The European Union's sustainable product policy is also redefining how product information is produced, stored and shared. At the centre of that shift are the Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport (DPP) it introduces. With the DPP registry going live in July 2026, the subject moved from theoretical discussion into an implementation timeline. This article sets out what the DPP is, the dates that are known, the product groups that come first, and the preparation steps open to Turkish manufacturers shipping to the EU market.
What the ESPR and the Digital Product Passport are
Regulation (EU) 2024/1781 entered into force on 28 June 2024. The ESPR is a framework regulation: ecodesign requirements such as durability, reparability and recycled content are set separately for each product group through delegated acts adopted by the Commission. DPP requirements are added to those acts where appropriate.
The European Commission describes the DPP as a digital container holding information for products, components and materials that supports sustainability, promotes circularity and makes regulatory compliance easier. The DPP is not specific to the ESPR. The Battery Regulation, the Packaging and Packaging Waste Regulation, the Toy Safety Regulation, the Construction Products Regulation and EU law on detergents also contain passport obligations.
Technical building blocks
The regulation and the Commission's explanatory material outline the DPP's core components as follows:
- Data carrier: a QR code or similar digital carrier that links the physical product to its passport. Article 10 of the regulation requires the data carrier to comply with internationally recognised standards.
- Unique product identifier: Article 11 refers to the ISO/IEC 15459 standard for unique product identifiers.
- Registry: product data is held in a decentralised way, in the economic operators' own systems. Every passport must nonetheless be recorded in the EU registry; the registry produces a unique registration identifier for the recorded product and will be connected to the EU Customs Single Window environment for customs access.
- Back-up copy: Article 12 provides for a back-up copy of the passport to be kept through a DPP service provider.
- Role-based access: consumers reach the core information relevant to a purchase decision, repair and recycling operators the information relevant to their activity, and public authorities the data needed for enforcement.
The technical standards for the passport are being prepared by the European standardisation bodies CEN and CENELEC.
The timeline: confirmed and indicative dates
The dates fall into two groups: those fixed in legislation and the indicative timeline shared by the Commission. The main confirmed dates are:
- 28 June 2024: the ESPR entered into force.
- April 2025: the Commission adopted the 2025-2030 Ecodesign and Energy Labelling Working Plan.
- 19 July 2026: the regulation required the registry to be set up by this date at the latest. The restriction on the destruction of unsold clothing and footwear also took effect on this date; micro and small enterprises are exempt from the ban, while medium-sized enterprises were given a transition period.
- 20 July 2026: the Commission announced that the DPP registry, based on Implementing Regulation (EU) 2026/1778, had become operational. Registration can be done through a user interface or an API; a test environment, technical documentation and a help desk are also provided.
- 18 February 2027: a digital passport becomes mandatory for certain battery types. That obligation comes from the Battery Regulation.
The indicative timeline on the Commission's DPP page lists the product groups as follows: iron and steel in 2026; textiles, tyres and aluminium in 2027; furniture in 2028; mattresses and information and communication technology (ICT) products in 2029. It is worth keeping in mind that these dates refer to the preparation and adoption stages of the relevant delegated acts. The ESPR requires a transition period of at least 18 months after rules are adopted for a product group. The date on which an obligation actually begins for a sector will therefore become clear when that sector's own act is published.
Which sectors come first
The working plan identified the following groups, seen as having high potential to contribute to the circular economy, as priorities:
- Final products: textiles (especially clothing), furniture, tyres and mattresses
- Intermediate products: iron and steel, and aluminium
- Energy-related products: various product groups
- Horizontal measures: requirements on a reparability score and on the recyclability of electrical and electronic equipment
The registry was designed to support textiles, steel and aluminium, tyres, furniture, ICT and energy-related products under the ESPR, and large batteries, construction products, toys, detergents and surfactants under other legislation. The Commission notes that implementation will proceed in stages and that additional product groups will be assessed over time; an interim evaluation is foreseen in 2028.
What it means for Turkish exporters
The ESPR sets rules for products placed on the EU market. A product manufactured in Türkiye will therefore be subject to its product group's requirements once it is offered for sale in the EU. In practice these demands will often reach the supplier through the importer, distributor or brand customer in the EU. That textiles, furniture, iron and steel, aluminium and tyres — groups regularly exported from Türkiye to the EU — are in the first wave shows that waiting to prepare can be costly.
Which data will be required, and at which level of identification (model, batch or individual item), will be set by a separate act for each product group. Even so, there are steps that can be taken today and that will be useful whichever scenario plays out.
Six steps to prepare
- Product inventory: map the products you send to the EU against the groups in the working plan and identify the products affected in the first wave.
- Data map: work out where, with whom and in what format data such as material composition, recycled content, supplier information and conformity documents is held. A significant part of this data sits with suppliers.
- Level of identification: even if you work at model or batch level today, plan a numbering infrastructure that can move to individual item level when needed. GS1 identifiers compatible with ISO/IEC 15459, such as the GTIN, are a natural starting point here.
- Packaging and labelling: bring the question of where the data carrier will sit — on the product, the packaging or the documents — into the design cycle early. Every code added afterwards affects printing and quality control processes.
- Systems and service providers: assess which system will host the passport data, how the back-up copy obligation will be met and how the data will be shared with business partners in the EU.
- Destruction restriction: businesses selling clothing and footwear on the EU market should review how they handle unsold products under the new rule.
The DPP and product safety: drawing the line correctly
The DPP's primary purpose is sustainability and regulatory compliance. That said, the Commission's Recommendation (EU) 2024/915 on combating counterfeiting lists advanced tracking systems such as the digital product passport among the tools that increase supply chain visibility.
There is an important distinction here. A QR code on packaging, like any printable mark, can be copied, and a copied code opens the genuine product's passport when it is scanned. The data a DPP carries therefore does not prove on its own that a product is genuine. Authenticity calls for a physical element that is hard to copy, or a control mechanism that notices the same code being read in unexpected places or repeatedly.
Preparing for the DPP is putting unique identification and chain-of-custody records on the agenda for many manufacturers. Spectrace's Tagvex secure label records every change of hands from the production line to the warehouse, the dealer and the customer through unique numbering at batch or unit level; a copied code becomes visible as an unexpected or repeated read. Grafex makes the packaging itself verifiable with an invisible signature embedded in the existing packaging design, without changing the design or the production line. Verification is done with the mobile app on a smartphone.
Conclusion
The DPP is a long-term infrastructure aimed at having product information travel with the product on the EU market. With the registry live, the framework is in place; sector-level obligations will become clear as the acts are adopted. For Turkish exporters active in the first-wave sectors, the soundest course is to handle data, identification and packaging decisions together now, and to follow the timeline closely, product group by product group.
Sources
- EUR-Lex, Regulation (EU) 2024/1781 on ecodesign requirements for sustainable products, 2024
- European Commission, Digital Product Passport, 2026
- European Commission, The Digital Product Passport Registry is now live, 2026
- European Commission Green Forum, 2025-2030 working plan, 2025
- European Commission Green Forum, The Ecodesign for Sustainable Products Regulation moves into implementation, 2026
- EUR-Lex, Commission Recommendation (EU) 2024/915 on measures to combat counterfeiting, 2024
- GS1, Global Trade Item Number (GTIN) Executive Summary, 2015
