EU DPP regulations, tracked article-by-article
How TracePass maps the EU regulations behind the Digital Product Passport — the Battery Regulation article-by-article, ESPR delegated acts per category, the boundary with CSRD reporting, and a changelog of how our schema responds to each change.
The Digital Product Passport isn't one regulation — it's a stack of them, each landing on a different timeline. These pages show exactly how TracePass reads each one and what it means for the data you'll need to publish.
We track the legal text article-by-article rather than summarising it, so you can trace any field in a passport back to the requirement that put it there.
TracePass tracks 9 regulatory surfaces behind the DPP — the Battery Regulation, ESPR delegated acts, the CSRD boundary, and a schema changelog.
Regulations we track
Battery Regulation 2023/1542
Per-article coverage of EU Battery Regulation 2023/1542: Article 7 carbon footprint, Article 8 recycled content, Article 11 removability, Article 77 DPP.
RegulatoryESPR & EU DPP delegated acts
Dated, sourced status of EU acts creating Digital Product Passport duties — Battery, Detergents, Toys, iron & steel, textiles: in force vs in preparation.
RegulatoryRegulatory changelog
EU DPP regulatory events with schema responses: ESPR 2024/1781, Battery Regulation 2023/1542, implementing acts, per-category templates. Reverse-chronological.
RegulatoryDPP and CSRD — where the product passport ends and reporting begins
TracePass is the product-level DPP and evidence layer that feeds your CSRD/ESRS reporting — it does not produce the report. Here's where the two meet.
RegulatoryThe EU DPP Registry — who submits, and what it actually checks
The EU DPP Registry is live but accepts no battery passports yet. Registration is the economic operator's duty, not the vendor's. Here is what that means.
RegulatoryStandards are not law — what actually makes a DPP field mandatory
An EN standard, a certification scheme or a non-EU convention does not make a passport field mandatory. Here is the test — and the 46 fields we got wrong.
RegulatoryHolding the data is not compliance — where a DPP duty is actually discharged
A field can be required by EU law while the passport is the wrong place to satisfy it. Labels, databases and held documentation each have their own legal form.
RegulatoryThe back-up copy obligation — a real ESPR duty with no provider to satisfy it
ESPR Article 10(4) requires a back-up copy of every ESPR passport with a service provider. The act defining that role is not adopted. What to do now.
RegulatoryEU battery passport data points — counts per type from Annex XIII
EV/LMT batteries need 56 required data points from 18 Feb 2027; industrial >2 kWh need 41. Plus 15 phased later. Annex XIII of EU Regulation 2023/1542.
RegulatoryRelated
Frequently asked questions
- Is TracePass a legal or compliance advisory service?
- No. These pages explain how our passport schema maps to the regulations, not legal advice. TracePass is software that helps you build and publish a Digital Product Passport; the positioning is "AI suggests, human approves".
- Does TracePass do CSRD or ESRS reporting?
- No. CSRD/ESRS is a separate corporate-reporting regime. The DPP can feed data into it, but TracePass is not a CSRD reporting tool — the CSRD page explains where the product passport ends and reporting begins.
- How often is the regulatory tracking updated?
- Each page carries its own last-reviewed date, and the changelog records how the TracePass schema responded to each regulatory change as the EU's implementing and delegated acts are published.
- When does the DPP become mandatory?
- It phases in by regulation. The EU battery passport is first, mandatory from 18 February 2027, followed by detergents (23 September 2029), toys (1 August 2030) and cars and vans (1 September 2032), each under its own law. Construction products wait on a delegated act under the CPR (Regulation 2024/3110); most other categories need a passport only once a delegated act under ESPR (Regulation 2024/1781) is adopted for them. None of these delegated acts has been adopted yet, and an ESPR act normally applies no earlier than 18 months after it enters into force. Packaging gets no passport under the PPWR (2025/40).
- What's the difference between ESPR and the Battery Regulation?
- The Battery Regulation (2023/1542) is a standalone law that mandates the battery passport directly. ESPR (2024/1781) is the framework regulation under which most other categories get a DPP, one delegated act at a time. The battery passport is furthest along; ESPR categories follow.
Maintained by the TracePass team · Last reviewed 25 September 2026