Question 1

Which EU regulation actually creates the Digital Product Passport?

Accepted Answer

The Ecodesign for Sustainable Products Regulation (EU) 2024/1781. It is a framework regulation: it establishes the passport as an instrument and then introduces it product group by product group through delegated acts, each specifying the fields that group must carry and when the requirement takes effect.

Question 2

What is a delegated act, and why does it matter so much here?

Accepted Answer

A delegated act is secondary legislation adopted by the Commission under powers the framework regulation grants. Under the ESPR each one covers a product group and sets its requirements. It matters because your obligation is defined by your group’s act, not by the framework — and until that act exists, the field list is not final.

Question 3

How long do we get once our delegated act is adopted?

Accepted Answer

Roughly eighteen months, though the exact transition period is set in each act. That sounds generous until you consider that collecting attributable evidence from tier-two and tier-three suppliers routinely takes longer, which is why programmes that start after adoption tend to arrive late.

Question 4

Does this apply to companies outside the EU?

Accepted Answer

It applies to products placed on the EU market, regardless of where the company is established or where the product was made. A manufacturer outside the EU supplying an EU brand is typically the party holding the data the passport needs, which is why non-EU suppliers are drawn into these programmes early.

Question 5

What happens if a product does not have a compliant passport?

Accepted Answer

It cannot lawfully be placed on the EU market. Enforcement sits with national market surveillance authorities, which can require corrective action, restrict availability or withdraw a product. Penalties are set by member states, so the consequences of non-compliance vary by country while the obligation does not.

Question 6

Do these five regulations ask for different data?

Accepted Answer

They ask different questions of the same underlying product record. Composition, origin, footprint and end-of-life appear in several of them under different names and reporting formats. Collecting once against a standards-based model and projecting into each format is what turns five programmes into one.

法律文件	What it requires	When it applies
ESPR (EU) 2024/1781	A Digital Product Passport per product group, defined by delegated acts, plus ecodesign requirements	Framework in force; passports phased 2026–2030 per group
Battery Regulation (EU) 2023/1542	A battery passport for LMT, EV and industrial batteries above 2 kWh, with due diligence and recycled content	Battery passport from February 2027
CSRD (EU) 2022/2464	Audited sustainability disclosure under the ESRS, including value chain information	Phased by company size and listing status; in force
EUDR (EU) 2023/1115	Deforestation-free due diligence with plot-level geolocation for relevant commodities	已生效
PPWR (EU) 2025/40	Packaging recyclability grades and minimum recycled content, with format restrictions	分阶段

五项法规，一份产品记录

欧盟何时要求提供数字产品护照？

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EUDR (EU) 2023/1115

CSRD (EU) 2022/2464

ESPR (EU) 2024/1781

电池法规 (EU) 2023/1542

ESPR 授权法案

每一个各自需要什么

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电池与电动汽车

纺织与服装

电子产品与信息通信技术

家具与木材

化妆品与包装

其余全部

常见问题

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