Your products will need a Digital Product Passport to sell in the EU — batteries first, from Feb 2027.

A Digital Product Passport is a digital record containing key information about a product—its materials, origin, sustainability data, and recycling instructions. The EU requires them for batteries from February 2027 under the Battery Regulation, and for more product categories under ESPR from about 2028.

The rules phase in from 2027 to around 2031, depending on your product category. The first confirmed deadline is 18 February 2027 for batteries (industrial, EV, and LMT). Iron & steel ESPR DPP enforcement is estimated for 2028. Textiles follow in 2029 (est.); an electronics/ICT act is not yet scheduled. CBAM financial obligations for iron & steel importers are already live from January 2026. We recommend starting now — collecting data from overseas factories can take months.

Yes, you share responsibility. Importers must make sure the manufacturer has met the requirements — including the passport — before the product is placed on the EU market, and keep the documentation available. If you sell under your own brand or modify the product, you take on the manufacturer's obligations yourself.

From 18 February 2027 (batteries) and an estimated 2028 (iron & steel), customs and market surveillance authorities can stop shipments that lack a valid digital identifier (QR code) linked to an interoperable Digital Product Passport. CBAM enforcement for iron & steel importers is already active — non-compliant carbon declarations can result in border adjustments today.

No. You can collect the technical data from your suppliers (in China, Turkey, etc.) and enter it into your PassportLab dashboard yourself. You then provide the generated QR codes to your factories for printing.

The retention period is set per product category in the relevant delegated act or product law, and ESPR requires a backup so the passport stays available even if the economic operator stops trading. PassportLab archives every passport for at least 10 years — matching the EU DPP Registry, which keeps registration data for 10 years (Implementing Regulation (EU) 2026/1778, Art. 10(3)).