After batteries: the Digital Product Passport is coming for everything

On 18 July 2024, the Ecodesign for Sustainable Products Regulation (EU 2024/1781, the ESPR) entered into force, and with it the legal machinery to require a Digital Product Passport for almost any physical product sold in the EU. The first mandatory passport arrives with batteries: from 18 February 2027, every EV, LMT and industrial battery above 2 kWh placed on the EU market needs one. Steel, textiles, tyres and furniture are queued behind them. This article looks at what the ESPR schedule actually says, and why the battery rollout is the dress rehearsal every other sector should be watching.

What is the ESPR and which products come next?

The ESPR replaces the 2009 Ecodesign Directive, which only ever covered energy-related products such as appliances. The new regulation is a framework: it sets no product requirements by itself. Those arrive through delegated acts, one per product group, and each act defines both the ecodesign rules and the data that group's passport must carry.

The first working plan, adopted by the Commission in April 2025, names the priorities for 2025 to 2030:

• Iron and steel: delegated act targeted for 2026, the first intermediate material in line.
• Textiles and tyres: acts targeted for 2027, with apparel the lead textile category.
• Furniture and aluminium: acts targeted for 2028.
• Mattresses: 2029.
• Horizontal requirements: repairability, plus recycled content and recyclability of electrical and electronic equipment, between 2027 and 2029.

Two cautions on those dates. They are indicative: the plan gets a mid-term review in 2028, and delegated acts have a history of slipping. And adoption is not application: operators typically get a transition period of around 18 months before requirements bite, which puts the first ESPR passports plausibly in the 2027 to 2029 window. The plumbing moves earlier, though. The ESPR requires the Commission to set up the central registry in which every passport's unique identifier must be filed, with a July 2026 target, before the first product rules land.

Why do batteries go first?

Batteries did not wait for the ESPR. They have their own law, Regulation 2023/1542, in force since August 2023, and it made the battery passport the first mandatory product passport in any sector. The design decisions in that regulation read like a prototype of the ESPR's: a QR code on the product resolving to a per-unit record, a defined data model (Annex XIII lists more than 90 mandatory attributes), tiered access rights, and data that must be kept current through the product's life rather than written once at the factory.

The sequencing turns the battery rollout into a live experiment. Identifier schemes, data carriers, access control and registry integration all get tested on batteries first, at industrial scale, before textiles or steel inherit them. Standards bodies and the Commission's DPP work draw openly on the battery case, and most DPP software, Passoria included, was forged against Annex XIII before any other annex existed.

For battery players this is a burden and an advantage at once. They face the hardest version of the problem first: high-value products, contested materials data, service lives measured in decades, a regulated end of life. Whatever they learn is transferable. The sectors behind them start from a playbook someone else paid to write.

Lesson one: identity lives at the unit, not the SKU

Most industries manage product data at model or batch level. A datasheet describes every unit of the SKU equally well on day one, so one record seems enough. The battery regulation rejects that logic: it demands a record per individual battery, because two packs of the same model diverge from the moment they ship. Different duty cycles, different climates, different repair histories, different residual values. The passport is valuable precisely because it captures the divergence.

Other sectors will meet the same logic in diluted forms. A steel or aluminium passport will likely live at batch or coil level, where melt chemistry and recycled share are decided. Textiles may start at model level for most attributes. But the direction of travel is unit-level identity wherever an item's individual history changes its worth, and resale, repair and recycling all depend on exactly that history. Battery companies are building serialisation, data carriers and identifier resolution now. Everyone else will shop for the same components in a few years, or build them in a hurry.

Lesson two: nobody shares data without access tiers

The hardest negotiation in any passport scheme is who sees what. Manufacturers hold chemistry, sourcing and process data they consider trade secrets; recyclers and repairers need exactly that data to do their jobs. The battery regulation settles the standoff with three tiers: the public, persons with a legitimate interest (explicitly including recyclers and second-life operators), and market-surveillance authorities together with the Commission. State-of-health parameters under Annex VII sit in the passport and stay readable to the parties that need them.

Every following sector will replay this negotiation. Textile brands guard supplier lists as competitive information while sorters need fibre composition; steelmakers treat alloy recipes the way cell makers treat cathode chemistry. The battery lesson is that tiering has to be built into the data architecture from the start, not bolted onto a finished system. A passport designed as a public brochure cannot later carry confidential disassembly instructions, and one designed as a locked vault fails its public-information duties.

Lesson three: a passport is a stream of evidence, not a form

The battery passport is the most dynamic of the planned passports, and that is its most instructive feature. State of health must be kept updatable through life. A carbon-footprint declaration has been mandatory for EV batteries since 18 February 2025. Supply-chain due diligence on cobalt, lithium, nickel and natural graphite arrives in 2027. Recycled-content minima apply to new industrial and EV batteries from August 2031: 16% cobalt, 85% lead, 6% lithium, 6% nickel, rising again in 2036. Each obligation is evidence supplied by a different party at a different moment: the BMS during use, upstream suppliers, recyclers at end of life.

The ESPR passports will have the same shape at lower intensity. Repairability scoring implies repair events get recorded somewhere trustworthy. Recycled-content rules for steel, aluminium and electronics imply a chain of custody from scrap to new product, the same evidence problem batteries hit in 2031. The operational lesson from the battery rollout is blunt: the passport document is the easy part. The hard part is the pipeline behind it, connecting parties who have never exchanged structured data, and keeping the record alive across changes of ownership.

Conclusion: the dress rehearsal is already on stage

The Digital Product Passport stopped being a battery topic in July 2024; it is now the EU's default instrument for product data, with steel first in the ESPR queue and textiles close behind. The battery sector is running the full-scale rehearsal: per-unit identity, tiered access, live data, chain-of-custody evidence, all under a hard 2027 deadline. The sectors that watch it closely will comply cheaply. The companies inside it are learning the lessons first and hardest, and that experience will be worth exporting.

Passoria builds passports the way the framework is heading: per-unit records structured on Annex XIII, tiered access for recyclers and authorities, and lifecycle data that stays current from factory to furnace. If you place batteries on the EU market or handle them at end of life, our pilot program is open to a limited number of partners ahead of the February 2027 deadline.