EU Digital Product Passport: What Dropshippers Need to Know
The Digital Product Passport becomes mandatory product group by product group, at least 18 months after each ESPR delegated act; batteries come first in February 2027. Here are the official dates and what resellers must do.
The EU Digital Product Passport (DPP) is a digital record of a product's data, reached through a data carrier such as a QR code, created under the Ecodesign for Sustainable Products Regulation (ESPR). For dropshippers it is not yet an obligation: product groups are added one by one through delegated acts, and the first ones, steel and textiles, are planned for 2026–2027.
Key takeaways
- The DPP comes from Regulation (EU) 2024/1781 (ESPR), in force since 18 July 2024; each product group gets its own DPP rules in a separate delegated act.
- A product-specific ESPR requirement cannot apply earlier than 18 months after its delegated act enters into force, except in duly justified cases.
- The Commission's 2025–2030 working plan prioritises textiles (apparel), furniture, tyres, mattresses, iron and steel and aluminium, plus horizontal rules on repairability and on recycled content of electronics.
- Batteries come first under separate law: from 18 February 2027 EV, light-means-of-transport and industrial batteries above 2 kWh need a battery passport.
- Resellers are covered too: dealers, including in distance selling, must make the DPP easily accessible to customers.
- What already applies today is the General Product Safety Regulation (GPSR), which requires product safety data in every online offer.
What is the EU Digital Product Passport?
The Digital Product Passport is a structured, digital set of information about a product, linked to the product through a data carrier and a unique identifier. It is introduced by the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781 of 13 June 2024, which has been in force since 18 July 2024.
Sources: Regulation (EU) 2024/1781, EUR-Lex and European Commission: ESPR.
The ESPR is a framework: it does not set requirements for any product by itself. Under Article 9, once a delegated act covers a product group, those products can only be placed on the market if a DPP is available, and the data must be accurate, complete and up to date. Each delegated act decides:
| What the delegated act specifies (Art. 9(2) ESPR) | Example of what it means |
|---|---|
| Data to include | Composition, substances of concern, repair or recycling information |
| Data carrier and its position | For example a QR code on the product, packaging or documents |
| Level of the passport | Per model, per batch or per individual item |
| Access before purchase, including distance selling | How an online shopper reaches the DPP before buying |
| Who can read which data | Customers, businesses, authorities |
| Who creates and updates the DPP | Usually the operator placing the product on the market |
| How long it stays available | At least the expected lifetime of the product |
The Commission describes the DPP as covering, depending on the product group, composition, circularity, environmental impact, use and maintenance, safety, end-of-life and regulatory compliance information (Commission: DPP web page launch, 17 July 2026).
When does the Digital Product Passport become mandatory?
There is no single start date. A DPP becomes mandatory for a product group only when its delegated act applies, and Article 4 of the ESPR says that cannot be earlier than 18 months after the act enters into force, except in duly justified cases. Batteries follow a separate regulation: 18 February 2027.
The key dates as of 8 Oct 2026:
| Date | What happens | Source |
|---|---|---|
| 18 Jul 2024 | ESPR enters into force | Commission: ESPR |
| 16 Apr 2025 | Commission adopts the 2025–2030 ESPR and Energy Labelling working plan | Working plan, COM(2025) 187 |
| 19 Jul 2026 | Deadline for the Commission to set up the DPP registry (Art. 13 ESPR) | Regulation (EU) 2024/1781 |
| 19 Jul 2026 | Ban on destroying unsold apparel and footwear applies to large companies | Commission news, 17 July 2026 |
| 18 Feb 2027 | Battery passport required for EV, LMT and industrial batteries above 2 kWh | Regulation (EU) 2023/1542, Art. 77 |
| 19 Jul 2030 | Destruction ban and disclosure duty extend to medium-sized companies | Regulation (EU) 2024/1781 |
The Commission's DPP registry page already lets organisations enrol; the registry stores unique identifiers and registration data, not the full passport (Commission: DPP Registry). Micro and small enterprises are exempt from the destruction ban and the disclosure duty.
Which products will need a Digital Product Passport first?
Batteries come first, under the Battery Regulation. Under the ESPR, the Commission's working plan of 16 April 2025 names priority groups with indicative adoption years: iron and steel (2026), textiles with a focus on apparel (2027), tyres (2027), aluminium (2027), furniture (2028) and mattresses (2029). Horizontal rules on repairability (2027) and recycled content of electronics (2029) follow.
| Product group | Indicative year of the measure | Relevance for dropshippers |
|---|---|---|
| Iron and steel | 2026 | Low — mostly an intermediate product |
| Textiles (apparel) | 2027 | High for fashion catalogues |
| Tyres | 2027 | Medium for automotive catalogues |
| Aluminium | 2027 | Low — intermediate product |
| Furniture | 2028 | High for home and garden catalogues |
| Mattresses | 2029 | Medium for home catalogues |
| Repairability, incl. scoring (horizontal) | 2027 | Possibly consumer electronics and small appliances |
| Recycled content and recyclability of electrical and electronic equipment (horizontal) | 2029 | Electronics catalogues |
Source: ESPR and Energy Labelling Working Plan 2025–2030, COM(2025) 187. The years are when the Commission plans to adopt the measure, not when obligations apply; add at least 18 months for application. Energy-related products with an energy label may rely on the existing EPREL database instead of a separate passport, as the working plan explains.
Who is responsible for the DPP in a dropshipping sale?
The operator placing the product on the EU market — usually the manufacturer or importer — creates the DPP and keeps it accurate. Distributors must check that a product is linked to its DPP before selling it, and dealers must make the DPP easily accessible to customers, including in distance selling. Online marketplaces must cooperate with authorities.
These roles come from the ESPR text (Regulation (EU) 2024/1781) and the Commission's guidance for economic operators (Commission: DPP for economic operators):
| Role | Main DPP duty | ESPR article |
|---|---|---|
| Manufacturer / importer | Create the DPP, attach the data carrier, register it, keep data accurate | Art. 9, 13 and the delegated act |
| Distributor | Verify the product is labelled or linked to a DPP before making it available | Art. 30 |
| Dealer (incl. distance selling) | Make the DPP easily accessible to customers and potential customers | Art. 31 |
| Online marketplace | Cooperate with market surveillance; authorities can order removal of offers for non-compliant products | Art. 35 |
For a dropshipping seller this means two practical things. First, the passport itself comes from upstream — the manufacturer or importer behind the wholesaler — not from the reseller. Second, whoever sells to the consumer must make the passport reachable from the offer, much like product safety data today.
In GAPLI's model the accounts and stores connected to GAPLI sell GAPLI's goods, and GAPLI is the seller towards the customer. GAPLI is a Polish full-dropshipping platform: the seller connects an Allegro, Erli or Aderlo account or a WooCommerce or Shopify store, and GAPLI supplies products from partner wholesalers, forwards orders, tracks parcels, issues customer invoices and settles the money (How GAPLI works). Product data therefore sits in one shared catalogue built from partner wholesalers' data (where GAPLI's products come from) rather than in each seller's spreadsheet.
What applies to online product data already today?
The General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, has applied since 13 December 2024. Its Article 19 requires every online offer to show the manufacturer's name and contact details, the EU responsible person if the manufacturer is outside the EU, information identifying the product including a picture and type, and any warnings or safety information.
Source: Regulation (EU) 2023/988, EUR-Lex. GPSR is the closest existing analogue of the DPP for online sellers: data that must travel with the product into every listing. See also GPSR in the GAPLI glossary.
| GPSR (applies now) | DPP under ESPR (later, per product group) | |
|---|---|---|
| Legal basis | Regulation (EU) 2023/988 | Regulation (EU) 2024/1781 + delegated acts |
| Applies from | 13 Dec 2024 | Per delegated act, at least 18 months after it enters into force |
| Scope | Consumer products generally | Product groups covered by delegated acts |
| What the online offer must carry | Manufacturer, EU responsible person, product identification, warnings | Access to the DPP before purchase, as the delegated act specifies |
| Typical identifier | Product type, picture, other identifiers (e.g. EAN) | Unique product identifier and a data carrier |
On Allegro, GAPLI attaches GPSR data to each offer, together with return, complaint and warranty terms, and does not list products without an EAN (GAPLI Allegro integration).
How should a dropshipper prepare for the DPP?
Prepare by knowing which of your categories fall into the priority groups, keeping product identifiers clean, and making sure product safety data already flows into every listing. You do not need to build passports yourself: they come from manufacturers and importers. Your job is to sell products whose data is complete and to show it where the law requires.
A practical checklist for 2026–2027:
| Step | Why it matters |
|---|---|
| Map your catalogue against the priority groups (apparel, furniture, tyres, mattresses, electronics) | Shows where DPP rules will hit first |
| Keep a valid EAN for every product | A clean identifier makes it easier to link offers to passports and to marketplace product cards |
| Check GPSR data in every listing now | It is already required and builds the same data habits |
| Follow the delegated acts for your categories | Only they define the data and the start date |
| Do not promise customers a DPP before it exists | Claims on offers must be accurate |
Avoid anyone who sells "DPP compliance" today for a product group with no delegated act: the data fields are not defined yet. The Commission's Digital Product Passport page is the official place to follow progress, including any changes from pending EU simplification proposals. For the related product-data topic, see our guide to AI product data automation for marketplace visibility.
Frequently asked questions
Do I need a Digital Product Passport to dropship in 2026?
Not under the ESPR yet. A product-specific DPP requirement applies at the earliest 18 months after its delegated act enters into force (save duly justified cases), and the first acts are indicatively planned for 2026–2027. Batteries are the exception, with a battery passport required from 18 February 2027 for certain battery types. GPSR product safety data is already mandatory.
Who creates the passport — the dropshipper or the manufacturer?
The economic operator placing the product on the EU market, usually the manufacturer or importer, creates the DPP and keeps it accurate. Resellers must make it accessible to customers, including in online sales. A dropshipper does not write passports, but sells products that must have them once rules apply.
Will the DPP replace the EAN code?
No. The DPP needs a unique product identifier and a data carrier, defined per product group; an EAN identifies a trade item and is what marketplaces use to match offers. Keeping valid EANs stays useful because it keeps product data consistent across channels. See EAN in the GAPLI glossary.
Does the ban on destroying unsold clothes affect dropshippers?
It applies to large companies from 19 July 2026 and to medium-sized companies from 19 July 2030; micro and small enterprises are exempt. A dropshipper holds no stock, so it rarely has unsold goods of its own to destroy, but its suppliers may be covered.
Sources
- GAPLI data (sales model, Allegro integration scope): GAPLI database and answer pages, as of 8 Oct 2026.
- EU: Regulation (EU) 2024/1781 (ESPR), EUR-Lex — Articles 4, 9, 13, 24, 25, 30, 31, 35.
- European Commission: Ecodesign for Sustainable Products Regulation.
- European Commission: ESPR and Energy Labelling Working Plan 2025–2030, COM(2025) 187.
- European Commission: Digital Product Passport, DPP Registry, DPP for economic operators, DPP web page launch, 17 July 2026.
- European Commission: Ban on destruction of unsold clothes and shoes enters application, 17 July 2026.
- EU: Regulation (EU) 2023/1542 on batteries, Article 77.
- EU: Regulation (EU) 2023/988 on general product safety (GPSR).
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GAPLI Team
E-commerce automation & dropshipping insights.