July 29, 2026
Which Product Categories Are Affected, What the EU Rules Mean, and How Manufacturers Can Scope Their
Determining which products need a Digital Product Passport is one of the first—and most important—questions in any DPP program.
The short answer is broader than many manufacturers expect.
The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781 establishes a horizontal framework that can apply to almost all physical products placed on the EU market. However, this does not mean that every physical product requires a DPP immediately. Specific obligations are introduced progressively through product-specific delegated acts and, in some sectors, through separate regulations with their own digital product information requirements. citeturn200560search1
This distinction matters.
A manufacturer may not yet have a binding DPP deadline for a particular product category, but that product can still sit within the broader ESPR framework or another sectoral regulatory pathway that will introduce digital information requirements later.
For companies selling into Europe, the scoping question therefore should not be limited to:
“Do we need a DPP?”
A more useful set of questions is:
Which of our products are affected, under which legal framework, at what level of granularity, and from when?
That shift is important for global manufacturers.
A DPP project is not only a compliance exercise. It affects product data architecture, supplier collaboration, product identification, lifecycle data, digital trust, and the way product information is shared across organizations.
For manufacturers with large portfolios, multiple factories, international suppliers, or several product categories, the first stage of DPP readiness should therefore be a structured scoping exercise.
This guide explains:
- which product categories are already subject to defined DPP requirements;
- which categories are prioritized under the ESPR roadmap;
- which sectors follow their own regulatory pathways;
- which products are currently excluded;
- which economic operators carry responsibility;
- and how manufacturers can assess their own portfolio systematically.
At a Glance
- The ESPR is a horizontal framework. It is designed to cover almost all physical products on the EU market, while concrete DPP obligations are introduced product by product through delegated acts.
- Sector-specific regulations also matter. Batteries, packaging, construction products, toys, detergents, and other categories can follow their own digital product information rules and implementation timelines.
- Batteries have the clearest fixed DPP deadline. Relevant EV, industrial, and LMT batteries require a Battery Passport from 18 February 2027 under the EU Battery Regulation.
- Textiles, electronics, furniture, tyres, metals, and other product groups are prioritized under the ESPR work plan, but their binding requirements depend on the relevant product-specific measures.
- Food, feed, medicinal products, living organisms, and several other categories are explicitly excluded from ESPR scope.
- The company placing the product on the EU market must understand its regulatory role. Manufacturers, importers, authorized representatives, distributors, and marketplaces can each have different responsibilities.
- DPP scoping should happen at product-category level, not only at industry level. One company can have products or components subject to several different regulatory frameworks at the same time.
Table of Contents
- The principle: DPP is designed for a broad range of physical products
- Where DPP requirements come from: ESPR and sector-specific regulations
- Product categories and DPP-related timing at a glance
- Industry by industry: which products are affected
- Which products are currently outside ESPR scope
- How to assess your product portfolio in 15 minutes
- What being “affected” means in practice
- Which products need a DPP: key numbers
- How a Digital Product Passport works
- DPP architecture and implementation challenges
- How Nota Sign supports DPP implementation
- Frequently asked questions
1. The Principle: DPP Is Designed for a Broad Range of Physical Products
The Digital Product Passport is not limited to batteries, fashion, or a small number of sustainability-focused industries.
The ESPR establishes a framework for sustainable product requirements across a very broad range of physical goods placed on the European market.
Its scope is intentionally horizontal.
Rather than defining one universal DPP template for every product, the regulation establishes the legal and technical framework, while detailed requirements are introduced progressively for specific product categories.
This means two things for manufacturers.
First, the absence of a binding DPP requirement today does not automatically mean that a product category is permanently outside scope.
Second, companies should not build their DPP strategy around a single deadline.
The correct approach is to monitor the regulatory pathway of each relevant product category.
For example, batteries already have a dedicated regulatory framework and a fixed Battery Passport deadline. Other categories are being addressed through the ESPR work plan, while sectors such as construction products, toys, packaging, and detergents follow separate regulatory instruments.
The ESPR 2025–2030 Working Plan identifies priority product groups for future ecodesign requirements, including textiles and apparel, furniture, tyres, iron and steel, aluminium, mattresses, and several energy-related and ICT products. citeturn200560search1
For manufacturers, the practical implication is straightforward:
Do not ask only whether DPP applies to your industry. Determine which regulation applies to each product category and what implementation sequence follows from it.
A company can also be affected through multiple pathways.
An e-bike manufacturer, for example, may need to consider battery-specific requirements for the battery while separately monitoring broader product requirements for the bicycle, electronics, textiles, or other incorporated components.
A furniture manufacturer can have products containing electrical components that fall under additional requirements.
An industrial machinery manufacturer may need to consider product-level rules, component-level rules, and separate machinery compliance obligations.
DPP readiness is therefore a product-portfolio exercise—not simply an industry label.
2. Where DPP Requirements Come From: ESPR and Sector-Specific Regulations
To understand whether a product needs a Digital Product Passport, manufacturers need to consider two regulatory layers in parallel:
- the ESPR framework; and
- sector-specific legislation.
These two layers complement each other.
ESPR as the Horizontal Framework
The Ecodesign for Sustainable Products Regulation entered into force in 2024 and replaced the previous Ecodesign Directive.
Its significance goes far beyond traditional energy efficiency regulation.
The ESPR provides the legal framework for introducing requirements related to:
- durability;
- reparability;
- resource efficiency;
- recycled content;
- substances of concern;
- environmental performance;
- product information;
- and Digital Product Passports.
Instead of publishing one fixed list of DPP data fields for every physical product, the European Commission develops product-specific requirements through delegated acts and other implementing measures.
This makes the framework scalable.
A textile does not require the same information model as an industrial battery. Furniture has different lifecycle characteristics from electronics. Construction products require different environmental and technical information from consumer goods.
Each category therefore requires its own regulatory and data model.
For enterprises, this means that DPP compliance should be designed around a flexible product-data architecture rather than a single static template.
Sector-Specific Regulations with Digital Product Information Requirements
Alongside the ESPR, several sectors have their own regulations that introduce Digital Product Passport requirements or comparable digital information structures.
The most advanced example is the EU Battery Regulation (EU) 2023/1542.
It establishes a Battery Passport for relevant:
- electric vehicle batteries;
- industrial batteries above 2 kWh;
- and light means of transport batteries.
The fixed Battery Passport date is 18 February 2027. citeturn200560search1
Other regulatory frameworks are also moving toward structured digital product information.
These include areas such as:
- packaging under the Packaging and Packaging Waste Regulation;
- construction products under the Construction Products Regulation;
- toys under the Toy Safety framework;
- detergents under the revised detergents regulatory framework.
These mechanisms should not automatically be treated as identical to an ESPR DPP.
The underlying policy objectives can differ.
Some frameworks focus primarily on:
- sustainability;
- product safety;
- conformity;
- labelling;
- environmental performance;
- or market surveillance.
But the direction is consistent: product data is increasingly expected to become structured, machine-readable, accessible, and connected to a persistent product identity.
For global manufacturers, this means DPP architecture should not be designed for only one regulation.
It should be capable of supporting multiple product-data and compliance regimes from the same digital foundation.
3. Product Categories and DPP-Related Timing at a Glance
The following table provides a practical scoping view.
For ESPR categories, timing should be treated as an implementation-planning window rather than a universal fixed DPP deadline. Binding obligations depend on the relevant product-specific rules.
The key lesson from this table is that manufacturers should distinguish between:
- a fixed legal deadline, such as the Battery Passport date;
- a prioritized product category, such as textiles or furniture;
- and a broader sectoral digital information requirement that may not use exactly the same DPP mechanism.
This prevents one of the most common DPP planning mistakes: treating every projected date as though it were already a binding legal deadline.
4. Industry by Industry: Which Products Are Affected?
The broad regulatory categories become more useful when translated into actual product portfolios.
Batteries
Batteries are currently the clearest DPP use case.
Under the EU Battery Regulation, three major battery categories require a Battery Passport from 18 February 2027:
Electric Vehicle Batteries
EV batteries used in electric vehicles fall directly within the passport requirement.
For manufacturers and automotive supply-chain companies, the Battery Passport connects information such as:
- battery identity;
- manufacturer information;
- technical data;
- material and sustainability data;
- lifecycle information;
- performance information;
- and recycling-related records.
The requirement applies regardless of where the battery was manufactured if it is placed on the EU market.
That makes Battery Passport readiness especially important for battery manufacturers in China, Korea, Japan, the United States, and other major exporting markets.
Industrial Batteries Above 2 kWh
This category extends DPP relevance well beyond passenger vehicles.
Industrial batteries above 2 kWh can appear in applications such as:
- stationary energy storage;
- UPS systems;
- warehouse vehicles;
- forklifts;
- automated guided vehicles;
- railway applications;
- industrial equipment;
- specialist machinery.
This is why Battery Passport readiness is not simply an automotive compliance issue.
For many companies it is becoming an industrial product-data and lifecycle-management issue.
LMT Batteries
Light Means of Transport batteries include products used in:
- e-bikes;
- pedelecs;
- e-scooters;
- e-mopeds;
- and comparable light mobility products.
Companies manufacturing, importing, or integrating these batteries into products sold in Europe need to assess the Battery Passport requirement at battery level.
The regulation also illustrates an important DPP principle:
A component can have its own digital product identity even when it is incorporated into a larger product.
Textiles and Fashion
Textiles are among the highest-priority product categories under the ESPR roadmap.
The immediate focus is particularly relevant for apparel and related consumer products.
Typical categories include:
- outerwear;
- shirts and tops;
- trousers;
- underwear;
- children's clothing;
- footwear;
- bags and accessories;
- home textiles;
- technical textiles.
The challenge for textile manufacturers is supply-chain fragmentation.
A single garment can involve:
- fiber suppliers;
- spinning mills;
- fabric mills;
- dyeing operations;
- garment manufacturers;
- brand owners;
- distributors.
DPP implementation therefore requires companies to connect information that traditionally sits across multiple independent organizations.
Relevant product information can include:
- fiber composition;
- material origin;
- manufacturing location;
- chemical information;
- care instructions;
- repairability;
- recycling information;
- environmental performance.
For brands, the DPP also creates a direct digital connection between the product and the end customer.
That means the same infrastructure used for compliance can support:
- product transparency;
- customer education;
- repair services;
- resale;
- circular business models;
- and post-purchase engagement.
The ESPR also introduces restrictions on the destruction of certain unsold consumer products, including apparel and footwear, reinforcing the broader move toward traceable lifecycle management.
Electrical and Electronic Products
Electronics and ICT products are another major DPP-relevant category.
Typical examples include:
- computers;
- laptops;
- smartphones;
- tablets;
- displays;
- servers;
- networking hardware;
- power tools;
- professional electronic equipment;
- and household appliances.
These products already operate within a mature regulatory environment covering issues such as energy performance, safety, materials, substances, and recycling.
DPP requirements add another layer: persistent, structured lifecycle information.
For manufacturers, relevant information can include:
- product identity;
- materials;
- components;
- energy performance;
- software or firmware references;
- reparability information;
- spare parts;
- disassembly information;
- end-of-life instructions.
This is particularly significant for electronics companies because their product data already spans multiple systems:
- PLM for engineering;
- ERP for product master data;
- MES for production;
- quality systems;
- supplier systems;
- service platforms.
A DPP platform must therefore connect existing digital infrastructure rather than create another isolated database.
Furniture
Furniture is another priority product category under the ESPR work plan.
Relevant product groups include:
- sofas;
- chairs;
- tables;
- cabinets;
- beds;
- office furniture;
- garden furniture;
- mattresses;
- hospitality furniture;
- public-space furniture.
Furniture is an interesting DPP use case because its useful life can be significantly longer than that of many consumer goods.
A product can remain in circulation for years or decades.
During that period, lifecycle information can support:
- maintenance;
- replacement parts;
- refurbishment;
- resale;
- reuse;
- recycling.
A Digital Product Passport can preserve information about:
- materials;
- suppliers;
- production origin;
- assembly;
- repair instructions;
- care information;
- sustainability characteristics.
For manufacturers developing circular services or resale strategies, product identity can therefore have commercial value beyond compliance.
Furniture also demonstrates why manufacturers need category-level scoping.
A furniture product containing electrical equipment may create overlapping obligations across furniture, electronics, or other sector-specific rules.
Construction Products
Construction products follow a different regulatory pathway.
They are primarily addressed through the Construction Products Regulation rather than simply through the ESPR product waves.
Relevant products include:
- cement;
- concrete components;
- insulation;
- roofing materials;
- windows;
- doors;
- construction chemicals;
- sanitary products;
- metal building components.
Construction products have extremely long lifecycles.
Product information may need to remain accessible throughout:
- design;
- construction;
- building operation;
- renovation;
- demolition;
- material recovery.
Relevant digital information can include:
- Environmental Product Declarations;
- technical performance;
- material composition;
- substances;
- reuse potential;
- dismantling information;
- recycling data.
The construction sector also highlights the importance of B2B data exchange.
Product data can pass between:
manufacturer → distributor → contractor → developer → building owner → maintenance provider → authority
A scalable DPP architecture therefore needs strong identity, access-control, interoperability, and data-governance capabilities.
Tyres
Tyres are another prioritized product group.
They already sit within an established regulatory environment that includes product performance and labelling requirements.
A future DPP-oriented data model can extend this with structured information related to:
- product identity;
- materials;
- durability;
- mileage;
- environmental characteristics;
- recycling and recovery.
Tyres also show how existing product labels can evolve toward broader lifecycle data rather than being replaced by one completely separate system.
Machinery and Industrial Equipment
Industrial machinery is often misunderstood in DPP discussions because there is no single category called “all machinery” that automatically receives one uniform DPP requirement.
Manufacturers need to examine both:
- the finished machine;
- and the regulated components inside it.
Typical components can include:
- motors;
- batteries;
- pumps;
- fans;
- drives;
- electronics;
- control systems.
A machine can therefore intersect with multiple regulatory frameworks.
The machinery sector is also well suited to lifecycle-oriented DPP use cases because manufacturers already manage:
- serial numbers;
- maintenance history;
- service records;
- replacement parts;
- inspection reports;
- software versions.
For industrial manufacturers, DPP can develop naturally from existing equipment lifecycle management rather than being treated as a separate consumer-facing product page.
Toys
Toy products follow their own safety-focused regulatory pathway.
Digital product information can support:
- proof of conformity;
- safety data;
- product identity;
- manufacturer information;
- material and ingredient information;
- traceability.
Toy manufacturers also need to consider packaging requirements separately, because the packaging and the toy can follow different regulatory frameworks.
This illustrates another common DPP principle:
One commercial product can contain several regulated objects with different digital information obligations.
Detergents and Cleaning Products
Detergents and cleaning products are moving toward structured digital product information through sector-specific legislation.
Relevant information can include:
- ingredients;
- safety information;
- labelling;
- usage instructions;
- environmental information.
Unlike durable machinery or furniture, these products often have shorter lifecycles.
The DPP model therefore needs to support very different product-data patterns across industries rather than assuming every passport is maintained in the same way.
Food, Outdoor Products, and Aerospace
Food and Feed
Food and feed are explicitly excluded from ESPR scope.
They remain subject to their own product information, traceability, and labelling frameworks.
Digital labels and smart product information can still exist in these sectors, but they should not automatically be described as ESPR Digital Product Passports.
Outdoor and Leisure Products
Outdoor products can overlap multiple categories.
Examples include:
- outdoor clothing;
- camping equipment;
- bicycles;
- sporting goods;
- electronic outdoor devices.
A single outdoor brand may therefore need to monitor textiles, electronics, batteries, materials, and later ESPR product categories simultaneously.
Aerospace
Aerospace products are strongly regulated through sector-specific frameworks.
While they are not simply part of a generic ESPR DPP category, many aerospace supply chains already rely on detailed:
- part identification;
- traceability;
- material data;
- maintenance records;
- certification evidence.
This makes aerospace highly relevant to the broader direction of machine-readable product identity and trusted lifecycle data.
Key takeaway: DPP scoping must happen at product and component level, not just at company or industry level. A single manufacturer can be affected by several regulatory pathways at the same time.
5. Which Products Are Currently Outside ESPR Scope?
The ESPR does not apply to every physical product.
Article 1 defines specific exclusions.
Important categories include:
- food;
- feed;
- medicinal products for human use;
- veterinary medicinal products;
- living plants;
- living animals;
- microorganisms;
- products of human origin;
- certain products derived directly from plants and animals relating to reproduction.
These categories follow their own regulatory systems.
The important point is that the exclusion list is relatively narrow.
A company should not assume that a product is permanently outside future DPP requirements simply because it is not currently highlighted in an ESPR priority list.
There is a major difference between:
“explicitly excluded from the regulation”
and:
“not yet covered by a product-specific delegated act.”
For most manufacturers, the second situation is much more common.
Companies should therefore maintain an internal regulatory map of their product portfolio and update it as product-specific measures develop.
6. How to Assess Your Product Portfolio in 15 Minutes
A first DPP scope assessment does not need to begin with a multi-month consulting project.
Manufacturers can create a useful initial view quickly.
The goal is to build a simple matrix showing:
Product category → Legal framework → Company role → Expected timing → Required preparation
Step 1: List Your Product Categories
Start with product families, not individual SKUs.
Use:
- Combined Nomenclature codes;
- customs classifications;
- internal product categories;
- product portfolio structures.
For example:
- EV battery packs;
- stationary storage batteries;
- e-bike batteries;
- upholstered furniture;
- office chairs;
- industrial motors;
- smart displays.
The purpose is to identify the regulatory category before analyzing individual product variants.
Step 2: Map Each Category to Its Regulatory Framework
For every category, determine whether it is primarily associated with:
- ESPR;
- Battery Regulation;
- Construction Products Regulation;
- packaging regulation;
- toy regulation;
- detergents regulation;
- machinery regulation;
- another sector-specific framework;
- or an explicit exemption.
Do not assume that one company maps to only one regulation.
Large manufacturers will typically have several.
Step 3: Check for Regulatory Overlap
Next, identify products containing components that create additional requirements.
Examples:
- an e-bike and its battery;
- furniture with embedded electronics;
- machinery containing an industrial battery;
- a toy with electronic components;
- a product and its packaging.
For DPP planning, these overlaps matter because data requirements can accumulate.
Step 4: Clarify Your Role in the EU Market
Ask whether your company acts as:
- manufacturer;
- importer;
- authorized representative;
- distributor;
- marketplace operator.
For companies manufacturing outside Europe, this step is especially important.
A Chinese manufacturer selling through an EU importer has a different legal structure from a Chinese company operating its own European subsidiary and placing products directly on the market.
The product may be the same, but the regulatory responsibility chain is different.
Step 5: Map the Data and Systems Behind Each Product
Once scope is clear, identify where relevant information currently exists.
Typical systems include:
- ERP;
- MES;
- PLM;
- PIM;
- QMS;
- supplier portals;
- sustainability platforms;
- data lakes;
- spreadsheets and document repositories.
This turns regulatory scoping into an IT implementation map.
A useful first matrix looks like this:
That matrix is far more useful than a generic statement that “the company is preparing for DPP.”
7. What Being “Affected” Means in Practice
The second dimension of DPP scope is responsibility.
A product can be within scope, but different economic operators have different obligations.
Manufacturers
Manufacturers usually carry the primary responsibility for product compliance.
Depending on the applicable act, this can involve:
- creating the DPP;
- ensuring required information is available;
- maintaining product data;
- providing identifiers;
- meeting registration requirements;
- updating lifecycle data where required.
The specific obligations depend on the relevant product legislation.
Importers
Importers are particularly important for products manufactured outside the European Union.
For global manufacturers exporting into Europe, the importer is part of the compliance chain and typically has obligations to verify that products meet relevant EU requirements before being placed on the market.
This is why DPP is directly relevant to Chinese, American, Japanese, Korean, and other non-EU manufacturers.
Export operations need to provide the EU-side entity with reliable product information.
DPP therefore becomes part of international market-access infrastructure rather than only a European internal compliance system.
Authorized Representatives
A non-EU manufacturer can appoint an authorized representative within the EU for specific regulatory responsibilities.
For multinational companies, this can be relevant where:
- manufacturing occurs outside Europe;
- an EU subsidiary manages market access;
- regulatory responsibilities are centralized.
A DPP platform should therefore support multi-entity organizations rather than assuming one product always belongs to one legal entity.
Distributors and Marketplaces
Distributors and marketplaces do not always carry the same primary obligations as manufacturers, but they still play a role in ensuring products offered on the market meet applicable requirements.
Once valid DPP information becomes a market-access condition for a product category, distributors and platforms will need mechanisms to verify relevant product information before listing or selling products.
This creates an important commercial effect:
DPP readiness can become a customer and channel requirement before enforcement reaches the manufacturer directly.
Large retailers, OEMs, procurement platforms, and marketplaces can incorporate product-data checks into onboarding and listing processes.
DPP Obligations Are Not Limited to Large Enterprises
Another common misconception is that DPP requirements will apply only to large corporations.
That is not how product regulation generally works.
If a regulated product is placed on the EU market, the applicable requirements follow the product and the economic operator's role.
Company size does not automatically eliminate the obligation.
Specific acts can provide targeted exemptions, transitional measures, or proportionality rules, but small companies should not assume a blanket SME exemption.
Model, Batch, or Individual-Item Level?
DPP implementation also differs in granularity.
Depending on the regulation and product category, a passport can potentially operate at:
- model level;
- batch level;
- individual-item level.
Battery Passports provide an important example of individual-product identification.
Other product categories can use different levels depending on the final product-specific requirements.
This distinction has major implications for IT architecture.
Managing 200 product models is very different from managing 20 million individual product identities.
Manufacturers should therefore define DPP granularity before choosing:
- identifiers;
- data carriers;
- databases;
- API architecture;
- lifecycle update processes.
8. Which Products Need a DPP: Key Numbers
18 February 2027
Fixed Battery Passport date for relevant EV batteries, LMT batteries, and industrial batteries above 2 kWh under the EU Battery Regulation.
Almost All Physical Product Categories
The ESPR is designed as a broad horizontal framework, with a limited number of explicit exclusions. Concrete product-level obligations are introduced progressively.
2025–2030
The current ESPR work plan period in which priority product groups are being addressed through product-specific regulatory work.
Multiple Regulatory Pathways
Manufacturers need to monitor both:
- ESPR product-specific measures;
- and sector-specific regulations.
One Product Can Trigger Multiple Requirements
A product can contain batteries, electronics, textiles, packaging, or other regulated components, meaning DPP scoping often needs to happen below finished-product level.
One DPP Program Can Involve Multiple Enterprise Systems
Relevant product information commonly sits across:
- ERP;
- MES;
- PLM;
- PIM;
- quality systems;
- supplier systems;
- lifecycle platforms.
This is why DPP should be approached as an enterprise product-data architecture rather than simply a compliance webpage.
Key takeaway: The first question in a DPP program is not simply “Do we need a passport?” The correct starting point is to map product category, legal framework, regulatory role, granularity, timing, and data sources. Once that scope is clear, manufacturers can move into DPP architecture, system integration, trusted data exchange, and implementation.
