Compliance
The regulatory landscape for Digital Product Passports: EU regulations, timelines, enforcement, and the Regulatory Radar.
With so much information available on Digital Product Passports (DPPs), finding the right information can be a challenge. CoE-DPP has brought together the key topics and linked them to content from official sources and trusted partners. Use the table of contents to quickly find the information you need.
If you can’t find what you’re looking for or you have other questions, please contact us at info@coe-dsc.nl. We’re happy to help you.
Regulations overview
Multiple EU regulations introduce DPP requirements. The table below summarizes the key ones:
| Regulation | Scope | DPP relevance | Status |
|---|---|---|---|
| ESPR (2024/1781) | Broad — all products via delegated acts | Core DPP framework | In force |
| Battery Regulation (2023/1542) | Batteries | Battery passport from Feb 2027 | In force |
| CPR (2024/3110) | Construction products | Separate DPP track | In force |
| PPWR (2025/40) | Packaging | Packaging information linked to DPP | In force |
| Toys Safety (2025/2509) | Toys | DPP provisions for toys | In force |
| Detergents (2026/405) | Detergents & surfactants | Digital labeling & DPP | In force |
| Green Claims Directive | All products with environmental claims | Requirements for substantiating green claims in DPP | Ongoing |
| ECGT (2024/825) | Consumer-facing products | Rules on communicating green claims to consumers | In force |
ESPR — The core framework
The Ecodesign for Sustainable Products Regulation (ESPR) is the primary regulation establishing the DPP. Key provisions:
- Art. 8–12: DPP requirements, responsibilities of economic operators
- Art. 2: Definitions (economic operator, product, substantial modification)
- Art. 30: Online marketplace obligations
- Art. 59–72: Market surveillance and enforcement
- Art. 77–78: EU DPP Registry
The ESPR itself does not define specific data requirements per product — these come via delegated acts for each product group.
ESPR Work Programme 2025–2030
The Work Programme sets the priority order for product groups receiving delegated acts with DPP requirements:
Priority product groups:
- Iron and steel
- Aluminium
- Textiles (apparel, footwear, accessories)
- Furniture
- Tyres
- Detergents and surfactants
- Paints and varnishes
- Lubricants and greases
- Chemicals
- ICT equipment (servers, data storage)
- Electronic displays
- Photovoltaic panels
- Electric motors
- Batteries (industrial, EV)
- Toys
Battery Regulation — First mandatory DPP
The Battery Regulation (2023/1542) is the first EU regulation with a mandatory DPP:
- February 2027: Battery passport required for industrial batteries > 2 kWh and EV batteries
- February 2028: Extended to all batteries
- Requires item-level DPP (each individual battery)
- Detailed data requirements including state of health, charging history, and material composition
Construction Products Regulation (CPR)
The CPR (2024/3110) establishes a separate DPP track for construction products, independent from the ESPR. It has its own Work Programme 2026–2029 defining which construction product groups receive specific requirements first.
Regulatory Radar
An interactive timeline visualization of all DPP-relevant regulations, their status, and upcoming milestones.
Key milestones
| Date | Milestone |
|---|---|
| 2024-07-18 | ESPR enters into force |
| 2025-01-09 | CPR enters into force |
| 2025-04-16 | ESPR Work Programme 2025–2030 published |
| 2027-02-18 | Battery passport mandatory (industrial + EV > 2 kWh) |
| 2027–2028 | First ESPR delegated acts expected (iron & steel, textiles) |
| 2028-02-18 | Battery passport mandatory for all batteries |
| 2030 | End of ESPR Work Programme first phase |
See the full Regulatory Radar data for a machine-readable version.
Green Claims Directive
The Green Claims Directive (proposal) sets requirements for how companies substantiate and communicate environmental claims. It is directly relevant to DPP because:
- Environmental claims made in or linked to a DPP must be substantiated according to a defined methodology
- It will govern what product-level sustainability claims are permissible
- Once adopted, it will work alongside the ECGT to regulate green marketing across the EU
The directive is still under negotiation and is expected to cover requirements that overlap with DPP data on environmental performance.
Empowering Consumers for the Green Transition (ECGT)
The Directive on Empowering Consumers for the Green Transition (2024/825), also known as “EmpCo”, amends the Unfair Commercial Practices Directive and the Consumer Rights Directive. It is relevant to DPP because:
- It bans generic environmental claims (e.g. “eco-friendly”, “green”) unless substantiated
- It prohibits sustainability labels not based on a certification scheme or established by public authorities
- It requires information about durability and repairability to be provided to consumers — data that aligns with DPP content
Member states must transpose the directive by March 2026, with application from September 2026.
Dutch context
National implementation
The Netherlands implements EU DPP regulations through national legislation. The Dutch Ministry of Economic Affairs (EZK) coordinates policy. CoE-DPP, funded by EZK, supports implementation.
Enforcement in the Netherlands
| Authority | Role |
|---|---|
| ILT (Inspectie Leefomgeving en Transport) | Environmental regulation enforcement |
| NVWA (Nederlandse Voedsel- en Warenautoriteit) | Product safety for consumer goods |
| ACM (Autoriteit Consument & Markt) | Consumer protection, market competition |
| Douane | Customs enforcement for imported products |
Supervision and enforcement
Under the ESPR, market surveillance authorities can:
- Request DPP data from economic operators
- Access non-public DPP information (reserved for authorities)
- Order products with non-compliant or missing DPPs to be removed from the market
- Impose penalties for non-compliance
Penalties are determined at national level. The ESPR requires them to be “effective, proportionate and dissuasive.”
Help us improve this page
The DPP landscape is evolving rapidly — regulations change, new standards emerge, and practical experience grows every day. If you notice something on this page that is incorrect, outdated, or incomplete, please let us know.
Your input helps us keep this knowledge hub accurate and useful for everyone in the DPP ecosystem.