Marko sells e-bikes, cordless power tools, and a growing line of portable power stations through his PrestaShop store, mostly to buyers in Germany, Austria, and the Netherlands. In May, one of his B2B distributors sent a supplier questionnaire that included a section titled "Battery Passport Readiness — 2027." Marko had heard of the Digital Product Passport in passing, filed under "future EU stuff," and hadn't looked closely. The distributor wanted answers this quarter.
That's a fairly common way to first encounter DPP obligations: not through a government notice, but through a business partner further up or down the chain who's already preparing. It's worth understanding what's actually confirmed, what's still taking shape, and what a merchant selling through PrestaShop needs to start doing regardless of which product category is affected first.
What a Digital Product Passport actually contains
A DPP isn't a single document — it's a structured, machine-readable dataset tied to a specific product (or product model/batch, depending on the category), accessible via a scannable identifier such as a QR code or NFC tag. Depending on the product group, it can include material composition, origin, carbon footprint, durability and repairability scores, recycled content percentage, and end-of-life handling instructions. The point isn't paperwork for its own sake — it's meant to let recyclers, repairers, regulators, and eventually customers pull consistent data about a product without contacting the manufacturer directly.
For an online retailer, the practical question isn't "what's a passport" — it's who populates yours, and where that data shows up on your product pages.
The legal engine: ESPR and its delegated acts
The Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781) is the framework that creates the DPP concept EU-wide. Crucially, ESPR itself doesn't set passport requirements for every product category on a single date — it authorises the European Commission to adopt delegated acts, category by category, each specifying its own data fields, verification requirements, and start date. That's why you'll see conflicting "the DPP starts in [year]" claims online: there isn't one start date, there are many, staggered over the rest of this decade and beyond.
Batteries go first — and this date is real, not predicted
Batteries are the exception to the "still being worked out" pattern. Under the separate Batteries Regulation (Regulation (EU) 2023/1542), the battery passport obligation applies from 18 February 2027 for industrial batteries, EV batteries, and LMT (light means of transport) batteries above a defined capacity threshold. If you sell e-bikes, power tools, scooters, or portable power stations, this is the one date on this list you can put in a supplier contract with confidence.
Which categories are next — and how confident we can be
Textiles and electronics are widely flagged in ESPR's working plan as priority categories for future delegated acts, alongside furniture and certain building products. Treat that as an informed prediction: the direction is well signalled by the Commission's own priority lists, but specific dates for these categories haven't been locked in with the same certainty as the battery passport. If you sell clothing, footwear, or consumer electronics, it's reasonable to start preparing data infrastructure now — but don't commit to a specific compliance deadline in a customer contract for these categories yet.
Who supplies the data, and who's liable if it's wrong
This is where merchants often assume it's someone else's problem. In practice, "economic operators" — a category that includes manufacturers, importers, and in some structures distributors and retailers — can each carry obligations depending on their role in getting a product to an EU customer. If you import white-label products and rebrand them, you may be treated as the manufacturer for regulatory purposes, which shifts liability for passport accuracy onto you, not your factory. This mirrors how GPSR already treats "responsible person" obligations for product safety — it's worth reviewing that overlap now rather than treating each regulation as a separate silo.
Building the data pipeline before the regulation forces it
The merchants who'll handle this smoothly aren't the ones who wait for a fixed deadline — they're the ones who start asking suppliers for structured data today, even informally. A few concrete moves:
- Add a "sustainability data" section to your supplier onboarding questionnaire, covering material composition, recycled content, and carbon figures where available.
- Store this data in structured fields (custom product features in PrestaShop, or a dedicated PIM if your catalogue is large) rather than buried in PDF spec sheets.
- Pilot a QR code linking to a basic product data page for one category — batteries, if you sell them — so the publishing workflow exists before it's mandatory.
- Loop in whoever manages your GPSR safety documentation, since the "responsible person" and traceability logic overlaps heavily with DPP obligations.
Our companion guide on PrestaShop-specific DPP implementation covers the module and product-field side of this in more detail if you're ready to build now rather than plan.
Preparation checklist
- [ ] Identify SKUs containing batteries covered by the 18 Feb 2027 deadline
- [ ] Request structured sustainability data from suppliers, not just PDFs
- [ ] Confirm your role (manufacturer/importer/distributor) for liability purposes
- [ ] Set up structured product data fields ahead of mandatory QR requirements
- [ ] Cross-reference with existing GPSR responsible-person documentation
Common mistakes merchants make early
The most frequent one is treating DPP as a labelling project rather than a data project — ordering new packaging with a QR code before the underlying dataset exists to link to. The second is assuming the battery passport date applies to unrelated categories, which causes some merchants to either panic unnecessarily about textiles or, worse, assume "2027" covers everything and miss category-specific deadlines that arrive earlier or later. The third is leaving DPP entirely with the sustainability or legal team when it's fundamentally a product-catalogue and supplier-data problem that touches merchandising and IT just as much.
If you're weighing how DPP fits alongside the rest of the compliance calendar — packaging rules, circular economy obligations, AI transparency — our broader roundup of upcoming EU eCommerce laws for 2027 puts them side by side with dates.
The practical next step, regardless of what you sell: pick your single most battery-heavy or highest-volume SKU category, and ask that supplier for structured sustainability data this month. Getting one clean data pipeline working is worth more than a spreadsheet of every future requirement you haven't started collecting for.
Frequently asked questions
What is a Digital Product Passport in simple terms?
It's a structured, scannable dataset attached to a product — accessible via QR code or similar — that holds information like material composition, carbon footprint, and recyclability, created under the EU's Ecodesign for Sustainable Products Regulation (ESPR).
When is the first Digital Product Passport requirement due?
Batteries are first, under the Batteries Regulation (EU) 2023/1542, with the battery passport obligation applying from 18 February 2027 for industrial, EV, and qualifying LMT batteries.
Does the DPP apply to clothing and electronics yet?
Not with a confirmed date. Textiles and electronics are widely expected to be early priority categories under ESPR's rollout, but the Commission hasn't fixed specific dates for them the way it has for batteries.
Who is responsible for the accuracy of passport data?
Liability generally follows the "economic operator" role — manufacturer, importer, or in some cases rebranding distributor. Retailers who import and rebrand products may be treated as the manufacturer for passport accuracy purposes.
Can PrestaShop handle Digital Product Passport data today?
PrestaShop doesn't have a native DPP module built into core, but structured product features and combinations can hold the required data fields, and QR codes can link to a hosted data page — our PrestaShop-specific guide walks through a practical setup.
Should I wait until my product category has a confirmed deadline?
No — waiting means scrambling later. Building a structured supplier-data pipeline now, even informally, is far cheaper than retrofitting one under deadline pressure once your category's delegated act is published.
Related reading
- Upcoming EU eCommerce Laws Every Merchant Should Prepare for in 2027
- EU Sustainability Rules That Will Impact Online Retail
- Future Packaging & Recycling Regulations for eCommerce
- Why Every Merchant Should Start Preparing for Circular Economy Laws
- Right to Repair Regulations Explained
