard that determines how a GS1 identifier such as the GTIN becomes an ordinary web address that can be opened in a browser – for example https://example.org/01/09506000134369. The QR code then carries only that string; a resolver decides which target is served depending on the request. For the product passport the standard is widely used but not prescribed: what is required are data carriers and identifiers according to international standards, not a particular provider.

The globally unique article number behind every classic barcode, issued through the GS1 organisations. It identifies an article at model level; batch, serial number or best-before date are added as further attributes where needed. For the product passport the GTIN is a possible building block of the unique product identifier, but is not the same thing as it.

A European standard developed on a standardisation request from the European Commission and whose reference has subsequently been published in the Official Journal of the EU. Only that citation turns a technical standard into a harmonised standard and triggers the presumption of conformity. Applying it remains voluntary: only the law is binding; the standard is the route to it recognised by the EU – not the only permissible one.

A legal act of the European Commission that creates no new obligations but ensures that existing requirements are applied uniformly in all member states – formats, procedures or lists of references, for instance. Unlike with a delegated act, the member states take part in drafting it through committees. One example from the DPP field: Implementing Decision (EU) 2026/1736 of 14 July 2026 cited the first six DPP standards in the Official Journal of the EU.

An economic operator established in the EU that places a product from a third country on the single market for the first time. It must check that the manufacturer has met the conformity requirements, and in practice steps into the manufacturer's obligations where the latter is based outside the EU. If it sells the goods under its own name or brand, it counts as the manufacturer in law.

Under the EU Battery Regulation, a sealed battery of no more than 25 kg specifically designed to power wheeled vehicles that can be propelled by an electric motor alone or by a combination of motor and human power – typically e-bikes, e-scooters and e-mopeds. Starter, traction and industrial batteries are expressly excluded. LMT batteries are subject to the battery passport obligation from 18 February 2027; for many bicycle and micromobility brands that is the first binding DPP key date of any kind.

In product law, not whoever produces something but whoever places a product on the EU single market for the first time under their own name or brand. Own-brand and private-label goods therefore make pure retail businesses manufacturers too, even where production lies entirely with a contract manufacturer. The manufacturer must create the product passport, keep it up to date and answer for the accuracy of its content – the fact that the data comes from a supplier does not relieve it of that towards market surveillance.

The checking by national authorities of whether products on the single market meet the applicable requirements; the powers are set out in the Market Surveillance Regulation (EU) 2019/1020. The authorities can request documents, order tests and go as far as a sales ban and a recall. In Germany responsibility lies with the authorities of the federal states; the specific penalties are set by the member states and must be effective, proportionate and dissuasive.

The first making available of an individual product on the EU single market. This moment is the point of reference for almost all product obligations: what counts is which rules applied at the time of placing on the market – not when the product was manufactured or sold to the end customer. Every further handover in the supply chain is merely making available on the market and triggers no new passport obligation.

The EU packaging regulation (EU) 2025/40, in force since 11 February 2025 and generally applicable since 12 August 2026. It replaces Packaging Directive 94/62/EC and governs design, substance content, labelling, reusability and recyclability of packaging. Its labelling obligations concern the packaging, not the product: a Digital Product Passport under the ESPR is expressly not the PPWR labelling, though one article may end up carrying both.

The legal consequence that, where a harmonised standard listed in the Official Journal of the EU is applied, the corresponding requirements of the underlying legal act are deemed to be met. In practice this reverses the burden of proof: the company does not have to demonstrate its conformity; the authority would have to demonstrate the opposite. Anyone choosing a different technical route may do so – but then carries the burden of proof themselves, which is as a rule the more laborious path.

A set of products with a comparable purpose or similar technical properties, for which the European Commission lays down common requirements – textiles, furniture or tyres, for example. The ESPR does not regulate across the board but product group by product group: the mandatory information, format and key date of the product passport always follow from the delegated act for the group concerned. The first practical question for every company is therefore which group its range falls into.

A two-dimensional barcode, in practice the most common data carrier for the Digital Product Passport. It does not store the product data itself, only a string – usually a web address through which the passport is retrieved. What matters is therefore less the code than the question of which domain it contains and who controls it: that determines whether printed labels survive a change of provider.

The share of secondary material from recycling in the total material of a product, usually stated as a percentage by mass. The ESPR can prescribe minimum shares per product group; in the first ecodesign working plan recycled content is foreseen as a horizontal requirement. The figure can only be substantiated with evidence from the supply chain – which makes it one of the more laborious data points of a product passport.

The extent to which a product can be repaired with reasonable effort – influenced by ease of disassembly, the availability and price of spare parts, and accessible repair instructions. The ESPR can prescribe both performance and information requirements on this; the first working plan foresees horizontal repairability requirements for electronics among others. Repair information is one of the typical contents of a product passport.

A service that receives the address stored in the data carrier and decides where the request is forwarded. This allows a single printed QR code to serve different targets depending on the request – product passport for end customers, master data for retail, disassembly instructions for recycling. The resolver is usually operated by the DPP software in use; who owns the domain used determines how easily providers can be changed later.

Companies below the thresholds of EU Recommendation 2003/361/EC: fewer than 250 employees and no more than EUR 50 million annual turnover or EUR 43 million annual balance sheet total. There is no general exemption from the DPP obligation for them – the obligation attaches to placing on the market, not to company size. The ESPR does, however, provide for support measures and in part longer deadlines for SMEs; micro and small enterprises are expressly exempt from the destruction ban.

Substances whose presence in a product should be traceable, so that repair and recycling do not fail because of unknown ingredients. The ESPR defines the term more broadly than chemicals law: as well as the substances of very high concern on the REACH candidate list (SVHC), it covers substances in certain hazard classes and substances that hamper reuse and recycling. What a product passport actually has to state about them is determined by the delegated act for the product group concerned – for the priority ESPR groups it is still outstanding.

The chain of businesses through which raw materials, intermediate products and finished goods pass to the party placing them on the market. For the product passport it is the real bottleneck: material composition, origin and certificates usually sit with an upstream supplier, not in-house. Obtaining that evidence takes considerably longer, in experience, than the technical implementation of the passport – it is the reason why preparation times of 6 to 18 months are realistic.

The ability to follow the origin, processing steps and whereabouts of a product or its materials. The product passport makes traceability technically retrievable through the unique identifier, but does not create it: the data has to be collected and evidenced in the supply chain beforehand. How deep the chain has to be documented depends on the delegated act for the product group concerned.

The period between the adoption of a requirement and the day from which it actually has to be applied. For ESPR product groups there are as a rule 18 months between adoption of the delegated act and the binding DPP obligation. This period is the reason why the years named in timelines and a company's own key date are rarely identical – and why dates shift as soon as a legal act arrives later than planned.

A unique string that identifies exactly one model, batch or item and provides access to its product passport. It is to be distinguished from the operator identifier and the facility identifier, which the ESPR also knows. How such identifiers are built, assigned and referenced is governed by the European standard EN 18219; at which level – model, batch or item – marking has to take place follows from the legal act for the product group concerned.