The EU is making a digital record of each product a condition of selling it, starting with batteries in February 2027 and steel after that. The importer registers the passport, but the data behind it sits with the manufacturer. We get that data ready.
Digital Product Passport (DPP) readiness for manufacturers and exporters in the UAE, Saudi Arabia and the wider GCC selling into the EU: scope and timing under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 and the Battery Regulation (EU) 2023/1542, product data gap assessment, reuse of CBAM embedded emissions data, product and batch identification, recycled content and substances of concern, product carbon footprint to ISO 14067, and supplier circularity data using ISO 59040. ESGweise is not a DPP service provider and does not register passports.
A legal obligation to have good product data
A Digital Product Passport is a machine-readable record of a product, reached by scanning a QR code or similar on the product. The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, sets the framework; each product group gets its own rules.
- What it carries: composition, recycled content, substances of concern, carbon footprint, repair and end-of-life information, compliance documents, and unique identifiers for the product, the manufacturer and the facility, as each product group's rules require.
- Where it lives: with the economic operator or a DPP service provider, with a back-up copy. The Commission's DPP Registry, live since 20 July 2026, holds the identifiers, not the passport content.
- Who reads it: customers, repairers, recyclers, market surveillance authorities and customs, each with the access level the product rules set.
- What it must be: accurate, complete and up to date for the life of the product, including if the company behind it closes. Registering it is expressly not proof that it is right.
Batteries first, then steel
Only the battery date is fixed in law. The others are the Commission's planned adoption dates as at October 2026, and obligations apply at least 18 months after each act is adopted.
- Batteries, 18 February 2027: EV batteries, light means of transport batteries and industrial batteries above 2 kWh need a passport, at item level, under the Battery Regulation.
- Iron and steel: the first product group under ESPR. Adoption is planned for the fourth quarter of 2026, which puts the earliest obligations around late 2028. The same act will define low-carbon steel, which the EU intends to use in public procurement.
- Textiles and apparel: adoption planned for the fourth quarter of 2027.
- Aluminium and tyres: adoption planned during 2027.
- At the border: once a product group is covered, customs checks the passport's registration identifier against the registry before releasing the goods, and the link becomes automatic through the EU Customs Single Window by about 2030.
The importer registers it. The supplier holds the data.
For goods made outside the EU, the duty to make the passport available and register it sits with the EU importer, and the importer may not place the product on the market without it. The importer cannot write it alone. Composition, chemistry, scrap share, emissions and batch records are held by the manufacturer, so the requirement arrives as purchase conditions and supplier questionnaires, and a producer who cannot answer becomes harder to buy from. The Commission has also signalled that suppliers may carry information duties of their own under some product group rules.
Steel, aluminium and textiles are among the first groups, which puts Gulf mills, smelters, fabricators and apparel suppliers near the front of the queue.
CBAM covers the emissions half. Nothing covers the circularity half yet.
- Carries across from CBAM: installation identity and location, CN codes, production route, direct emissions, electricity and precursor data.
- New for the passport: recycled content split by pre-consumer and post-consumer origin, substances of concern with location and concentration, compliance documents, unique product, operator and facility identifiers, and use, repair and end-of-life information.
- The largest gap is granularity: CBAM reports annual averages per installation, while the steel passport is expected to work per batch, with the heat number proposed as the batch identifier.
- The carbon footprint widens: the steel work starts from ETS and CBAM values and adds the upstream and downstream contributions CBAM leaves out.
Start collecting circularity data before the rules are final
ISO 59040:2025, the Product Circularity Data Sheet, published in February 2025, is a voluntary international format for describing a product's circularity: recycled content, recyclability, disassembly and substances, in standard statements a buyer can read. It is not named in ESPR and does not satisfy a passport on its own. It is the most practical way to ask suppliers for circularity data in one consistent form now, while the product group rules are still being written, and much of what it covers is what those rules will ask for. It sits alongside the ISO 59000 circular economy standards.
How ESGweise gets your product data passport ready
Exposure map
Which products, CN codes and EU customers are caught, under which rules, and when. Batteries, steel, aluminium, textiles and tyres first, with the planned dates tracked as they move.
Data gap assessment
What you already hold, from CBAM reports, mill test certificates, EPDs and quality records, set against what the passport will ask for, with each gap given an owner and a route to close it.
Product identity and traceability
How model, batch and item identifiers are assigned and kept, so a figure in the passport can be traced to the heat, lot or serial number it describes.
The hard data
Recycled content by a documented mass balance, a substances of concern inventory, and a product carbon footprint to ISO 14067 built from your CBAM data and consistent with any EPD you publish.
Supplier data and controls
An ISO 59040 based request to your suppliers, and the ownership, change control and evidence trail that keep passport data accurate for the life of the product.
Alignment with your EU customers
Agreeing what data each importer needs, in what form, and who registers, so the data you build is the data they can use.
- ESGweise: quoted as a fixed scope after the exposure map
- Passport hosting and registration: by a DPP service provider and your EU importer. ESGweise is neither.
The same plant data serves CBAM, EPDs and life cycle assessment and your customers' Scope 3 requests. Built once with controls, it stops being collected again for every request. See also our work with heavy industry and manufacturing.
Digital Product Passport: questions we hear most
What is a Digital Product Passport?
A Digital Product Passport is a structured, machine-readable record of data about a physical product, reached by scanning a QR code or similar data carrier on the product, its packaging or its documents. It carries what EU law requires for that product group, such as composition, recycled content, substances of concern, carbon footprint, repair and end-of-life information, and the identity of the manufacturer and importer. The legal basis is the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (ESPR). Batteries have their own passport under the Battery Regulation (EU) 2023/1542.
When does the Digital Product Passport become mandatory?
Product group by product group. Battery passports are mandatory from 18 February 2027 for EV batteries, light means of transport batteries and industrial batteries above 2 kWh. Under ESPR, iron and steel comes first: as at 13 October 2026 the Commission plans to adopt its delegated act in the fourth quarter of 2026, and obligations apply at least 18 months after adoption, so the earliest steel passports fall around late 2028. Textiles, aluminium and tyres are planned for adoption during 2027. These are planned dates, not deadlines, until each act is adopted.
Does a GCC exporter have to create the passport?
The legal duty sits with the economic operator placing the product on the EU market, which for goods made outside the EU is normally the EU importer. The importer must not place the product on the market unless the passport exists, and customs checks its registration identifier before release. But the importer cannot produce the data. Composition, chemistry, scrap share, emissions and batch records sit with the manufacturer, so the requirement reaches the exporter through contracts and supplier questionnaires. The Commission has also signalled that some suppliers may get information duties of their own under the product group rules.
We already report under CBAM. How much of the passport does that cover?
For steel and aluminium, a verified CBAM data set covers much of the emissions half of a passport and none of the circularity half. Installation identity, CN codes, production route, direct emissions, electricity and precursors carry across. What the passport adds is recycled content by origin, substances of concern, compliance documents, unique product, operator and facility identifiers, and repair and end-of-life information. The largest gap is granularity: CBAM works on annual installation averages, while the steel passport is expected to work at batch level, with the heat number proposed as the batch identifier.
What is ISO 59040 and do we need it?
ISO 59040:2025, the Product Circularity Data Sheet, published on 3 February 2025, is a voluntary international format for describing a product's circularity characteristics so a supplier can pass that information to a buyer in a consistent form. It began as a Luxembourg government initiative. It is not named in ESPR and does not satisfy the passport on its own, but much of what it covers, such as recycled content, recyclability and substances, is what passports will ask for. It is a practical way to start collecting circularity data from suppliers while the EU product rules are still being written.
Do you build or host the passport?
No. The passport itself is held by the economic operator or a DPP service provider, and the EU importer registers its identifiers in the Commission's DPP Registry. ESGweise works on what goes into it: mapping which products are caught and when, assessing the data you hold against what the rules ask for, designing product and batch identification, measuring recycled content and carbon footprint, building the substances inventory, and putting controls on the data so it stays accurate for the life of the product. We work alongside whichever platform you or your EU customer choose.
Thirty minutes. We figure out if there's a fit.
We don't pitch on the call. We listen, ask sharp questions, and tell you honestly whether digital product passport is what you need, or what else might be.
Speak with our team