Digital Product Passport

Foundations

Where the digital product passport idea came from

The passport comes from EU recycling and repair policy, not from trade policy. That decides the type of data it carries.

Published . Updated . Checked . Due for review .

The digital product passport comes from European environmental policy. The general passport rules sit in the Ecodesign for Sustainable Products Regulation (ESPR). That law repealed most of an older ecodesign directive.

That origin decides what a passport holds. Expect material, durability and repair data. A delegated act for each product group sets the actual fields, and the European Commission has adopted no such act.

Here is what that costs you if you ignore it. You can buy a passport system to prove that your merino jumper comes from New Zealand. That is the wrong record. Your European buyer will still ask for the conformity documents. A passport does not replace an export certificate.

The passport comes from a recycling and repair agenda

GS1 in Europe, a standards body, calls ESPR a primary part of the European Union circular economy agenda and of the Green Deal. The same page states the objective of becoming the first climate-neutral region by 2050.

Read that as policy context from an industry source. It is not a legal text, and this site has not read a Commission statement of the same words.

The people the passport serves follow from that agenda. A repairer, a recycler and a market surveillance authority each read part of a passport. See who reads a passport and what a digital product passport is.

That agenda also sets the problem the passport must solve. See what problem a passport solves.

The law replaced an older directive, and kept part of it

InstrumentStatus
Directive 2009/125/EC, the older ecodesign directiveRepealed by ESPR. Article 79 keeps some articles and annexes for transitional purposes
Regulation (EU) 2024/1781, the ESPRIn force since 18 July 2024

So the older directive did not lose all effect on that date. An older measure can still reach an energy-related product. See energy-related products.

The older rules set the design, and the passport adds the disclosure

GS1 in Europe says the new framework expands the older ecodesign directive. The same page says the framework gives great attention to better information for consumers.

Warning: the disclosure duty is not automatic. Under ESPR it starts only when the European Commission adopts a delegated act for a product group. As at 14 August 2026 the Commission has adopted no such act for any group. See what law creates the passport.

An ecodesign requirement says what a product must achieve. A passport says what you must disclose about that product.

The product list is a list of material streams

GS1 in Europe quotes the ESPR priority categories in Article 18(5). The quotation names:

  • iron and steel
  • aluminium
  • textiles, in particular garments and footwear
  • furniture, including mattresses
  • tyres
  • detergents
  • paints
  • lubricants
  • chemicals
  • some energy related products
  • information and communication technology products and other electronics

This site has not read that article in the Official Journal, so treat the quotation as a secondary source. See the priority categories.

Read the list as material streams. Each entry names a material, or a product built from one. ESPR excludes food and drink. This site found no passport rule for food anywhere in European Union law. See food and feed are excluded.

The data fields come from ESPR, not from a trade agreement

The data a passport carries depends on the product group. The delegated act for each group sets the actual fields, and no act is adopted. See what a passport holds.

Customs will read part of the record. ESPR Article 15 carries the title "Customs controls relating to the digital product passport". It requires the registration identifier to be given to customs. That article applies only once the registry is operational, and only to a product covered by a delegated act. See market surveillance and customs.

The passport comes from ESPR, and its fields follow that regulation. The New Zealand-EU Free Trade Agreement contains no passport provision.

The agreement also has no dedicated circular economy article. See the NZ-EU Free Trade Agreement. A country of origin mark is separate work. A FernMark licence does not create a passport duty, and it does not replace a passport. See FernMark and provenance.

CIRPASS is consortium work, and it binds nobody

Warning: a consortium paper creates no duty and sets no date. Do not plan against one.

The European Union funded two projects on the passport. CIRPASS-2 followed CIRPASS.

ProjectPartnersNote
CIRPASS31The first project
CIRPASS-249It names 13 lighthouse pilots

CIRPASS-2 names four target value chains: textiles, electrical and electronic equipment, tyres, and construction materials. Those are the same material streams again.

The pilots publish no cost figure, no time figure and no error rate. So this site cannot tell you what a passport costs to build or to run. See what a passport costs.

What this site does not know about the drafting history

Three parts of that history have no source here. This site states them plainly, because a history is easy to invent.

  • No source here names who first proposed the passport.
  • No source here gives the drafting history of the passport articles.
  • No source here says which alternatives the European Commission rejected.

So this page gives none of the three. If a supplier tells you that story, ask for the document behind it.

Plan for material questions, and not for origin evidence

Five practical results follow from a passport that comes from a recycling and repair agenda.

  • Plan for material questions: fibre, alloy, chemistry and recycled content.
  • Do not plan a passport as country of origin evidence.
  • Expect a repairer and a recycler to read your data, not only a buyer.
  • Check your conformity documents separately, because a passport does not replace them.
  • Read a published sector year as an adoption year. See how to read the timeline.

To learn who in New Zealand is affected today, see what this means for New Zealand exporters.