HCPC Brands EuropeDigital Product Passport & the ESPR — The Bigger Picture
Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR), establishes the Digital Product Passport as a horizontal instrument that applies to a product group once a delegated act for that group requires it, and its own data requirements are set out in Annex III. It is not a single passport duty that already applies to nearly all physical goods. When our Detergents Regulation (EU) 2026/405 article describes a DPP obligation for detergents and end-user surfactants, that obligation arises under the Detergents Regulation itself, not under the ESPR, even though it uses related infrastructure. Digital product passports share technical infrastructure but arise under different legal frameworks: the ESPR, the Batteries Regulation, the Detergents Regulation and the Construction Products Regulation each provide their own basis, scope and timing. Understanding the ESPR helps explain why the DPP requirement looks the way it does, and what else is coming alongside it.
What Exactly Is a Digital Product Passport?
A DPP is a structured, digitally accessible record assigned to a specific product, reached through a data carrier such as a QR code or RFID tag affixed to or included with the product or packaging, as required. Depending on the product category, it typically holds identification data, composition and material information, durability and repairability characteristics, environmental footprint data, and end-of-life or recycling information. The passport is designed to be readable by regulators, recyclers, and - increasingly - procurement systems, without requiring a manual document exchange between parties.
Legal Basis
The ESPR was adopted on 13 June 2024 and has been in force since 18 July 2024, replacing the 2009 Ecodesign Directive, which was limited mainly to energy-related products. The ESPR is deliberately structured as a framework regulation: it does not itself list the specific data a passport must contain for any given product. Instead, it creates the legal obligation, the digital infrastructure, and the enforcement mechanism, while a separate delegated act - adopted by the European Commission for each product category - defines the exact data fields, thresholds, data carrier requirements, and application date for that category.
Scope - Who and What Is Covered
The ESPR applies to nearly all physical goods placed on the EU market, regardless of where they are manufactured. Only a short, explicitly named list of categories is excluded - principally food, feed, medicinal products, and living organisms. Any manufacturer, importer, authorised representative, or (secondarily) distributor and online platform placing a covered product on the EU market falls within scope. Being headquartered outside the EU provides no exemption if the product is sold into the EU market, directly or through an intermediary.
Prioritised Product Categories
Article 18.5 of the ESPR names the first wave of product categories the Commission is required to prioritise for delegated acts. Detergents appear directly on this list, alongside:
- Iron and steel
- Aluminium
- Textiles, particularly garments and footwear
- Furniture, including mattresses
- Tyres
- Detergents
- Paints
- Lubricants
- Chemicals
- Certain energy-related products
- Information and communication technology products and other electronics
HCPC Brands' own service scope centres on cosmetics and Home Care / Personal Care chemical products - so of this list, detergents and chemicals are the categories most directly relevant to our clients. The other categories are included here for context: if a business also handles textiles, furniture, or similar goods, the same underlying ESPR framework will eventually apply to those product lines too, on their own separate timeline.
Timeline - Which Categories Move First
| Category | Legal basis and status |
|---|---|
| Batteries | Own legal basis, not the general ESPR route: Article 77 of Regulation (EU) 2023/1542 requires a battery passport from 18 February 2027 for LMT batteries, electric-vehicle batteries and industrial batteries with a capacity above 2 kWh. Adopted application date. |
| Textiles | Priority group under the ESPR. No delegated act adopted yet, so no application date exists - the Commission working plan foresees measures for textiles and clothing around 2027 as an intended adoption date, not a compliance deadline. |
| Electronics and ICT | Priority group under the ESPR. Energy-related measures are foreseen around 2027 and ICT around 2029 in the working plan; those are intended adoption dates, and Article 18(5) is a prioritisation list rather than a guarantee that every category receives a measure in the first plan. |
| Construction products | Own legal basis: Regulation (EU) 2024/3110, with its own passport route and application mechanism - not the ESPR delegated-act route. |
| Detergents | Own legal basis: Regulation (EU) 2026/405. Adopted application date - main provisions apply from 23 September 2029, with later elements in 2032 and 2034. |
| Other ESPR groups | Indicative planning only - no delegated act adopted and no application date set. |
| Furniture, tyres, and remaining priority categories | Listed as priority categories in the ESPR Working Plan 2025-2030, adopted 16 April 2025. The Working Plan schedules when rules are to be drawn up; application dates follow only from the future delegated acts. |
The working-plan years above concern the intended adoption of future ESPR measures. They say nothing about the battery and detergent dates, which are already fixed in their own regulations, or about construction products, which follow Regulation (EU) 2024/3110. Where a delegated act has been adopted, its own transition period determines from when the requirements apply; we reassess these entries on publication of each act.
The Registry & Technical Standards
The practical infrastructure behind the DPP is already operational ahead of most product-specific deadlines. The EU's central product registry opened on 20 July 2026, with Implementing Regulation (EU) 2026/1778 applying from 6 August 2026 to govern how the registry itself operates. Separately, a first family of European technical standards defining how a passport should be structured and made digitally accessible has been published by CEN-CENELEC during 2026; publication of a standard is not in itself a guarantee that a given passport complies - meaning the technical groundwork for a DPP can reasonably begin before a specific product category's delegated act is even finalised.
Related ESPR Measures Beyond the Passport
The DPP is the ESPR's headline measure, but not its only one. The regulation also introduces a prohibition on destroying unsold products listed in Annex VII - currently clothing, clothing accessories and footwear - subject to the applicable enterprise-size rules and derogations, applying to large companies from 19 July 2026 and to medium-sized companies from 19 July 2030 - and mandatory green public procurement criteria for covered product categories. These sit alongside, rather than replace, the ecodesign performance requirements (durability, repairability, recycled content) that a delegated act can set per category.
How This Connects to Our Detergents Work
The Digital Product Passport requirement described in our Detergents Regulation (EU) 2026/405 article is required by that regulation, not by the ESPR: digital product passports use related infrastructure but arise under different legal frameworks, with batteries following Regulation (EU) 2023/1542 and construction products Regulation (EU) 2024/3110. What they share is the practical layer - the registry, the data-carrier standards and the general infrastructure described above, which a detergent manufacturer's DPP will plug into - while the legal basis, the scope and the category-specific data requirements (formulation categories, biodegradability data, allergen disclosures) come from the Detergents Regulation itself.
Sources
Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for setting ecodesign requirements for sustainable products (ESPR). European Commission, ESPR Working Plan 2025-2030, adopted 16 April 2025.
Frequently Asked Questions
Is the Digital Product Passport specific to detergents?
No. The detergent DPP obligation discussed here arises under Regulation (EU) 2026/405. This does not exclude detergents from the general scope of the ESPR - they are named among the priority groups in Article 18(5) - but specific ESPR product requirements depend on the relevant delegated measures, and none has been adopted for detergents. Batteries follow Regulation (EU) 2023/1542 and construction products Regulation (EU) 2024/3110 on the same logic: a shared framework, separate passport routes. Textiles and the other groups in the Commission working plan follow their own delegated acts and transition periods.
Which product category gets DPP requirements first?
Batteries - though under their own legal basis rather than the general ESPR route: Article 77 of Regulation (EU) 2023/1542 requires a battery passport from 18 February 2027, for LMT batteries, electric-vehicle batteries and industrial batteries above 2 kWh rather than for all batteries. For textiles and other ESPR product groups, timing depends on the relevant delegated acts and their transition periods; the years in the Commission working plan are indicative adoption dates, not mandatory application dates. Construction-product passports follow their own legal framework. Detergents follow the separate Regulation (EU) 2026/405 timeline, whose main provisions apply from 23 September 2029.
Does the ESPR itself list exactly what data a DPP must contain?
No. The ESPR is a framework regulation - it creates the legal obligation and the technical infrastructure (registry, data carrier standards) but leaves the exact data fields, thresholds, and deadlines for each product category to a separate delegated act adopted by the European Commission for that category.
Who is responsible for creating and maintaining a Digital Product Passport?
The manufacturer, by default. Where a manufacturer is established outside the EU, an authorised representative, importer, or fulfilment service provider can become responsible depending on the specific sectoral regulation and the party's role in placing the product on the EU market.
Is there already a live EU system for registering a DPP?
Yes. The EU product registry opened on 20 July 2026, with Implementing Regulation (EU) 2026/1778 applying from 6 August 2026. A first family of European technical standards defining how to build a DPP has been published by CEN-CENELEC during 2026; we identify the individual standards and their catalogue dates per project rather than citing a single publication date. The technical groundwork can therefore begin before a product-specific delegated act is finalised - though publication of a standard is not in itself a guarantee that a given product passport complies.
Back to Knowledge Base, or see our New Detergents Regulation article.
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