TL;DR: The essentials
- The EU is not building a single monolithic repository. Article 9 ESPR (Reg EU 2024/1781) configures a family of decentralised sectoral passports with a common regulatory and technical layer.
- Reg (EU) 2023/1542 on batteries: the first operational sectoral DPP, effective application 18 Feb 2027 (Art. 77). A methodological laboratory for textiles, electronics and furniture.
- Working Plan COM(2025) 187 final cross-sectoral timetable: iron/steel 2026 + textiles/aluminium/tyres/energy 2027 + furniture 2028 + mattresses/ICT 2029.
- 8 harmonised CEN/CENELEC JTC 24 standards under Mandate M/604 AMD 1 (Implementing Decision EU 28 Nov 2025): unique identifiers, data carriers, access control, security, interoperability, data format, persistence, APIs.
The DPP is not a single system — it is a family of sectoral passports with a common layer
The design of the Digital Product Passport under Regulation (EU) 2024/1781 (ESPR) imposes a paradigm of decentralisation. The regulation neither requires nor provides a central Community database that hosts the full content of all the passports. Article 12 of the ESPR defines the scope of the European registry, limiting its function to a search index. This central registry stores exclusively the unique product identifiers, the facility identifiers and the identifiers of the economic operators.
The passport is conceptually a knowledge graph. Each root node is the unique product identifier (Product UID). Article 9(2)(c) of the ESPR decrees textually that «the digital product passport shall be kept by the economic operator responsible for its creation or by digital product passport service providers». This legal requirement configures a network of decentralised repositories. Each economic operator deploys and operates its own data-hosting infrastructure.
Interoperability becomes the primary technical guideline. The system does not prescribe which internal database a textile manufacturer must use. The Regulation requires that the exposure of that data towards the exterior use standardised languages and protocols. The technical documents of the CIRPASS consortium describe the use of HTTP URIs or decentralised identifiers (DIDs). When scanning a physical data carrier, the system does not access the information directly. The scan activates a resolver that evaluates the user's credentials and redirects the request towards the appropriate repository.
This sectoral-family structure allows evolutionary flexibility. Each sector has different performance metrics and circularity models. A textile passport will document resistance to abrasion and colour fastness. A steel passport will prioritise fatigue resistance. The sectoral ontologies extend the common vocabulary without breaking the underlying data structure. The legal basis requires a common language for cross-cutting attributes, delegating specificity to the delegated acts of each category.
Batteries Reg (EU) 2023/1542 as a methodological laboratory — what it requires today, what the other sectors learn
The regulatory framework for batteries acts as a technical and institutional testbed for the entire digital-passport ecosystem in Europe. Regulation (EU) 2023/1542, operational in its DPP chapter since 18 Feb 2027 in accordance with Article 77, establishes the compliance standard. The requirements dictated for industrial batteries, electric-vehicle batteries and light-means-of-transport batteries anticipate the technical obligations that will fall on the next regulated sectors.
The battery passport introduces a stratified access model based on the need-to-know principle. Not all information is public. The system distinguishes between open-access data for consumers and restricted datasets. The market-surveillance authorities require total visibility to verify technical compliance. The recyclers require privileged access to the exact chemical composition and the location of the substances of concern. This management of permissions requires the use of verifiable-identity systems. The access-control protocols outlined in the early implementations require Verifiable Credentials to unlock the protected datasets.
The other sectors extract critical operational lessons from this methodological laboratory. The first lesson is the relative immutability of the data. The passport of a battery is born in the manufacturing phase with static design parameters. The life cycle of the battery requires the addition of dynamic data during its use. An independent repair workshop must annotate the replacement of defective cells. The regulation provides that these independent operators have authorisation to write in the original passport or link a complementary passport.
The second lesson affects versioning and legal liability. If a remanufacturer substantially alters the characteristics of a battery, the regulation requires the issuance of a new passport. This new identifier must maintain a cryptographic or semantic link with the original passport. The historical traceability is preserved while the legal liability is transferred to the new economic operator. The textile and furniture sectors must foresee database architectures that support this inheritance of records.
Working Plan ESPR cross-sectoral timetable 2025-2030
The deployment of the information obligations does not follow a simultaneous-application model. The Working Plan ESPR 2025-2030 contained in Communication COM(2025) 187 final establishes a sequential implementation calendar. The document outlines the regulatory priorities based on the volume of the market and the potential environmental impact. The work plan defines a roadmap with staggered interventions that oblige the supply chains to synchronise their digitalisation efforts.
The timetable anticipates the adoption of delegated acts for the iron and steel industry during 2026. This sector, characterised by high energy consumption, will act as the spearhead of intermediate products. The year 2027 marks the critical turning point with the convergence of multiple driving sectors. The plan projects the adoption of the specific regulations for textiles, aluminium, tyres and energy-related products. The textile industry faces the challenge of digitalising a highly fragmented and globalised value chain.
The second phase of the timetable extends the scope towards durable consumer goods and technological equipment. The furniture sector is scheduled for 2028. The complexity of furniture lies in the assembly of multiple previously regulated materials, such as metals and textiles. The cycle closes in 2029 with the inclusion of mattresses and information and communication technology (ICT) products.
This cascading calendar imposes a challenge of temporal compatibility. The manufacturers of complex products will have to manage the incorporation of components that already possess a digital passport together with materials not yet regulated. A furniture manufacturer in 2028 will assemble steel structures regulated from 2026 and textile upholstery regulated from 2027. The architecture of the system must allow the hierarchical aggregation of unique identifiers before the legal obligation affects the final product.
The 8 harmonised CEN/CENELEC JTC 24 standards — common technical layer mandate M/604 AMD Nov 2025
The operational viability of the digital-passport ecosystem depends on technical standardisation. The legal framework does not specify cryptographic protocols or data-serialisation formats. These decisions fall on the Joint Technical Committee 24 of CEN and CENELEC. The eight harmonised standards developed under Mandate M/604 AMD 1 (Implementing Decision EU 28 Nov 2025) build the underlying technical infrastructure. This common layer guarantees that a customs scanner can decode a tyre passport using the same software designed for garments.
The mandate organises the technical development into eight critical modules. The first module governs the unique identifiers, based on the ISO/IEC 15459 family of standards to guarantee global uniqueness without collisions. The second module standardises the data carriers. It requires robust physical links between the product and its digital twin through QR codes or RFID tags, determining the persistence of the link against physical wear.
The third module defines access control and information rights. It establishes the specifications for role-based authentication and the protection of trade secrets. The fourth and fifth modules form the core of technical and semantic interoperability. They require the use of open data-processing formats, profiling structures such as JSON-LD and descriptive models based on the Resource Description Framework (RDF) to allow automated reading by software agents.
The last modules address long-term security and network topology. The sixth module dictates the rules for data storage and the persistence of records in the event of the manufacturer's cessation of activity. The seventh ensures the authenticity and integrity of the information through digital signatures. The eighth module standardises the Application Programming Interfaces (APIs). These APIs regulate how the systems interact to request, filter and update data throughout the life cycle of the product.
How the textile DPP will dialogue with batteries, electronics and furniture — multi-sectoral scenarios
The theoretical separation between product groups disappears on the assembly lines of the real market. Contemporary business models constantly fuse sectors. A modern sofa integrates steel structures, textile upholstery, electric motors for articulation and USB charging ports. A technical mountaineering jacket embeds heating panels powered by removable batteries. Cross-interoperability is not a theoretical advantage. It is a strict requirement for regulatory compliance.
The design of the digital passport employs multi-level referencing models. When a complex product integrates previously regulated components, the final manufacturer does not have to duplicate the technical data of those components. The passport of the final product acts as a container of typed links (Typed Links). The identifier of the mountaineering jacket includes a semantic reference that points directly to the unique identifier of the battery supplied by a third party.
The methodology of the Joint Research Centre foresees professional access levels for the supply networks. An upholstered-furniture manufacturer, operating under the regulations projected for 2028, will consult the repositories of its textile suppliers. Through an authenticated HTTP GET request with its credentials, the furniture manufacturer's system will extract the carbon footprint of the textile and the percentage of recycled content. These values will be injected in an automated manner into the calculation of the environmental impact of the final product.
In the operational scenarios of repair, interoperability avoids the corruption of the data. If a maintenance centre replaces the electric motor of an articulated armchair, the technician will update the passport of the furniture. The system will record the deactivation of the original motor's identifier and link the identifier of the new component. The architecture based on knowledge graphs allows these substitutions without altering the static history certified by the original manufacturer. The traceability of the materials is maintained intact down to the recycling plant.
Architecture decisions 2026-2027 to avoid becoming isolated
Companies face a horizon of critical infrastructure decisions. Deploying a proprietary system or one dependent on closed formats in 2026 guarantees technical isolation and future regulatory non-compliance. Article 10(1)(d) of the ESPR explicitly prohibits vendor lock-in. The corporate data architecture must be founded on public vocabularies and standardised web protocols.
The structural recommendation requires the transition towards graph-oriented databases. The traditional enterprise resource planning (ERP) systems must implement transformation layers to expose the data in interoperable and machine-comprehensible formats. The adoption of Linked Data semantics allows the description of the provenance, the unit of measure and the hierarchy of each attribute. Designing API interfaces compliant with the standards in development will ensure fluid communication with the EU customs registry and the market-surveillance portals.
The corporate digital-identity model requires immediate attention. The prospective architectures point towards the use of Decentralised Identifiers (DIDs) and Verifiable Data Registries. The validation of cryptographic credentials will allow granular permissions to be granted to the value chain without compromising intellectual property. The systems integrators must plan resilient architectures capable of supporting massive queries from the European authorities.
To delve deeper into the prioritisation of categories and the impacts on the value chain, it is advisable to contrast this analysis with the Working Plan ESPR 2025-2030 and its 7-product-group timetable. The analysis on the discrepancies in the data models is detailed in the study of the technical gap between JRC 145830 and CIRPASS D2.1. The implications of data inheritance in maintenance operations and the separation between immutable Core DPP and dynamic Life-cycle Log are examined in the passport versioning with W3C VC 2.0.
Cited sources
- Official Journal of the European Union12 jul 2023Regulation in force
- Official Journal of the European Union13 jun 2024Regulation in force
- European Commission16 abr 2025Communication · Working Plan
- CEN/CENELEC2024-2026Standardisation programme
- CIRPASS Consortium2024Technical document
- Joint Research Centre · European Commissionmar 2026Methodological document
