Two EU frameworks shape digital product passports, and they operate at different levels. The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, is horizontal: it sets the general rules and is activated for each product group through delegated acts over time. The Batteries Regulation (EU) 2023/1542 is vertical and product-specific: it already fixes the battery passport content, the access tiers and a fixed deadline without waiting for any further act.
| Dimension | Batteries Regulation (EU) 2023/1542 | ESPR (EU) 2024/1781 |
|---|---|---|
| Type of framework | Product-specific (vertical) | Horizontal, per-product-group |
| Passport content | Fixed in Annex XIII | Defined per delegated act |
| Activation | Already in force, deadline set | Phased in per product group |
| Deadline | 18 February 2027 | Varies by delegated act |
| Granularity | One passport per battery (Art. 77(1)) | Set per delegated act |
| Applies to batteries? | Yes, directly | Not where the Batteries Regulation governs |
How they relate
The ESPR establishes the broader DPP architecture that other product groups will eventually follow, while the Batteries Regulation is the first concrete, binding instance of that architecture. The shapes are compatible — both rely on a data carrier, tiered access and a structured record — but the legal content for batteries comes from Annex XIII of the Batteries Regulation, not from ESPR.
- Batteries: obligations and content are already fixed — act now.
- Other categories: watch for ESPR delegated acts that define their passports.
- A passport built to the Batteries Regulation maps to the wider ESPR DPP shape.
Frequently asked
Does the ESPR replace the Batteries Regulation for batteries?
No. The Batteries Regulation (EU) 2023/1542 governs the battery passport directly. The ESPR is a horizontal framework for other product groups; for in-scope batteries you follow the Batteries Regulation and its Annex XIII.
Do I need to wait for an ESPR delegated act before acting on batteries?
No. The battery passport obligation is already fixed by Regulation (EU) 2023/1542, with a deadline of 18 February 2027. The ESPR rollout does not change that.