Digital Product Passport (DPP): Obligations for Importers and Exporters

The EU’s Digital Product Passport registry is live from July 2026. Every business that trades across EU borders needs to know what DPP regulations will demand.

Chris Stennett

15 Apr, 2026
5 min read

Copied

Compliance European Union Goods Classification

Digital Product Passport (DPP): Obligations for Importers and Exporters

Contents:

What the Digital Product Passport is
Which products are in scope
What exporters must prepare
What importers need to check
The compliance cost of getting this wrong
Why this matters for your business
How Customs Support Group can help

What the Digital Product Passport Is

The Digital Product Passport (DPP) is a digital record that travels with a product through its whole life.

It is part of the Ecodesign for Sustainable Products Regulation (ESPR), which the EU created to make product data open and verifiable across global supply chains.

Each DPP holds a unique product ID and a set of standard data. That data covers:

Where materials came from
Their impact on the environment
Any harmful substances
Safety guidance
How to dispose of the product.

This data is linked to a digital tag – often a QR code – that stays with the product at the point of sale and at the border.

The DPP is not a paper form. It is a digital record that customs bodies, market watchdogs, and buyers must all be able to read. Getting the data structure right matters as much as the data itself.

Which Products Are in Scope

Priority sectors are live from 2027, with all product types due to be covered by 2030.

The products included are:

Batteries (from 18^th February 2027)
Textiles (from mid-2027)
Iron and steel (from mid-2027)
Tyres (from mid-2027)
Furniture (by the end of 2027)
Mattresses (by the end of 2027)
Aluminium (in 2028)
Energy-related goods (in 2028)
IT products (in 2028)

*Note that this list does not include other products currently under review.

The DPP rules apply to any product sold in the EU, no matter where it was made. If your goods fall within a covered sector – likely in line with the commodity code – a digital product passport must exist.

What Exporters Must Prepare

For businesses sending goods into the EU market, the creation of the DPP falls on the maker or their named agent. This means the exporter must build, hold, and send the passport data before goods arrive.

In practice, this means four things:

Find out which data points apply to your product type
Set up a system to gather and store that data — materials origin, supply chain records, compliance files.
Assign a unique product ID and link it to a digital tag
Make sure the data is correct and can be checked. EU watchdogs can review DPPs and block market access where data is wrong, missing, or false.

Exporters with long, complex supply chains face the harder version of this. When goods come from many suppliers across many countries, tracing that data back takes time and money.

Starting now cuts the risk of being caught short once the DPP becomes mandatory.

What Importers Need to Check

For businesses bringing goods into the EU, the DPP creates a checking duty. An importer taking in goods from a covered sector must confirm that a valid digital product passport exists and that it comes with the shipment.

This is not a box-ticking task, because you are liable for the information on the digital product passport as the importer.

EU customs and market watchdogs are building systems to check DPP data at the border. Importers who accept goods without a valid DPP – or with one that holds wrong data – risk holding goods that cannot reach the market. They may also face questions about supply chain checks that go well beyond the DPP.

In practice, importers should hold the information used in a DPP from their suppliers already – both as part of their goods classification and as part of their procurement due diligence. What changes now is the requirement to add a digital product passport to the existing flow.

Customs Support Group works with importers to build a comprehensive, compliant, and defensible classification database. Contact us to arrange a customs health check.

The Compliance Cost of Getting This Wrong

The ESPR lets member states set the fine amounts for a breach, and those fines will grow as sector deadlines pass. For importers, goods held at the border whilst DPP checks are done is a real cost risk – delays, storage fees, and order losses if windows are missed.

For exporters, the risk is greater. A DPP that fails the rules is not just a paperwork problem. It blocks market access. Products sold in the EU without a valid DPP can be pulled from sale. Repeat failures can lead to market reviews that damage the wider trade ties with EU buyers.

Why This Matters for Your Business

For makers and traders in the priority sectors, digital product passports are not far off.

However, the overlap between DPPs, other green supply chain measures, and best practices for product tariff classification means that importers already prioritising compliance will be able to take it in their stride.

Businesses that treat this as a document task will find the data rules harder than expected. A DPP is only as good as the data that feeds it. Importers who rely on suppliers not yet set up for DPP will face gaps at the point when checks begin. And those gaps may trigger further review into your compliance ecosystem.

Getting ready means two things: knowing which sector timeline applies to your trade flows, and reviewing your flows with suppliers and freight partners now.