ESPR vs Digital Product Passport

ESPR is the framework

The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 establishes a framework for setting ecodesign requirements for sustainable products. It also establishes the digital product passport as part of that framework.

ESPR itself does not put a single DPP obligation on every product overnight. Product-group rules are specified in delegated acts adopted under ESPR, or in other Union law that requires a passport.

The DPP is the information instrument

ESPR defines a digital product passport as a set of data specific to a product that includes the information specified in the applicable delegated act and that is accessible via electronic means through a data carrier.

In short: ESPR (and some sector regulations) decide whether and how a passport is required; the DPP is the structured, machine-accessible product record those rules point to.

Delegated acts and sector laws

Under ESPR, delegated acts can specify the data to include, which data carriers to use, layout and positioning, whether identification is at model, batch, or item level, access rights, and how long the passport must remain available.

Standalone legislation can also require DPPs — for example certain batteries under the Battery Regulation, construction products under the CPR system, toys under the Toy Safety Regulation, and detergents under the Detergents Regulation. Packaging rules under PPWR address digital labelling and carriers but packaging is not a standalone DPP product group in our category map.

What brands should do next

Identify your closest product category, track whether your obligation comes from a confirmed sector date or an expected ESPR delegated act, and close product-ops gaps on identifiers, carriers, materials, and hosting. Use our free readiness checker for a prioritised gap list.