--- title: "A customer asks when we will have a digital product passport" description: "Under the Ecodesign Regulation (EU) 2024/1781, a digital product passport becomes mandatory for a product group only when a delegated act requires it, and such acts normally apply at least 18 months after entry into force. The battery passport under Regulation (EU) 2023/1542 comes first, from 18 February 2027, for LMT, electric vehicle and industrial batteries above 2 kWh. Tell customers which applies to you." type: "problem" url: "https://www.conphora.com/solutions/problem/dpp-preparation/" markdown: "https://www.conphora.com/solutions/problem/dpp-preparation.md" locale: "en" language: "en" updated: "2026-10-04" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/eli/reg/2024/1781/oj" tags: ["BattR", "batteries-electronics"] license: "Free to quote with attribution and a link to the page" --- # A customer asks when we will have a digital product passport Under the Ecodesign Regulation (EU) 2024/1781, a digital product passport becomes mandatory for a product group only when a delegated act requires it, and such acts normally apply at least 18 months after entry into force. The battery passport under Regulation (EU) 2023/1542 comes first, from 18 February 2027, for LMT, electric vehicle and industrial batteries above 2 kWh. Tell customers which applies to you. ## Why this happens The digital product passport is a tool of the Ecodesign Regulation (EU) 2024/1781, not a stand-alone duty. The regulation establishes the passport (Article 1(1)) and lets the Commission set ecodesign requirements by delegated act for product groups (Article 4(1)). Where those information requirements include a passport, products can only be placed on the market or put into service if a passport is available in line with the delegated act, and its data must be accurate, complete and up to date (Article 9(1)). Delegated acts normally apply no earlier than 18 months after their entry into force (Article 4(4)). [1] The delegated act fills in the detail: the data from Annex III, the data carrier and its position, whether the passport is kept per model, batch or item, how it is shown to customers before purchase, who may access and update which data, and how long it remains available, at least the expected lifetime of the product (Article 9(2)). The passport is connected through a data carrier to a persistent unique product identifier, uses open and interoperable standards and may not store customers' personal data without their explicit consent (Article 10(1)). [1] Some preparation is the same for every product group. The economic operator placing the product on the market makes a back-up copy available through a passport service provider (Article 10(4)), gives dealers and online marketplaces a digital copy of the data carrier or identifier within five working days of a request (Article 10(3)), and uploads the unique identifiers to the Commission's registry, which was to be set up by 19 July 2026 and also stores the battery identifiers (Article 13(1) and (4)). Manufacturers and importers check that a passport, including the back-up copy, is available before placing the product on the market (Articles 27(1)(c) and 29(2)(c)). [1] Batteries go first. From 18 February 2027, each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service has a battery passport (Battery Regulation Article 77(1)). It is reached through a QR code, kept accurate by the operator placing the battery on the market, and its unique identifier is uploaded to the registry under Regulation (EU) 2024/1781 (Article 77(3), (4) and (10)). [2] ## How to solve it 1. **Check whether any passport duty applies today** Under the Ecodesign Regulation, the passport is an information requirement set product group by product group in delegated acts; without such an act, there is no passport duty. The Battery Regulation is the exception already in force: from 18 February 2027, LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries need a battery passport. 2. **Follow the delegated acts that concern your products** Each delegated act will set the data, the data carrier and its position, whether the passport is per model, batch or item, who may access and update which data, and how long it stays available. The Commission was to set up the central registry for unique identifiers by 19 July 2026. 3. **Get your identifiers in order** A passport connects through a data carrier to a persistent unique product identifier. Annex III of the Ecodesign Regulation lists the identifiers that may be required, including the GTIN, commodity codes, unique operator and facility identifiers and the importer's EORI number, and points to the ISO/IEC 15459 series. 4. **Gather the compliance data you already hold** Much of the content can come from documents you must have anyway: the declaration of conformity, technical documentation or certificates, user manuals, warnings and safety information, and the details of the responsible economic operator in the Union. Put them in a structured, machine-readable form. 5. **Decide where the passport will be stored** The passport is stored by the economic operator responsible for it or by a digital product passport service provider, and when placing the product on the market you make a back-up copy available through such a provider. A provider may not sell, re-use or process the data beyond its service unless you agree. 6. **Answer the customer from the text** Tell the customer which act covers your product, whether a delegated act exists and from when it applies. Do not promise data fields that are not yet settled. Once a passport applies, dealers and marketplaces can ask you for a digital copy of the data carrier or identifier, which you provide free of charge within five working days. ## What you need to show - **The digital product passport, once a delegated act requires it** — The economic operator placing the product on the market (Regulation (EU) 2024/1781 Articles 9(1) and 27(1)(c)) - **Back-up copy with a digital product passport service provider** — The economic operator placing the product on the market (Regulation (EU) 2024/1781 Article 10(4)) - **Registry upload and unique registration identifier** — The economic operator placing the product on the market (Regulation (EU) 2024/1781 Article 13(4) and (5)) - **Battery passport for LMT, EV and industrial batteries above 2 kWh** — The economic operator placing the battery on the market (Battery Regulation Article 77(1) and (4)) ## If you do nothing - **No passport, no placing on the market** — Where a delegated act requires a passport, products can only be placed on the market or put into service if one is available, and its data must be accurate, complete and up to date (Regulation (EU) 2024/1781 Article 9(1)). - **Fines and exclusion from tenders** — Member States lay down penalties for infringements of the Ecodesign Regulation and must at least be able to impose fines and time-limited exclusion from public procurement procedures (Regulation (EU) 2024/1781 Article 74(1) and (3)). - **The battery passport date is fixed** — From 18 February 2027 each LMT battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the market or put into service shall have a battery passport (Battery Regulation Article 77(1)). ## Questions ### Is there a list of which products need a passport and when? The Ecodesign Regulation sets the framework; the product groups, data and dates come from delegated acts adopted under Article 4, which normally apply no earlier than 18 months after their entry into force (Article 4(4)). ### Is the battery passport the same thing? It is a separate record under the Battery Regulation, but it must be fully interoperable with other digital product passports (Battery Regulation Article 78(a)), and its unique identifier goes into the registry set up under the Ecodesign Regulation (Article 77(10); Regulation (EU) 2024/1781 Article 13(1)). ### Who will be able to see our data? Each delegated act decides which actors have access to which data (Regulation (EU) 2024/1781 Article 9(2)(f)). Access is free of charge for the actors listed in Article 11(b), according to those access rights. ### Must the QR code be on the product itself? The data carrier must be physically present on the product, its packaging or the documentation accompanying it, as the delegated act specifies (Regulation (EU) 2024/1781 Article 10(1)(b)). ### Will customers' personal data end up in the passport? Not without their explicit consent in compliance with Article 6 of the GDPR (Regulation (EU) 2024/1781 Article 10(1)(e)). ## Regulations involved BattR ## Sources 1. [Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products](https://eur-lex.europa.eu/eli/reg/2024/1781/oj) — EUR-Lex, 2026-10-04 2. [Regulation (EU) 2023/1542 concerning batteries and waste batteries (consolidated text of 13 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20260813) — EUR-Lex, 2026-10-04