A Digital Product Passport (DPP) is a structured, machine-readable record of a product carried by a data carrier such as a QR code, giving different audiences tiered access to information across the product life cycle. The battery passport is the first product category for which this concept becomes a hard legal requirement, so the two terms are often used interchangeably even though they are not the same thing.
Two different legal sources
The general DPP framework comes from the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, which sets the horizontal rules and will be activated for specific product groups through delegated acts over time. The battery passport instead comes from a dedicated, product-specific law — the Batteries Regulation (EU) 2023/1542 — which already fixes the content, the access tiers and the deadline.
| Aspect | Battery passport | General DPP (ESPR) |
|---|---|---|
| Legal basis | Regulation (EU) 2023/1542 | Regulation (EU) 2024/1781 + delegated acts |
| Status | Mandatory from 18 February 2027 | Phased in per product group |
| Scope today | LMT, industrial >2 kWh, EV batteries | Textiles, electronics and others to follow |
| Granularity | One passport per individual battery (Art. 77(1)) | Defined per delegated act |
| Access tiers | Annex XIII (public / legitimate interest / authorities / Commission) | Tiered access, scope set per act |
Why the distinction matters
- Your obligations and content requirements are already fixed for batteries — you do not need to wait for an ESPR delegated act.
- A tool built for the battery passport can map to the wider DPP shape, but the legal field set comes from Annex XIII of the Batteries Regulation.
- Treating the battery passport as a generic DPP risks missing battery-specific fields such as carbon footprint, recycled content and due diligence.
Frequently asked
Is a battery passport the same as a Digital Product Passport?
A battery passport is a specific type of Digital Product Passport. The general DPP is a framework under the ESPR; the battery passport is the first concrete, legally mandated instance of it, governed by the Batteries Regulation (EU) 2023/1542.
Do I need an ESPR DPP if I already have a battery passport?
For in-scope batteries, the Batteries Regulation governs your obligations directly. You do not need a separate ESPR delegated act to be required to publish a battery passport by 18 February 2027.