Digital Product Passport Requirements

A Digital Product Passport is a structured, machine-readable record of information about a product, reachable through a data carrier such as a QR code attached to the product, its packaging or its documentation. It is not a document you publish once. It is a data record tied to an identifier that has to stay accurate for as long as the applicable rules require it to remain available.

The passport is a legal instrument of the Ecodesign for Sustainable Products Regulation. What it must contain is decided product group by product group.

That distinction is the single most useful thing to understand about passport requirements. Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation or ESPR, builds the mechanism: identifiers, data carriers, data quality duties, a registry and access rules. The content of a passport for a specific product group, such as furniture, comes from a delegated act adopted later for that group.

The Regulation is already in force, and a number of things are settled by the framework itself rather than left open. These apply horizontally, whichever product group a future act covers.

• The Digital Product Passport itself: a product passport is provided for as an instrument of the Regulation, with its content and requirements set out for each product group in the applicable act.

  Art. 7, Annex III

• The list of product aspects that ecodesign requirements may improve, from durability to expected generation of waste materials.

  Art. 5(1)

• The requirement that a passport be connected to a persistent unique product identifier and made accessible through a data carrier.

  Art. 9, Art. 10

• The requirement that passport data be accurate, complete and up to date, and that data be open and interoperable.

  Art. 9(1), Art. 10(1)

• That the operator placing the product on the market keeps a backup copy of the passport with a passport service provider.

  Art. 10(4)

• A Commission-managed registry storing at least unique identifiers, relevant commodity codes and battery identifiers.

  Art. 13

• That product-specific ecodesign requirements, including passport requirements, are laid down in delegated acts adopted by the Commission.

  Art. 4, Art. 7

Establishing the mechanism is not the same as imposing it on a given product. Until a measure applies to your product group, none of the above creates a passport obligation for your products.

Passport obligations arise for a product group when a relevant ESPR delegated act applies to that group. The framework does not impose a passport on every product by itself, and the position differs from one product group to another, so it is worth checking which measures apply to what you actually place on the market.

The legal progression is straightforward and always runs in the same order:

The third step is where obligations for your products are actually fixed. For furniture, no such delegated act has yet been adopted.

Dates matter, but only some of them are legally fixed. Below, every entry is tagged so an indicative planning date is never read as a deadline.

1. 18 July 2024Adopted

   Regulation (EU) 2024/1781 enters into force, replacing the Ecodesign Directive and establishing the Digital Product Passport as a framework instrument.

   Reg. (EU) 2024/1781

2. April 2025Adopted

   The Commission publishes the ESPR working plan for 2025 to 2030, identifying priority product groups and indicative timing for product-specific measures.

   COM(2025) 187 final

3. 19 July 2026Adopted

   The date by which the Regulation requires the Commission to set up the product passport registry.

   Art. 13, Reg. (EU) 2024/1781

4. 6 August 2026Adopted

   Implementing Regulation (EU) 2026/1778, specifying implementation arrangements for the registry, applies from this date.

   Impl. Reg. (EU) 2026/1778

5. 19 July 2026Adopted

   The prohibition on destroying unsold apparel, clothing accessories and footwear listed in Annex VII begins to apply, with exemptions for micro and small enterprises. Furniture is not listed.

   Art. 25, Annex VII

6. 2028Indicative

   Indicative timing given in the working plan for measures covering furniture, including mattresses, as a second-wave priority group. The delegated act, once adopted, determines the actual obligations and their application date.

   COM(2025) 187 final

7. 19 July 2030Adopted

   The unsold-goods destruction prohibition extends to medium-sized enterprises for the product groups listed in Annex VII.

   Art. 25, Annex VII

Article 5(1) lists sixteen product aspects, from durability to expected generation of waste, that ecodesign requirements may improve where relevant. The actual DPP information derives from Article 7 and Annex III and is specified product group by product group in each delegated act. So the list below is not a set of mandatory passport fields; it is the range of aspects that product-specific measures may address.

• Durability

  Art. 5(1)(a)

• Reliability

  Art. 5(1)(b)

• Reusability

  Art. 5(1)(c)

• Upgradability

  Art. 5(1)(d)

• Reparability

  Art. 5(1)(e)

• Possibility of maintenance and refurbishment

  Art. 5(1)(f)

• Presence of substances of concern

  Art. 5(1)(g)

• Energy use and energy efficiency

  Art. 5(1)(h)

• Water use and water efficiency

  Art. 5(1)(i)

• Resource use and resource efficiency

  Art. 5(1)(j)

• Recycled content

  Art. 5(1)(k)

• Possibility of remanufacturing

  Art. 5(1)(l)

• Recyclability

  Art. 5(1)(m)

• Possibility of recovery of materials

  Art. 5(1)(n)

• Environmental impacts, including carbon and environmental footprint

  Art. 5(1)(o)

• Expected generation of waste materials

  Art. 5(1)(p)

Alongside whatever content is required, every passport is bound to a persistent unique product identifier and made reachable through a data carrier, so the record can be found reliably years after the product was sold.

The technical layer is the most settled part of the framework, because it has to work identically across product groups. These elements are established by the Regulation and supported by harmonised standards.

Two related duties often get missed. The operator placing the product on the market keeps a backup copy of the passport with a passport service provider, and on request it must give dealers and online marketplace providers the data carrier or the unique identifier within five working days. Separately, online marketplaces are required to cooperate with market surveillance authorities and to provide a contact point; they are not made responsible for verifying passport compliance.

Art. 10(3), Art. 10(4), Art. 35

The Regulation requires the Commission to set up a product passport registry by 19 July 2026. The registry stores at least unique identifiers, relevant commodity codes and battery identifiers, and it is managed by the Commission. Implementing Regulation (EU) 2026/1778 specifies implementation arrangements and applies from 6 August 2026.

Beyond what the Regulation and Implementing Regulation (EU) 2026/1778 state, further operational detail of the registry is still being specified. This page does not describe registry architecture, data flows or functionality that current official EU sources do not support.

For furniture, flooring, lighting and interior products, the honest position is that the framework is settled and the product detail is not. The three registers below are deliberately kept apart: what the law establishes, what is still open, and what we recommend as preparation.

These are data readiness practices we believe make future compliance easier, not legal obligations. Our solutions overview shows how the same data is organised in practice.

Established set by Regulation (EU) 2024/1781 or an adopted act. To be determined left to product-specific measures.

Nothing below depends on knowing the final furniture requirements. Each step improves data you will need under any plausible version of them.

1. 01

   Establish a single product data source

   Decide which system holds the authoritative bill of materials and component data. Passport data has to be accurate, complete and up to date, which is difficult when the same product exists differently in three systems.

   Established

2. 02

   Resolve materials and weights

   Map component codes to identified materials with weights. This is the base layer under almost every aspect listed in Article 5(1), whichever of them a future act selects.

   To be determined

3. 03

   Attach documentation to components

   Link supplier declarations, certificates and test reports to the components they describe, so evidence can be produced without a document hunt.

   Established

4. 04

   Decide your identifier strategy

   Passports are linked to persistent unique product identifiers carried on a data carrier. Choose how identifiers are minted and stored before you need thousands of them.

   Established

5. 05

   Keep configuration granularity open

   Because the passport may correspond to a model, batch or item, avoid collapsing configurations that differ materially. Granularity is easy to lose and expensive to rebuild.

   To be determined

6. 06

   Watch the delegated act, not the headlines

   The obligations that will apply to your products come from the delegated act for your product group. Track its consultation and adoption rather than indicative dates.

   To be determined

Logifurn organises the sustainability data furniture and interior manufacturers already hold, in bills of materials, purchase records and supplier certificates, into structured product records that can become passports when the applicable requirements are known.

We do not claim to know the final furniture rules. We build the data foundation that the framework already makes unavoidable: identified materials, resolved weights, linked evidence and stable identifiers. More on the approach in about Logifurn, and practical questions are answered in the FAQ.

• Bill of materials ingestion from any ERP export, mapped to identified materials and weights.
• Component-level evidence, with supplier declarations and certificates linked to what they cover.
• Passport generation with persistent identifiers and data carriers, ready for the requirements that apply.

Every regulatory statement on this page rests on the primary sources below. Where a source does not support a claim, the claim is not made.

• Regulation (EU) 2024/1781

  Ecodesign for Sustainable Products Regulation, in particular Articles 4, 5, 7, 9 to 13, 23 to 27, 35, 65 and Annexes III and VII.

• COM(2025) 187 final

  ESPR and Energy Labelling working plan 2025 to 2030, including priority product groups and indicative timing.

• Implementing Regulation (EU) 2026/1778

  Implementation arrangements for the digital product passport registry, applying from 6 August 2026.

• Implementing Decision (EU) 2026/1736

  Harmonised standards supporting digital product passport technical requirements.

• Delegated Regulation (EU) 2026/296

  Rules relating to the prohibition on the destruction of unsold apparel, clothing accessories and footwear.

• Implementing Regulation (EU) 2026/2

  Disclosure obligations relating to unsold consumer products.

• Regulation (EU) 2023/1115 and Regulation (EU) 2025/2650

  EU Deforestation Regulation and its amendment setting application from 30 December 2026 for large operators and 30 June 2027 for natural persons and micro and small enterprises.

• European Commission, Ecodesign for Sustainable Products Regulation

  Commission information on the Regulation and the Digital Product Passport.

This page is a general information resource, not legal advice. Last reviewed 8 September 2026.