The Digital Product Passport is arriving on a fixed timetable, and a lot of UK manufacturers have quietly decided it is a European problem. For anyone who exports, it is not.
You are in scope if your product is
The obligation follows the product placed on the EU market, not the address of the company that made it. Sheffield or Stuttgart makes no difference. If your goods end up on the EU market and they fall in a covered group, a passport will be required.
There is no GB mandate at the time of writing. For most UK workshops this is therefore an export question, which makes it easy to defer, right up until a customer asks for something you cannot produce.
The dates
| When | What |
|---|---|
| 20 July 2026 | The EU DPP Registry went live under Implementing Regulation (EU) 2026/1778. |
| 18 February 2027 | First binding deadline. Large batteries above 2kWh need a passport retrievable by QR code. |
| 2027 onwards | Textiles, aluminium and tyres enter the framework through delegated acts, each with its own transition. |
| Before all of it | Large buyers and public contracts start asking for passport-ready data ahead of the legal date. |
What a passport actually is
Less exotic than it sounds. It is a public web page about a specific unit, reached from a QR code on the product, that a person can read and a machine can parse. No login, because the point is that anyone down the chain can check it.
- A unique identifier for the item, either a GTIN or one you issue yourself.
- A data carrier, in practice a QR code that resolves to a real web address.
- Product information: materials, recycled content, repair guidance, end of life instructions.
- A record that ties back to the batch it came from.
The part that takes the longest
Publishing the passport is the easy half. The hard half is having something true to put in it.
Nobody fails this because they could not generate a QR code. They fail it because they cannot say which batch of material went into which unit.
If your material data lives in a spreadsheet that gets rebuilt every quarter, that is the work. Lot and batch traceability, captured at goods-in and carried through production, is the foundation everything else sits on. It is worth starting whether or not your product group has a date yet.
What to do in the next six months
- Find out whether your product group is scheduled, and when. Do not assume you are exempt because you are small.
- Ask your three largest EU customers whether passport data is on their roadmap. Their timetable may be earlier than the law.
- Get lot and batch traceability working properly, because everything else depends on it.
- Decide who owns the product data internally. This fails when it belongs to nobody.
- Check whether your existing systems can publish a machine-readable passport at all.
One thing to be clear about
No software can make your product compliant, and you should be wary of anything that claims otherwise. Compliance attaches to a product placed on the EU market by an economic operator, in the same way an accounting package cannot be tax compliant on your behalf. Software can hold the data and publish the passport. Signing it off remains yours.
Brytebuild publishes an EU-ESPR-ready digital product passport per unit, behind a GS1 Digital Link QR code, generated from the lot and batch data already in the system. You can read what it does and, just as importantly, what it does not do yet.