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Navigating the Digital
Product Passport:
What are Your
Compliance Obligations?
18 June, 2025
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Meet the Team
Dila Sen, Michelle Walsh, Andrew O'Neill, Orlaith Morris
Regulatory Senior Team Leader - Regulatory Content Marketing
Compliance Specialist Global Regulatory Compliance Specialist Manager, Compliance
Compliance Team & Risks
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Your Battery's EU
Travel Permit
Unpacking the Digital Product Passport
EU Batteries & Waste Batteries Regulation
2023/1542
• Repeals the existing Battery Directive
(2006/66/EC) as of 18 August 2025
• The first EU law to address entire battery life
cycle.
• Aims for a circular, carbon-smart battery
industry: sustainable materials sourcing,
durability, performance labeling, and recycling
targets.
EU Batteries & Waste Batteries Regulation
2023/1542
Who is Responsible?
Economic operators - natural or legal persons involved in making
batteries available or putting them into service in EU.
• Manufacturer
Key Definitions:
• Supplier of Battery Cells/Modules
Placing on the market: First
• Authorized Representative (written mandate)
supply for distribution or use in
• Importer
the EU
• Distributor
Putting into service: First actual
• Fulfilment Service Provider
use in the EU
EU Batteries & Waste Batteries
Regulation 2023/1542
Covers all battery types as products and batteries in products
under one law.
Applies to ALL batteries on the EU market or putting into service:
• Portable
• Starting, Lighting & Ignition (SLI)
• Light Means of Transport (LMT)
• Electric Vehicle (EV)
• Industrial
Note: Military/Space applications are exempt.
EU Batteries & Waste Batteries Regulation
2023/1542
Battery Passport (Article 77)
• Unique electronic record
• Functions as a digital certificate of conformity and
transparency
• From 18 February 2027
• Access Mechanism: Permanent QR Code
EU Batteries & Waste Batteries Regulation
2023/1542
Scope of the Application
● A full DPP is mandatory from 18 February 2027, for the following
categories:
o Electric Vehicle (EV) Batteries
o Light Means of Transport (LMT) Batteries
o Industrial Batteries > 2 kWh
● Other Categories (Portable & SLI Batteries): Do not require a full DPP
but must still have a QR code linking to a more limited set of general
and end-of-life information.
EU Batteries & Waste Batteries Regulation
2023/1542
Data Requirements & Access Tiers
• Publicly Accessible Information:
o General Info
o Key Declarations
• Restricted Access (Owners, Repairers, Remanufacturers):
o Operational Data
o Service Information
• Confidential Data (Notified Bodies & Authorities):
o Compliance Verification
o Technical Substantiation
EU Batteries & Waste Batteries Regulation
2023/1542
Who is Responsible?
• If the battery placed on the market offline or if online but the
online seller is established in the EU and it is placed on the
market from inside the EU
• If the battery placed on market is from outside the EU
• If the online seller is not established in the EU and the battery is
marketed to EU customers
• If the online seller is not established in the EU and the battery is
marketed to non-EU customers
EU Batteries & Waste Batteries Regulation
2023/1542
Transfer of Responsibility: A Critical Legal Shift
The Foundational Principle: The economic operator who initially places the
battery on the market BUT there are two scenarios where this legal
responsibility must be transferred:
Case 1: Placing a Second-Life Battery on the Market
Case 2: Take-over of an Unused Battery
EU Batteries & Waste Batteries Regulation
2023/1542
The Compliance Timeline
• IMMEDIATE PRIORITY: August 18, 2025
o Supply Chain Due Diligence policies must be operational and third-party verified.
• NEXT UP: February 18, 2026
o Carbon Footprint Declaration for rechargeable industrial batteries >2kWh is required.
• GET READY: August 18, 2026
o New physical Labeling Requirements apply, including CE marking.
• GO-LIVE: February 18, 2027
o The Digital Product Passport must be live and accessible for all specified battery
categories.
EU Batteries & Waste Batteries Regulation
2023/1542
Conclusion: Preparing for the Future of Product Regulation
● Act Now: Prioritize due diligence and carbon footprinting immediately.
● Integrate: This is a cross-functional challenge for legal, procurement, IT,
and sustainability teams.
● Innovate: Leverage the DPP as a driver for digital transformation and a
tool for competitive advantage.
● The Blueprint: The Battery Passport is the pilot program for the EU's
broader Ecodesign for Sustainable Products Regulation (ESPR).
ESPR
EU Ecodesign for Sustainable Products
Regulation
Regulatory Framework to make sustainable products the norm
across all products placed on the EU market (18 July 2024)
Performance Requirements:
• Circular Economy: durability, reusability, upgradability,
repairability, recyclability etc.
• Energy, Water Use & Resource efficiency
• Minimum Recycled Content
• Carbon and Environmental Footprint
• Remove worst performing products from the market
• Delegated Acts - Date of application: 18 months after EIF (Art. 4(4)
Digital Product Passport
• Product Performance: Repairability or durability score, carbon
or environmental footprint based on classes
• Unique identifiers for product, operator, and facility
• Information on installation, use, and repair (durability)
• Data for end-of-life treatment operators
• Details on Substances of Concern
• Declaration of conformity
• Manufacturer/importer information
• DPP Service Provider hosting a back up of the copy of DPP
Transparency across Value Chain
Different access rights to information in the DPP
Customers, manufacturers, importers and
distributors, dealers, repairers, refurbishers,
remanufacturers, recyclers,and competent national
authorities
Deadline - 19 July 2026: EU Commission to set up
Digital registry to store unique identifiers
EU Commission: Web portal to search information
included in the DPP.
DPP Standards
Contained in a Data carrier on or in the product, its packaging or on documentation
accompanying the product.
Harmonised standards to be developed by CEN/CENELEC by end of 2025:
• Unique identifiers,
• Data carriers;
• Access rights management and business confidentiality,
• interoperability, data processing,
• data storage, archiving, data authentication, and
• Application Programming Interfaces (APIs) for the product passport lifecycle
management
DPP Standards Development
CEN/CENELEC:
• Actively engaging with National Standard Body (for
example German Institute for Standardization (DIN))
UNECE/ISO Joint Initiative Development of International
Standard Project:
• "Digital Product Passport - Part 1: Overview and
Fundamental Principles"
• (ISO/PWI 25534-1) (Core principles for developing a
global DPP standard system)
EU ESPR - Priority Products
Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025 - 2030
(published April 2025)
4 New Final Products:
• Textiles/ Apparel (2027); Tyres (2027); Furniture (2028); Mattresses (2029)
2 New Intermediate Product Groups:
• Iron and Steel (2026); Aluminium (2027)
2 Horizontal Measures:
• Repairability (including scoring) (2027)
• Recycled content and recyclability of EEE (2029)
EU ESPR - Priority Products
Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025 - 2030
16 Energy Related Product: (Ecodesign and Energy Label 2026 - 2030)
● 4 New: Low-temperature emitter, EV chargers, Professional Laundry, Prof. dishwashers
● 2026: Low-temperature emitters (energy label), household and professional dishwashers,
household and professional washing machines, Local space heaters (energy label only)
● 2027: Electronic Displays,
● 2028: EV chargers, electric motors, Household refrigeration, refrigeration with direct sales
function,
● 2029: Lighting products
● 2030: Welding equipment, Mobile phones and tablets, Local Space heater (ecodesign),
Tumble dryers, standby and off mode.
Textiles
Timeline for Adoption: 2027
• Excludes Footwear (Sustainability study by end of
2027)
• Scope: JRC study suggested definition: Includes any
product containing at least 80% textile fibres by weight.
• Must work with: Textile Labelling Regulation (currently
under review)
DPP Textiles Study - Parliamentary Research Service (July 2024)
Phase 1: “Minimal & simplified DPP” for textile by 2027
Phase 2: “Advanced DPP” for textile by 2030
Phase 3: “Full circular DPP” for textile by 2033
Tyres
Timeline for Adoption: 2027
• Scope: JRC study suggested definition: Cars tyres,
vans tyres and heavy-duty vehicles tyres
• Currently Regulated: Tyre Labelling Regulation (EU)
2020/740
• Why? Potential to improve recyclability and recycled
content waste management of end-of-life tyres.
Furniture
Timeline for Adoption : 2028
Scope: JRC study suggested definition
• Free-standing or built-in units
• primary function: storage, placement or hanging of items
• surfaces where users can rest, sit, eat, study or work
• For indoor or outdoor use.
Why? Potential to improve resource use, affecting production and
supply of materials
Mattresses
Timeline for Adoption: 2029
• Scope: JRC study suggested definition: Limited
to mattresses for indoor use.
• Why? High potential to improve waste generation,
lifetime extension and material efficiency.
How to Prepare?
Key Sources
Cirpass2 Project:
• Innovation Action project funded by the EU Digital Europe Programme that will be
ongoing until April 2027.
• Project is looking at DPP Functionality in 4 Sectors: Textiles, electrical and
electronic equipment, tyres and construction materials.
Public Consultation:
• EU Commission until 1 July 2025 for service providers who will store and process
DPP data on behalf of responsible economic operators that decide not to provide
these services themselves
Toys
Why Update the Toy Safety Rules?
• Addressing Gaps: EU review found the 2009 Directive had
weaknesses in practice some risks weren’t fully covered
(e.g. certain harmful chemicals, online sales loopholes).
• Health Concerns: New scientific evidence on chemicals
affecting children (e.g. endocrine disruptors) called for
stricter protections.
• Digital Age: Toys have evolved (smart toys, online
marketplaces) – old rules didn’t fully cover cyber security or
internet sales.
• Uniform Enforcement: As a Regulation (not a Directive), the
rules will apply uniformly across all EU countries, improving
compliance and market fairness.
Stronger Chemical Safety Measures
• Ban on Harmful Chemicals: New regulation prohibits endocrine
disruptors and other toxic substances in toys (beyond the earlier
ban on CMRs).
• PFAS & Bisphenols Banned: Per- and polyfluoroalkyl substances
(PFAS) and the most dangerous bisphenol chemicals can no longer
be used in toys
• Allergens & Other Toxins: Fragrance allergens are banned in toys
for young children (under 36 months) and mouth-contact toys
• Stricter limits set for heavy metals and nitrosamines in all toys
• Safety Assessments: Manufacturers must do a thorough chemical
safety evaluation for each toy (considering combined exposure to
multiple chemicals
Introduction of the Digital Product Passport
• Every Toy Gets a Digital Passport: All toys must carry a Digital Product
Passport (DPP) – typically via a QR code on the product/packaging.
• What’s in the DPP: The passport is an electronic record with key info: the toy’s
unique ID, manufacturer details, compliance certificates (CE mark, standards
met), safety warnings, and even an image of the toy.
• Accessible to All: Consumers, customs officers, and regulators can scan the
code to instantly access the toy’s safety and compliance information.
• Why It Matters: The DPP improves traceability – it helps customs and market
inspectors spot non-compliant toys quickly, especially among online imports,
and gives consumers transparent info about the toy’s safety.
Enhanced Enforcement & Online Sales
• Closing Online Loopholes: The new rules apply equally to toys sold online – no more
evading safety checks by selling directly from outside the EU
• Online marketplaces must ensure toys on their platforms comply with EU safety
requirements.
• Marketplaces’ Duties: E-commerce platforms will be legally required to help verify toy
compliance – for example, they must allow display of the CE mark, safety warnings, and
a DPP link/QR code on toy listings before a sale is made.
• Stronger Market Surveillance: National authorities get greater powers to inspect and
remove dangerous toys from the market (offline and online). With the DPP system,
inspectors and customs can more easily identify non-compliant products and stop them
• Fair Competition: These enforcement measures ensure imported toys (often 80% of
our market) meet the same standards as EU-made toys, so compliant businesses are
not undercut by unsafe, cheap imports.
Specific Rules for Digital & Connected Toys
• New Safety Requirements: Smart toys and connected toys (those with digital functions,
internet connectivity, etc.) are explicitly addressed. Manufacturers must ensure these
toys do not pose risks to children’s mental health or cognitive development.
• Privacy & Cybersecurity: Although primarily a toy safety law, it links with digital
regulations – connected toys must be designed with data protection and cybersecurity in
mind (e.g. guarding against hacking or misuse of child data).
• AI and Content: If a toy uses AI or interactive content, it should be age-appropriate and
free from harmful content or bias. The EU’s upcoming AI Act will also apply to high-risk
AI in toys (e.g. those that affect learning or behavior).
• Parental Controls: The new standards encourage features that allow parental
supervision of connected toys (for example, controlling online features or content) to
ensure digital play is safe.
Implications for Manufacturers &
Stakeholders
• Manufacturers: Must reformulate products to remove newly banned
chemicals (e.g. replace PFAS-based materials). Also need to perform
more rigorous testing and documentation
• Compliance & Documentation: Every toy now requires a Digital
Product Passport – companies must set up systems to compile and
maintain this data (and possibly adjust packaging to include QR
codes).
• Importers/Retailers: Importers have to ensure toys from abroad meet
all new criteria and must submit DPP information at EU borders for
customs checks. Retailers (online and offline) must verify that the toys
they sell carry the proper compliance markings and passports.
• Online Marketplaces: Platforms like Amazon or eBay now bear legal
responsibility to vet toy listings for safety compliance.
Timeline for Implementation
• 28 July 2023: European Commission published the proposal for the new Toy Safety
Regulation
• Early 2024: European Parliament and Council reviewed and amended the proposal.
(Parliament adopted its first reading position in March 2024; Council agreed its
position in May 2024).
• 11 June 2025: The regulation is ready for formal adoption, pending final votes
• July or September: Formal adoption and Entry into Force – the Regulation will be
published in the EU Official Journal and become law 20 days later.
• Transition Period (~4.5 years): Industry and authorities have 54 months from entry-
into-force to fully implement the new requirements.
• Existing toys can continue to be sold during this phase, but by spring 2030 all toys on
the EU market must comply with the new Regulation.
• Target: 2030 – full compliance deadline. The old Toy Safety Directive will be
repealed at the end of the transition.
Trends and
Takeaways
Other Key Trends
• DPP: Requirement under new Construction Products Regulation ( declaration
of performance and conformity, safety information and instructions for use).
• DPP Digital Circularity Vehicle Passport:
o Latest draft 11 June.
o Draft Regulation for Circularity of Vehicles (DPP to include parts
containing lead, mercury, cadmium or hexavalent chromium, as well as
a declaration on the % of recycled content).
• China is developing a strategy and development of the DPP.
o China: Draft Standard on the general requirements for DPP.
o China News on plans to launch a "digital Battery ID card”.
Key Takeaways
• Batteries: Implementation of battery passport by 18 February 2027 for LMT, EV and Industrial
battery with >2 kWh.
• EPSR/ Batteries Public Consultation - EU Commission on Requirements for Service
providers (1 July).
• Ecodesign/ Energy Labels: 2026 timeline for adoption of 6 ERP Products:
• ESPR - 2027 Timeline for Adoption for New Products: Textiles, Tyres, Aluminium,
Repairability (horizontal measure).
• Development of Standards for DPP by CEN/Cenelec by end of 2025.
• Toys: Formal adoption/ Entry into Force will probably be approved July or September
depending on outcomes of Plenary sessions.
• Toys: Transition Period (~4.5 years): Industry and authorities have 54 months from entry-
into-force to fully implement the new requirements.
Questions?
Lets Talk
Dila Sen, Michelle Walsh, Andrew O'Neill, Orlaith Morris
Regulatory Senior Team Leader - Regulatory Content Marketing
Compliance Specialist Global Regulatory Compliance Specialist Manager, Compliance
Compliance Team & Risks
