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2026.08.16

Digital Product Passport Compliance 2026 for EU Exporters

Digital Product Passport Compliance 2026 for EU Exporters

“We ship parts into the EU, but does the Digital Product Passport actually apply to us?” That question is coming up more and more often at manufacturing sites in Thailand and Vietnam. Everything in the news is about EV batteries, so a company making automotive components or electronic parts has no easy way to work out what will be required of it, or when. This article addresses exactly that. It is not about tracking lots inside the plant. It is about the data that leaves the plant – the information the EU market has started to require that a product carry – and it sets out what is settled today and what you should start working on now.

What is a Digital Product Passport – what the ESPR regulation wants every product to carry

An identity document made of data, travelling with the product

A Digital Product Passport (DPP) is a set of electronic information bound to an individual product. Scan the identifier printed on the product or its packaging and an operator, an authority, and in some cases a consumer inside the EU can see what the product is made of, where it was made, and what environmental burden it carries. That is the basic idea.

The point worth holding onto is that a DPP is not a quality record. Quality records exist so you can explain yourself internally or to a customer when something goes wrong. A DPP is different. It is built from the outset to be disclosed to outsiders, and if you cannot disclose it you cannot place the product on the EU market. The word “traceability” covers both, but storing and disclosing are not the same design problem. You have to hold information in a form you can produce on demand, for readers you cannot name in advance. That single requirement is what separates a DPP from every record a factory has accumulated so far.

Where ESPR sits, and which product categories come first

The legal foundation that makes DPPs mandatory is the ESPR, the Ecodesign for Sustainable Products Regulation. ESPR entered into force in 2024. It is a framework regulation, however. The concrete substance – which information goes on which product, and from when – is set category by category through separate delegated acts.

The priority product categories identified by the European Commission are textiles and apparel, iron and steel, aluminium, tyres, furniture and mattresses. Adoption of these delegated acts is expected to gather pace from 2026 onwards, with actual application commonly expected around 2028 to 2029. Electronic and electrical products are not in this first wave of the delegated act track. They are being handled separately, through horizontal requirements such as repairability and recycled content and through the existing ecodesign framework. Automotive component makers do not fall directly into a listed category and so have no reason to panic, but electronic component makers cannot be described as being on the same clock either, and that difference in position is worth understanding. You can read the timeline as “we have several years”, or you can read it as “if we wait until our own category is confirmed, we will not have time”. Which reading is correct depends entirely on how long you think the data preparation takes, which is the subject of the rest of this article.

July 2026 – the central registry went live

There is a concrete reason 2026 is described as a turning point for the DPP. Article 13 of ESPR obliged the European Commission to set up a central DPP registry – the shared infrastructure for registering, searching and verifying passports – by 19 July 2026. And in fact, that registry went live on 20 July 2026.

This is where misreadings start, so let us separate the two things carefully. The registry going live does not mean that every product needs a DPP as of today. July 2026 is a milestone on the infrastructure side, not a compliance deadline shared by all products. The registry is a container. What gets registered in it, and which products fall in scope from when, is decided individually by the product-specific delegated acts described above.

That said, the container existing is not a small thing. The scheme has moved from a design on paper to a system that actually runs. Something treated internally as “coming one day” is now, on the EU side, live infrastructure. That difference matters directly when you are trying to secure budget and headcount internally.

InstrumentLegal basisScopeTiming
Central DPP registryESPR Article 13Shared infrastructure for registering, searching and verifying passportsRequired to be set up by 19 July 2026, went live on 20 July 2026
Battery passportBattery Regulation (EU) 2023/1542EV and industrial batteries above 2 kWhFrom 18 February 2027, cannot be placed on the EU market without a passport
ESPR DPP for priority categoriesProduct-specific ESPR delegated actsTextiles, steel, aluminium, tyres, furniture and similar (electronic and electrical products handled separately)Delegated act adoption gathering pace from 2026, application expected around 2028 to 2029
Digital Product Passport Compliance 2026 for EU Exporters - figure 1

Battery passport 2027 – the first hard deadline lands on batteries

Scope is EV and industrial batteries above 2 kWh

Within the DPP framework, batteries are the one product with a confirmed deadline. The legal basis is not ESPR but a separate instrument, the Battery Regulation (EU) 2023/1542.

Under that regulation, from 18 February 2027, EV and industrial batteries with a capacity above 2 kWh cannot be placed on the EU market unless they are accompanied by a digital product passport, the battery passport. The date and the scope are already fixed in the text. Unlike the other categories, this is not “someday” – it is a date on the calendar.

The 2 kWh threshold has practical consequences. Scope is not limited to EV traction batteries. Industrial batteries are caught too, as soon as capacity exceeds 2 kWh. Even if you are not a battery maker, if you ship products with batteries built into them, or you supply materials and components into cell or module production, this is not somebody else’s problem.

What information the passport has to carry

The battery passport is accessed by reading a data carrier or unique identifier applied to the product, in practice a QR code. The information it has to carry falls broadly into four groups.

Type of informationWhat is actually being askedWhat the plant needs in order to answer
Raw material originWhich material came from whereA link between supplier and lot
GHG emissionsGreenhouse gas emissions from manufacturingEnergy consumption per process, plus a documented allocation method
Recycled contentHow much recycled material the product containsSegregation by material and a record of input quantities
Lifecycle performancePerformance and durability under stated conditionsDesign values, measured values and test records

Looking at that table, one thing stands out. Three of the four are not in a factory’s conventional quality records. Raw material origin sits in the purchasing system, energy consumption sits in facility management or meter data, and recycled content sits in supplier declarations. Each lives somewhere else. The inspection records held by the quality assurance department will not fill in a passport on their own. That is precisely why treating DPP compliance as “an extension of traceability” will trip you up.

What happens if you are not compliant

The first thing that bites in practice is the border. With the central registry live, customs authorities are described as being able to check whether the required passport has been registered. Missing information, or information that does not match, can lead to additional queries, delays in customs clearance, and restrictions on placing goods on the EU market. On top of that, the Battery Regulation requires member states to lay down penalties that are effective, proportionate and dissuasive.

In practice the penalty amount is the lighter half of the problem. Money can be dealt with after the fact. A shipment stuck at the border hits your delivery date directly. For a European vehicle manufacturer or set maker, a part not arriving means their own line stops. Which is exactly why they come asking their suppliers for data before anyone comes asking them.

The clock runs on the date of placing on the market, not the date of manufacture

There is one point that is easy to miss. What the legal text puts a deadline on is not the moment of manufacture but the moment the product is placed on the market in the EU. So stock manufactured before the deadline, if it is placed on the EU market on or after 18 February 2027, should be read as falling on the passport-required side of the line. Exactly how this plays out in practice will need to be confirmed against future guidance, but planning on the assumption that you can build ahead and slip under the wire is risky.

This feeds straight into production planning and inventory policy. If you hold EU-bound product as long-term stock, the question is whether you can assemble the data for that stock after the fact. Energy consumption and material origin that were never recorded at the time of manufacture cannot realistically be reconstructed just before shipment. The obvious truth that records cannot be created retroactively is what bites here.

Why the battery passport is the template for every DPP that follows

The reason not to dismiss the battery discussion with “we don’t make batteries” is that the battery passport is positioned as the leading example, the template, for DPPs under ESPR generally.

When the European Commission writes delegated acts for textiles, steel, aluminium, tyres or furniture, it will not be designing from scratch. The structure of the battery passport – what goes on it, how it is accessed, who is responsible – is already in law and about to be in operation, and it becomes the precedent. It is therefore reasonable to read the four categories of information demanded for batteries (raw material origin, GHG emissions, recycled content and lifecycle performance) as likely to be asked for in some form in other categories too. Electronic and electrical products are not in the first wave, but the debate around horizontal requirements on repairability and recycled content may well end up resting on the same underlying logic as the battery passport.

Put another way, the battery passport is a trailer for the delegated act that will eventually cover your own category. With no delegated act yet published for your own product category, the battery text is the only concrete clue you have for working out what to prepare.

What actually reaches component makers in Thailand and Vietnam

The party named in the regulation is not the party doing the work

As a rule, EU regulations impose obligations directly on the operator placing the product on the EU market. A factory in Thailand is not going to be penalised directly by an EU authority. If anything, that should worry you more, not less.

The EU-side operator carrying the obligation will ask its own suppliers for whatever it needs to discharge it. The vehicle maker asks the battery maker, the battery maker asks the cell material supplier, and that supplier asks the component plant in Thailand. The party named in the regulation and the party actually producing the data sit at opposite ends of the supply chain. And contractually, a supplier that cannot produce the data will struggle to keep the business. It arrives not as a legal obligation but as a commercial requirement, and that is the real picture for a site in Thailand or Vietnam.

Among Japanese companies exporting to the European market, the number affected by the Battery Regulation is estimated at several hundred, concentrated in electrical and electronic equipment makers and automotive-related firms, and large players such as Toyota and Panasonic are reported to be already working on it. At the same time, the burden on small and medium-sized firms has been flagged as heavy. That gap is less about capital than about whether a company had a run-up period in which to get its data in order.

The three shapes a customer request arrives in

In practice, requests arrive in three forms.

  • As a survey form. A template asking you to fill in materials used, substances contained, suppliers and manufacturing sites. Because it looks like an extension of the green procurement questionnaires you have always received, this is the hardest form to notice.
  • As a contract clause. A new or renewed supply agreement includes an obligation to provide the information needed for regulatory compliance. Refuse it and there is no deal.
  • As a system integration. You are asked to register data per product or per lot on a platform the customer nominates. This is by far the heaviest form, and you cannot comply unless your internal data can be extracted electronically.

The typical sequence is survey form first, then contract clause, then system integration. A plant that is starting to receive survey forms today should assume it is likely to face a system integration request within a few years and begin preparing on that basis.

A parallel regulation – the Euro 7 durability requirements

Not a DPP matter as such, but worth mentioning as a regulation running on a similar timeline, is Euro 7 (Regulation (EU) 2024/1257). It sets durability requirements for traction batteries, applying to new type approvals for passenger cars and light commercial vehicles from 29 November 2026 and to existing types from 29 November 2027.

It has no direct connection to the DPP, but it matters as situational awareness that battery-related demands are arriving from several regulations at the same time. If you handle each incoming survey form individually without first sorting out which regulation it stems from, you will end up rebuilding the same data over and over in different formats.

Companies that are ready, and companies that are not

A 2026 KPMG survey of more than 70 European companies examined DPP readiness across awareness, governance, data readiness, supplier engagement, systems capability and strategic priority. Commentary drawing on that survey notes that many companies still do not have a plan for DPP compliance.

The thing to notice is that this surveyed European companies. If even the parties named in the regulation are not ready, then the requests reaching their Asian suppliers will only arrive once those companies start moving in earnest. The picture is one where the apparent breathing space collapses into an extremely short window between the request arriving and the response being due. The less prepared your customer, the more likely they are to demand a large volume of information right on the deadline.

Digital Product Passport Compliance 2026 for EU Exporters - figure 2

How in-plant traceability differs from a Digital Product Passport

Before turning to what the factory should do, it is worth pinning down the vocabulary. Leave this vague and the internal discussion lands on “we already do traceability, so we’re fine”.

DimensionIn-plant traceabilityDigital Product Passport
PurposeIdentify cause and scope when a defect occursContinuously disclose product attributes to the market
Who reads itYour company, your customer, auditorsEU authorities, trading partners, sometimes consumers
When it is usedWhen something goes wrongAlways. It travels with every unit shipped
Required speedTracing back within days or weeks is acceptableReadable on the spot from the identifier
Main data handledProcess conditions, inspection results, input lotsRaw material origin, GHG emissions, recycled content, performance
Where records liveHeld internally is sufficientMust be referenceable from outside
Where data comes fromMainly your own processesYour processes plus upstream suppliers

The difference concentrates in the last two rows, where records live and where data comes from. A record you only have to store and a record that has to be visible from outside are different designs. And the fact that your own process data cannot fill in the passport is why the extension of in-plant traceability does not get you there. For raw material origin and recycled content, the answers are held by your suppliers, not by you.

This also affects who owns the work internally. In-plant traceability is usually led by quality assurance or production engineering, whereas the information a DPP asks for is scattered across purchasing, facility management, environment and safety, and IT. Put quality assurance alone in charge and the purchasing and facility data will never arrive. In practice the workable arrangement is to keep quality assurance as the point of contact while pulling purchasing and facility management in from the very first inventory exercise. Waiting until a request arrives before assembling the departments burns months on internal coordination alone.

Four kinds of data a factory needs for Digital Product Passport compliance

From here on, the factory side. This article does not cover how to build in-plant traceability itself. How to choose the unit you trace, what the cost breaks down into, and how to prepare for customer audits are all covered in separate articles.

What this article covers is the join between them – which of those records actually leave the factory, and what is missing once you assume they will be disclosed.

Identification – pointing to the exact lot or unit for an outsider

A DPP is bound to a product. The starting point is therefore whether you have an identifier that can point unambiguously at a product for someone outside your company. A lot numbering scheme that works internally does not necessarily mean anything to a customer or an authority.

There are three issues. First, granularity. Is it per unit (serial) or per lot? A product managed by serial, like a battery, and a product managed by lot, like a component, need different granularity. Second, uniqueness. Is the same number in use at another of your plants or on another line? Third, permanence. Change the numbering scheme after shipment and you lose the correspondence with product already in the field.

On the reading side, there is an industry initiative led by GS1 called Sunrise 2027, under which retail point-of-sale systems are to be able to read both one-dimensional barcodes and GS1-compliant two-dimensional codes (GS1 QR, GS1 DataMatrix) by the end of 2027. A two-dimensional code can hold expiry date, batch number, serial number and weight in addition to the GTIN, all in a single code. For a detailed treatment of that topic please see Traceability System Build Cost rather than this article.

Origin – tying raw materials and suppliers to the lot

Raw material origin is asked for consistently across every DPP. The wall a factory hits here is structural – purchasing data and manufacturing data are disconnected.

The purchasing system knows when, from whom, what and how much was bought. The manufacturing system knows when, on which line, and what was made. But “which purchase lot of material went into this product lot” is frequently written in neither. The typical case is a warehouse that operates a first-in-first-out rule at issue but never records which lot was actually consumed.

Without that link, when someone asks about raw material origin the honest answer is “probably this supplier”. In a scheme built on disclosure, “probably” does not pass.

Environment – GHG emissions and recycled content

This is the newest territory in DPP compliance and the one that takes longest to prepare. To answer GHG emissions per product, you have to allocate plant-level energy consumption to individual products on some defensible basis.

Three things are needed.

  • Measurement. Energy consumption visible at process or equipment level, not just as a single plant-wide invoice
  • Allocation. A documented method for deciding how much of the measured consumption is assigned to which product
  • Retention. Records kept for a defined period and at a defined granularity so they can be traced back even after shipment

Recycled content is the same. Unless materials are segregated and input quantities recorded, you cannot answer. And much of this information is held not by you but by your upstream suppliers. Getting your own records in order does not finish the job – that is what makes this area hard.

History – manufacturing conditions and inspection records

Information about lifecycle performance has to be tied not only to design values but to actual manufacturing conditions and inspection results. This is the area that overlaps most with existing quality records, and most factories already hold it in some form.

The problem is the format it is held in. If records live on paper forms or scanned PDFs, they exist as records but cannot be passed electronically to an external system. Since a DPP is premised on disclosure, an operation where a person searches and retypes will not survive at scale. A handful of queries a month is manageable. Something that travels with every unit you ship is a different proposition.

Digital Product Passport Compliance 2026 for EU Exporters - figure 3

How to approach Digital Product Passport compliance – what to do now, what can wait

If your reaction so far is “this is too much”, that is the correct reaction. But you do not have to do all of it now. There is a sensible order in which to start.

Stage 1 – determine whether you are in scope at all

The first task is not evaluating systems, it is determining scope. Answer these questions and the urgency settles itself.

  • Do your EU-bound products go there as direct exports, or via a domestic trading company or customer?
  • Do those products contain a battery? If so, does the capacity exceed 2 kWh?
  • Could your product category fall into an ESPR priority category (textiles, steel, aluminium, tyres, furniture and similar)? Electronic and electrical products are not in this first wave
  • Have you already received survey forms from customers that reference the DPP or ESPR?

If batteries apply to you, the confirmed date of 18 February 2027 becomes your clock. If not, you are in the position of tracking delegated act developments. Buying a system before making this determination is the single most wasteful way to proceed.

Stage 2 – inventory your data and make the gaps visible

Next, tabulate your current state against the four kinds of information a DPP asks for. What you are producing here is not a plan of countermeasures. It is a picture of the present.

InformationWhere it livesFormatLinked to the product lot
Raw material originPurchasing system, delivery notesMix of electronic and paperOften not linked
GHG emissionsElectricity invoices, equipment meter readingsUsually plant-wide onlyNot linked
Recycled contentSupplier declarationsPaper and PDFNot linked
Manufacturing and inspection historyQuality records, daily production reportsMix of electronic and paperUsually linked

Fill this in at a typical factory and three rows will say “not linked”. That is fine. Seeing the gap is the deliverable of this stage. Requesting quotations before you can articulate what is missing gets you proposals built on different assumptions, which cannot be compared.

Stage 3 – design the identifier and unify numbering

Decide the identifier scheme you will expose externally. The reason to lock this down early is that everything downstream is keyed off it. Granularity (unit or lot), the structure of the digits, the mapping to existing internal numbers, and uniqueness across plants. Decide these four and document them.

Finish this design before investing in systems and you can migrate to whichever tool you later choose. Leave identifier design to a vendor and you will find it hard to ever leave that vendor’s product.

Stage 4 – query your upstream suppliers

For the information you cannot fill in yourself, particularly raw material origin and recycled content, start querying your tier-one suppliers. This stage takes time. They are wrestling with the same problem and will not answer immediately.

The workable approach is not to blanket-query every supplier but to narrow to materials used in EU-bound products and start with the largest by value or volume. Run everything at once and your staff time disappears into chasing responses.

Stage 5 – build the mechanism for publishing outward

Last comes the mechanism for supplying the collected data externally. Whether you register on a customer-nominated platform or host your own reference point depends on the shape of the request. Only at this stage does system selection start to mean anything.

What you do not need to do yet

It is equally worth listing what is not urgent right now.

  • Fixing the complete set of data fields in advance while the delegated act for your category is still unadopted. The fields are not settled, so the work may be wasted
  • Bringing every product and every line into scope at once. Starting with EU-bound products is enough
  • Building a consumer-facing display. The first demands will come from customers and authorities

The priority is one thing – start capturing now the data you cannot create later. Identifier assignment and process-level energy measurement cannot be reconstructed retroactively. How you present the data you have collected, by contrast, can always be changed later.

Five common stumbling blocks in EU export traceability data

Finally, the places that cause trouble again and again in practice.

  • The mapping between internal and customer part numbers lives in someone’s head. A cross-reference table maintained in Excel by one specific person means manual work every time you have to disclose
  • First-in-first-out is an operating rule with no record of the lot consumed. The moment someone asks about raw material origin, you have no answer
  • Energy is metered plant-wide only. The minimum decomposition needed to produce per-product GHG figures is not there
  • Records survive on paper and in PDFs. They exist, but they cannot be handed over electronically
  • Supplier declarations are out of date. Old forms sit in the file, no longer matching what you actually buy today

None of these is solved automatically by installing a system. A gap on the operations side stays exactly where it is once you put a system on top of it. The order is to make the gaps visible first, then choose the means of closing them.

Frequently asked questions

What is a Digital Product Passport?

It is a set of electronic information bound to a product, making information such as raw material origin, environmental burden and lifecycle performance verifiable from outside via an identifier. The EU’s ESPR (Ecodesign for Sustainable Products Regulation, in force since 2024) sets the framework, while the specific content and application dates are set by delegated acts per product category. Unlike conventional quality records, which are premised on internal retention, the defining difference is that a DPP is designed from the start to be disclosed externally.

When do products other than batteries come into scope?

Batteries are the only category with a confirmed date today. Under the Battery Regulation (EU) 2023/1542, from 18 February 2027 EV and industrial batteries above 2 kWh cannot be placed on the EU market without a passport. For priority categories such as textiles, steel, aluminium, tyres and furniture, delegated act adoption is expected to gather pace from 2026, with application commonly expected around 2028 to 2029. Electronic and electrical products are not in this first wave and are being discussed separately as horizontal requirements. In any case these are expectations, not confirmed dates. The realistic stance is not to wait for your own category’s delegated act, but to prepare using the battery requirements as your guide.

I heard the registry went live in July 2026. Does that mean we have to comply now?

The central DPP registry was required under ESPR Article 13 to be established by 19 July 2026, and it went live on 20 July 2026. However, the registry going live does not mean a DPP obligation immediately attaches to every product. Which products are in scope, what information is required and when it applies are all determined individually by product-specific delegated acts. The infrastructure existing and an obligation attaching to your company are two separate things.

How much does Digital Product Passport compliance cost?

There is no single benchmark. What it costs depends heavily on how much of your data is already digitised and to what depth. A plant that already links product lots to the materials consumed may only need to add the external publication layer. Starting from paper records with no lot linkage, you first have to build the foundation. Costs are broken down layer by layer in Traceability System Build Cost and we would point you there. We would also suggest completing the data inventory described above before you request quotations. Quotations built on inconsistent assumptions cannot be compared.

We are a tier-two or tier-three supplier, not tier one. Does this still apply to us?

Assume it very likely does. EU regulations impose obligations directly on the operator placing product on the EU market, but that operator will ask its own suppliers for the information it needs to comply. The request travels back up the commercial chain. Even at tier two or tier three, as long as information about your materials and processes forms part of the final product’s passport, the query will reach you. If anything, the further upstream you sit, the later the query arrives and the shorter your response window.

We have received a survey form from a customer. Is this part of DPP compliance?

Quite possibly. It is hard to distinguish because the format resembles the green procurement questionnaires you have always received, but if the questions mention ESPR, the Battery Regulation, recycled content or GHG emissions, it is likely a regulatory compliance query. Recording which regulation each query stems from will reduce the rework of rebuilding the same data in a different format later.

Summary

To pull the threads together.

  • The DPP is a scheme framed by ESPR (in force since 2024), with content and timing set by delegated acts per product category
  • The central registry under ESPR Article 13 was required to be established by 19 July 2026 and went live on 20 July 2026. The registry going live does not, however, create an obligation for every product
  • Batteries are the only category with a confirmed date. Under the Battery Regulation (EU) 2023/1542, from 18 February 2027 EV and industrial batteries above 2 kWh cannot be placed on the EU market without a passport
  • The deadline runs on the date of placing on the market, not the date of manufacture. Planning around building stock ahead of the deadline is risky
  • Non-compliance can lead to additional customs queries, clearance delays and restrictions on market placement. The Battery Regulation requires member states to impose effective and dissuasive penalties
  • The battery passport is positioned as the leading example for other categories, and the four kinds of information it requires – raw material origin, GHG emissions, recycled content and lifecycle performance – are likely to be asked for in some form elsewhere
  • For plants in Thailand and Vietnam, the requirement arrives not as a legal obligation but as a commercial one, through customer survey forms, contract clauses and system integration
  • The order of preparation is to start with the data you cannot create later, namely identifier assignment and process-level energy measurement

The essence of DPP compliance is not accumulating records inside the factory, but holding those records in a form that can leave it. Storage and disclosure are different designs, and the second is not a natural extension of the first. The sooner a plant sees that difference, the shorter its run-up when the customer request finally lands.

Determining whether you are in scope, and taking stock of how far your existing data can actually answer, are both things you can progress before evaluating any system. TOMAS TECH supports Japanese manufacturers across Thailand and ASEAN in building the data foundations of their plants. We are happy to talk at the exploratory stage – “a customer sent us a survey form and we don’t know what to answer”, or “we want to work out whether we are in scope at all”. Get in touch through our contact page and we will take it from there.

References

1. European Commission announcement that the DPP registry is live (20 July 2026)

Primary source for the central registry going live on 20 July 2026. The announcement refers to Ecodesign Regulation (EU) 2024/1781 and also mentions the 18 February 2027 implementation date for certain large batteries.

European Commission Digital Product Passport Registry now live

2. Deadline for establishing the central DPP registry

Source for the European Commission’s obligation to establish the central registry by 19 July 2026. For the fact that it went live, see source 1 above.

EU central DPP registry deadline explained

3. What the registry going live means for exporters and importers

Source for the points that July 2026 is an infrastructure milestone rather than a compliance deadline shared by all products, that customs authorities can check whether the required passport has been registered, and that missing or inconsistent information can lead to additional queries, clearance delays and restrictions on market placement.

Solvira on the EU DPP registry and its impact on exporters and importers

4. Overview of ESPR (Ecodesign for Sustainable Products Regulation)

Source for ESPR entering into force in 2024, for it being the framework that makes DPPs mandatory, and for the expectation that delegated acts on priority categories gather pace from 2026 with application around 2028 to 2029. The priority categories listed in this article draw on this page together with source 5 below. Japanese-language source.

BLUE DOT GREEN commentary on ESPR

5. Commentary on the Digital Product Passport under the ESPR regulation

Source for the basic concept of the DPP, its relationship to ESPR, and the structure whereby product-specific delegated acts determine the required content. Japanese-language source.

EY on the DPP under the ESPR regulation

6. Practical commentary on the digital product passport for batteries

Source for the requirement that EV batteries, and industrial batteries above 2 kWh, placed on the EU market carry a digital passport by 18 February 2027, for the information items covered (raw material origin, GHG emissions, recycled content and lifecycle performance), for penalties having to be effective, proportionate and dissuasive, and for the battery passport serving as the technical template that DPPs under ESPR will follow.

Bluestone PIM Digital Product Passport for batteries

7. Overview of the battery passport scheme

Source for the requirement under Battery Regulation (EU) 2023/1542 that industrial batteries above 2 kWh carry an electronic record from 18 February 2027, and for access being provided through a data carrier or unique identifier.

Battery passport (Wikipedia)

8. The Battery Regulation and its impact on Japanese exporters

Source for the estimate that several hundred Japanese companies exporting to the European market are affected by the Battery Regulation, concentrated in electrical and electronic equipment makers and automotive-related firms, and for large firms such as Toyota and Panasonic progressing while the burden on smaller companies is described as heavy. Note that the framing in this article around sites in Thailand and Vietnam is our own application of that estimate for Japanese companies overall to the local supply chain. The source does not provide a breakdown by production site. Japanese-language source.

rechroma commentary on the Battery Regulation

9. KPMG European Digital Product Passport Readiness Survey (2026, more than 70 European companies)

A survey covering awareness, governance, data readiness, supplier engagement, systems capability and strategic priority in DPP compliance. This article does not quote any specific percentage from it and refers to it only for the point that many companies do not yet have a compliance plan. The second link is a Japanese-language source.

KPMG European Digital Product Passport Readiness Survey

KPMG Japan commentary on EU regulation and the DPP

10. GS1 Sunrise 2027

Source for the industry initiative under which retail point-of-sale systems are to read both one-dimensional barcodes and GS1-compliant two-dimensional codes (GS1 QR, GS1 DataMatrix) by the end of 2027, and for two-dimensional codes being able to carry expiry date, batch number, serial number and weight in addition to the GTIN.

GS1 US Sunrise 2027