Which Products Require an EU Digital Product Passport?

Digital Product Passports are expected to be gradually introduced for a range of product categories in the European Union. In this guide, we explain which products are covered by Digital Product Passport requirements under the Toy Safety Regulation and the Ecodesign for Sustainable Products Regulation (ESPR).

Do all products sold in the EU require a Digital Product Passport?

At the time of writing, Digital Product Passports are not required for all products sold in the European Union.

Digital Product Passports are only required if a product is covered by one or more regulations (including delegated acts) that in turn require the creation of one.

Which products will require a Digital Product Passport?

Currently, there are two EU regulations that contain detailed provisions concerning Digital Product Passports:

Toy Safety Regulation

This regulation is applicable to toys for use in play by children under 14 years. All toys must have a Digital Product Passport.

Ecodesign for Sustainable Products Regulation (ESPR)

This regulation is applicable to, in theory, almost all physical products, including electronics, textiles, and many other categories. That said, the Ecodesign for Sustainable Products Regulation refers to delegated acts that, in turn, determine if a certain product must come with a Digital Product Passport.

Toy Safety Regulation

The Toy Safety Regulation, which replaces the Toy Safety Directive, applies to toys falling within this scope:

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This Regulation applies to products which are designed or intended, whether or not exclusively, for use in play by children under 14 years of age (‘toys’).

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Manufacturers are required to create a Digital Product Passport under the Toy Safety Regulation.

Article 17 states that each Digital Product Passport must correspond to a specific toy model. As such, it is expected that each SKU has its own Digital Product Passport.

The following articles contain detailed information about Digital Product Passport requirements for toys:

• Article 7: Obligations of manufacturers
• Article 17: Digital product passport
• Article 18: Technical design and operation of the digital product passport

Note that the creation of a Digital Product Passport is the responsibility of the toy manufacturer. That being said, importers must verify that the Digital Product Passport is in place before selling imported toys in the EU.

Ecodesign for Sustainable Products Regulation

The Ecodesign for Sustainable Products Regulation (ESPR) sets ecodesign requirements for products that fall within this scope:

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This Regulation applies to any physical goods that are placed on the market or put into service, including components and intermediate products. However, it does not apply to:

(a) food as defined in Article 2 of Regulation (EC) No 178/2002;

(b) feed as defined in Article 3(4) of Regulation (EC) No 178/2002;

(c) medicinal products as defined in Article 1(2) of Directive 2001/83/EC;

(d) veterinary medicinal products as defined in Article 4(1) of Regulation (EU) 2019/6;

(e) living plants, animals and micro-organisms;

(f) products of human origin;

(g) products of plants and animals relating directly to their future reproduction;

(h) vehicles as referred to in Article 2(1) of Regulation (EU) No 167/2013, in Article 2(1) of Regulation (EU) No 168/2013 and in Article 2(1) of Regulation (EU) 2018/858, in respect of those product aspects for which requirements are set under sector-specific Union legislative acts applicable to those vehicles.

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In theory, this means that the Ecodesign for Sustainable Products Regulation can apply to most consumer products, including electronics, textiles, and any other product categories.

The Ecodesign for Sustainable Products Regulation also requires the creation of a Digital Product Passport, under certain conditions:

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Article 9: Digital product passport

The information requirements shall provide that products can only be placed on the market or put into service if a digital product passport is available in accordance with the applicable delegated acts adopted pursuant to Article 4 and with Articles 10 and 11. The data in the digital product passport shall be accurate, complete and up to date.

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As such, the ESPR does not make Digital Product Passports mandatory for all products. Instead, this depends on the requirements in delegated acts applicable to specific products.

What the Ecodesign for Sustainable Products Regulation does in its current form is to establish the general requirements that a Digital Product Passport must comply with. However, the delegated acts:

a. Determine if a product must have a Digital Product Passport

b. Technical and information requirements of the Digital Product Passport

The following articles contain detailed information about Digital Product Passport requirements for toys:

• Article 9: Digital product passport
• Article 10: Requirements for the digital product passport
• Article 11: Technical design and operation of the digital product passport
• Article 12: Unique identifiers

Note: At the time of writing (May 2025), I am not aware of any ESPR delegated acts published in the Official Journal. As such, there is no final list of products for which the Digital Product Passport will be required under the ESPR.

Will the Digital Product Passport eventually be required for all products?

A statement on the European Union data portal claims that the Ecodesign for Sustainable Products Regulation will require “nearly all products sold in the EU to feature a Digital Product Passport (DPP)”.

It is not clear to me, at this moment, if this refers to the broad scope of the ESPR or if they will create delegated acts for nearly all products.

Does the Digital Product Passport format differ for different products?

Yes, this is implied as the Ecodesign for Sustainable Products Regulation refers to delegated acts to provide the specific details. This is a strong indication that the format of the Digital Product Passport will differ depending on the product.

Further, the Toy Safety Regulation already provides a list of Digital Product Passport requirements, which are specific to toys.