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Digitaler Produktpass
What is a device made of, how can it be repaired, and what happens to its raw materials at the end? A digital product passport is intended to answer these questions in future. For manufacturers, dealers and everyone who refurbishes or recycles used devices, this is an important topic for the future. Here you can read what the passport is, what it contains and from when it applies (as of: 10/2026).
In brief
The digital product passport (DPP) is an electronic dataset about a product that can be accessed via a data carrier such as a QR code and contains information on materials, repair, recycling and environmental impact. The legal basis is primarily the EU Ecodesign Regulation (ESPR), which gradually defines the contents for individual product groups. For the circular economy, it is intended to make repair, reuse and recycling easier.
Legal basis and timeline
the Ecodesign Regulation (EU) 2024/1781 has been in force since July 18, 2024. It creates the framework for digital product passports but does not directly set the obligations for all products. Which product group needs a passport when and what data it must contain is determined by the EU Commission in separate delegated acts. Its working plan for the years 2025 to 2030 describes the priorities for this.
| Milestone | As of: 10/2026 |
|---|---|
| Ecodesign Regulation (ESPR) enters into force | July 18, 2024 |
| Central EU registry for product passports | To be established by the Commission by July 19, 2026 |
| Battery passport under the EU Battery Regulation | From February 18, 2027 for batteries of electric vehicles, light means of transport and industrial batteries above 2 kWh |
| Further product groups | Gradually after adoption of the respective delegated acts, each with a transition period |
As of 10/2026, there is no binding product passport obligation for laptops, smartphones or servers. Device batteries in laptops also do not fall under the battery passport categories. More on this in the entry German Battery Act and EU Battery Regulation.
What a digital product passport can contain
- Unique identifier of the product, model or batch and information on the manufacturer
- Materials and substances, in particular substances of concern, and shares of recycled materials
- Environmental information, for example on the CO₂ footprint
- Repair and disassembly information, spare parts and maintenance notes
- End-of-life information, for example on collection, dismantling and recycling
- Conformity evidence and documents for authorities
Not all data is visible to everyone. Tiered access rights are planned for consumers, repair shops, recyclers and authorities.
Rule of thumb: The product passport turns a device into a source of information, for purchase, repair and recycling.
Significance for IT hardware and remarketing
For the Circular economy in IT, the passport can close several gaps: refurbishers receive reliable information on spare parts and disassembly, recyclers know which materials are in the device, and companies can take over data for their sustainability reports, for example under ESRS E5. Important: A product passport contains product data, not user data. The erasure of company data on a device remains a separate task. How IT cycles already work today is shown in the article How your IT becomes a circular model.
Digital product passport and Second IT
Second IT extends the use of IT hardware through testing, repair and refurbishment and prioritizes reuse over recycling. What can no longer be used is properly recovered as a certified waste management company under § 56 KrWG. Customers receive recycling and disposal certificates for their CSR and ESG reporting. More on IT disposal with certification.
Frequently asked questions about the digital product passport
From when does the digital product passport apply?
There is no uniform start date. The battery passport applies from February 18, 2027 for certain batteries. For other product groups, the obligation only begins once the EU Commission has adopted the respective delegated acts and their transition periods have expired (as of: 10/2026).
Do companies that only use IT need a product passport?
No. The obligations mainly affect manufacturers, importers and dealers who place products on the market. Companies that buy and use IT benefit from the data, for example for procurement and reports.
Does the product passport contain personal data of users?
No. It describes the product, not the data that someone has stored on it. Secure erasure therefore remains necessary before any transfer.
Who may see the data in the digital product passport?
Not all data is visible to everyone. Tiered access rights are planned for consumers, repair shops, recyclers and authorities. The passport can be accessed via a data carrier such as a QR code on the product.
Is there already a digital product passport for laptops and smartphones?
No. As of 10/2026, there is no binding obligation for laptops, smartphones or servers. Device batteries in laptops also do not fall under the battery passport categories. Which product group needs a passport when is determined by the EU Commission in separate legal acts.
Circular economy instead of throwaway, with evidence for your ESG reporting.
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