Digital Product Passport Data Requirements: What to Collect, Where It Lives, Who Owns It

Digital product passport data requirements come from Annex III of the ESPR (Ecodesign for Sustainable Products Regulation), a menu each product-group delegated act turns into a field list, and, for batteries, from Batteries Regulation Annex XIII.

You do not have to wait for your act. Start a data inventory now that records where each likely item lives, who owns it and who may see it.

This guide is for the operator placing goods on the EU market that must make a Digital Product Passport (DPP) available. New to the topic? Start with what a digital product passport is.

What are digital product passport data requirements?

Digital product passport data requirements are the data elements that a product-group delegated act selects from ESPR Annex III and Article 7, plus any data that other EU law adds. Each element must be accurate, complete and up to date (Article 9(1)), structured and machine-readable where appropriate (Article 10(1)(d)), and linked to a unique product identifier.

As of October 2026, no ESPR delegated act setting digital product passport data requirements has been adopted. Batteries are the binding exception, from 18 February 2027. Toys and detergents have adopted passport field lists in their own regulations, but those apply later.

Which data can a delegated act require?

Annex III is the menu behind ESPR digital product passport data requirements: each act specifies which data "are to or can be included". So the sheet described below gives every row a status: law, expected or voluntary (such as an EU Ecolabel award). Group the menu into five blocks.

Copy the five blocks as the sections of your sheet. For blocks 1–3, the Joint Research Centre (JRC) methodology behind future acts proposes one definition for every product group, drawn from vocabularies such as the GS1 Web Vocabulary or Schema.org.

That proposal is not law, but it makes these rows safe to prepare now. Blocks 4–5 wait for your act.

Where does each item live in your company?

Set up one sheet for all your digital product passport data requirements: one row per data element, twelve columns. Paste this header into cell A1 and split it at the commas (Data, then Text to columns):

element,legal anchor,status,granularity,system of record,owner,supplier-dependent,access tier,format/unit/vocabulary,evidence,update trigger,default or specific

Status is law, expected or voluntary; granularity is model, batch or item; access tier is one of four tags (see the tagging section). One row of digital product passport data requirements, filled across all twelve columns:

This map shows where digital product passport data requirements usually land in a manufacturing company. It fills seven of the twelve columns; add the rest in the gap analysis. "Law" means fixed by the ESPR once your act applies; access tags are provisional.

The JRC's draft textile study found commercial data structured in ERP and electronic data interchange (EDI) systems, but claims, technical data and certificates in emails, PDF test reports and spreadsheets.

A value that exists only inside a PDF is therefore a gap, even if it is right; documents such as the declaration of conformity can stay documents.

Fill the first eleven rows now. They cover Annex III points (b) to (l), which the JRC proposes to define alike for every product group. Mark every Article 7 row "awaiting act" and name one owner per row, not per department. That part of your digital product passport data requirements can be prepared before any act.

How do you turn the 71 battery data points into your sheet?

Annex XIII of the Batteries Regulation holds the first digital product passport data requirements with a full field list to apply, from 18 February 2027. It mixes model data with data on each battery, including data from its use (Article 77(2)).

The Commission's guidance "Digital Batteries Passport – data points by category" (version 2.0, DG GROW) lists 71 data points for electric vehicle (EV), light means of transport (LMT) and industrial batteries over 2 kWh, with legal source and applicability for each.

It is the most detailed passport inventory the Commission has published, though non-binding and not an official Commission position.

Load it row by row. This table turns each block of the battery's digital product passport data requirements into an action:

Real composition. The Commission says a chemistry label such as "LFP" is not detailed composition. It considers a 1% (DIN SPEC) or 0.1% (draft CEN technical specification) threshold potentially reasonable. Ask your cell supplier for values at that depth.

Not a battery maker? Copy the guidance's pattern for your own digital product passport data requirements: its legal source and applicability columns become your legal anchor and status columns.

See our battery passport guide, the battery carbon footprint guide and the battery due diligence guide for the Article 47 test.

How do you add your product group's fields before its act is final?

Blocks 4–5 wait for your act, but drafts come first. Each time a JRC study, call for evidence or draft act appears, run this routine so expected digital product passport data requirements enter your sheet clearly marked:

1. Copy the field list (compliance lead) into block 4 or 5, one row per field.
2. Tag it "expected" (compliance lead) with source and date, for example "expected (JRC draft, April 2026)".
3. Map it to a document you already issue (function head), such as a certificate or test report, before designing anything new.
4. Score it (data owner) on the five tests in the gap analysis below.

Steel example. The Commission's call for evidence considers information on carbon footprint, recycled content and substances that make products harder to recycle; adoption is indicated for 2026 (expected).

The JRC proposes the heat number as mandatory batch identifier: map the mill certificate's heat number to "batch identifier, expected (JRC proposal)".

Final-product makers add a "steel content" row marked open, as one JRC scope option would put steel data in their passports.

Textile example. The act is indicated for 2027 (expected). The JRC's May 2026 study is a draft external study, not a Commission position; our textile DPP data guide lists its fields.

Public or restricted: how should you tag each field?

Each delegated act sets who sees what (ESPR Article 9(2)(f)), so every access tag you set today is provisional. Two models help:

• Battery pattern (law): public, legitimate interest, authorities. The act defining legitimate interest was due by 18 August 2026 (Batteries Regulation Article 77(9)); a Commission draft for public feedback is planned for Q4 2026 (expected).
• JRC illustration (proposal): five tiers from public to regulatory; data for specific business customers falls outside the legal basis and is managed by the data owner.

Use four tags only (public, legitimate interest, authorities, contract) and choose one per row of your digital product passport data requirements by field type:

How do you run a data gap analysis?

A gap analysis turns digital product passport data requirements into a dated work list. Five steps, one owner each:

1. List the rows by block (compliance lead): the map above, or the 71 guidance points for batteries.
2. Find system and owner (function heads): one name per row.
3. Score each field 0–2 (data owner) on the five tests below.
4. Mark default or specific (sustainability, procurement). The JRC expects much supplier data, such as carbon footprint or recycled content, to start as defaults.
5. Sort and date (compliance lead): fix internally, request from supplier, or wait for the act, each with an owner and a date.

A workable cut-off: any 0, or a total below 7 of 10, puts the row on the gap list.

For key rows, add the per-field attributes the JRC methodology proposes for future digital product passport data requirements: required accuracy, recency, completeness, provenance, who provides and verifies, update timing, confidentiality. This is step 2 of our DPP implementation plan.

How do you keep passport data current?

Article 9(1) makes accuracy a continuing duty, as does Article 77(4) of the Batteries Regulation. Without triggers, digital product passport data requirements are met at launch and missed a month later. Set a trigger per field and version every change:

Battery use-phase data must be updated at least when a change in the battery's status occurs or is considered (Commission battery FAQ).

Which data-quality rules will your passport be checked against?

Your digital product passport data requirements face three different checks:

Upload mechanics, including why one error rejects a whole multi-passport file, are in our registry guide.

Tag each row with one of the JRC draft textile study's three verification types (tested, calculated or chain-of-custody, identification); the type tells you which evidence to keep.

Run nine checks on your digital product passport data requirements before any upload:

Walkthrough: a hypothetical storage-battery assembler in Plzeň

Take a hypothetical Plzeň firm assembling three models of 10 kWh stationary storage cabinets, about 90 a month, with cells from one non-EU supplier. A stationary battery energy storage system is an industrial battery; these exceed 2 kWh, so each cabinet needs a passport.

The firm completes the battery, so it is the manufacturer (Commission battery FAQ).

Weeks 1–2 (compliance lead): load the 71 guidance points. In the industrial column, our count gives 32 mandatory, 27 conditional or optional and 12 not to be filled.

Of those 12, eight wait for later dates: the carbon footprint declaration and label, due diligence, four recycled-content shares and instructions for use (held pending an amendment). Two repeat earlier points; two do not apply to industrial batteries.

The cells are lithium iron phosphate, so only the lithium recycled-content row stays, dated; the cobalt, nickel and lead rows do not apply (Commission battery FAQ). The due diligence row stays only if the Article 47 turnover test does not exempt the firm or its group; the compliance lead checks that first.

Week 3 (function heads): owners named: master data for identifiers, engineering for part numbers and dismantling, quality for the declaration and test reports, firmware for use-phase data. Procurement sends the cell supplier a dated request for cathode, anode and electrolyte composition.

Week 4 (data owners, compliance lead): every row scored on the five tests. Hypothetical result for the 32 mandatory points:

• 18 pass the cut-off.
• 9 are fixed internally, each with an owner and a date, among them dismantling information (engineering) and test-report links (quality).
• 5 go to the cell supplier, among them detailed composition and cell resistance.

The dated rows (carbon footprint, the lithium share and, if it applies, due diligence from 18 August 2027) sit on a separate wait list. That gap list is the firm's digital product passport data requirements in dated form.

Counterfactual: in month 3 the firm adds a second LFP cell supplier, but the composition rows have no "supplier or material change" trigger. Cabinets with the new cells get passports showing the first supplier's composition.

They pass every format check, because the values are well formed, yet an authority comparing cells with passports would find them inaccurate (Batteries Regulation Article 77(4)). The trigger table would have forced a new declaration and version before the first new cabinet shipped.

Edge cases: what if your situation is different?

These cases change who fills a row, not the digital product passport data requirements themselves.

• Contract manufacturer and brand. Whoever markets the product under its own name or trademark is the manufacturer (ESPR Article 2(42)). Record who supplies each field and whose GS1 licence the GTINs come from.
• Two passport laws. When two laws set digital product passport data requirements for one product, register at the most granular level either requires (Implementing Regulation (EU) 2026/1778, Article 8(3)).
• Supplier will not share. Use a flagged default and log a dated request. For non-EU suppliers outside direct EU oversight, the JRC's draft textile study points to contractual arrangements, recognised third-party assessments or mutually accepted certification schemes.
• Confidential recipes. Keep exact values restricted; Article 7(5)(c) allows a maximum concentration or a range.
• Products already on sale. Units placed on the market after your act applies need a passport, even for an old model; check the act's transitional rules. A battery remanufactured after the battery passport starts needs one (Commission battery FAQ).

Zoom out: what is settled and what should you watch?

Settled (law): the Annex III menu; Article 7(2)(b) and 7(5); the accuracy duty in Article 9(1); the registry's semantic checks; battery Annex XIII; adopted passport lists for toys and detergents.

Watch list: each event below reopens part of your digital product passport data requirements sheet.

Digital product passport data requirements will differ by act; the structure will not. Build the sheet now: the act only decides which rows become mandatory.

What should you do in the next 30 days?

Seven actions turn digital product passport data requirements into a working sheet:

1. Days 1–3, compliance lead: copy the header row and the five blocks.
2. Week 1, master data: fill the eleven rows for Annex III points (b) to (l).
3. Week 1, function heads: name one owner per row.
4. Week 2, compliance lead: tag status and provisional access.
5. Weeks 2–3, data owners: score each row on the five tests.
6. Week 3, procurement: send dated supplier requests; log defaults.
7. Week 4, compliance lead: issue the gap list with owners and dates; battery makers check it against the 71 points.

Test identifier-to-passport links with the free GS1 Digital Link QR generator: no signup, and it runs in your browser. Passmith also has a free plan.

Further reading: What is a digital product passport? · Textile DPP data · Battery passport · DPP implementation: 8 steps

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