TRUTH ANCHOR: EUR-LEX 32024R1781

Digital Product Passport Requirements: The Complete Data Field Guide for Manufacturers

This guide covers every data field required by Regulation (EU) 2024/1781 (ESPR) — the Ecodesign for Sustainable Products Regulation — for a valid Digital Product Passport. Each field is explained with its legal reference, what data to provide, and a real-world example. This is the definitive reference for manufacturers preparing for the 2027 mandatory deadlines.

The Legal Framework: ESPR Annex III

The DPP requirements are established in Regulation (EU) 2024/1781, specifically in Article 9 (Digital Product Passport) and Annex III (Minimum Data Requirements). The regulation entered into force on 18 July 2024 and applies to all products placed on the EU market, regardless of where they were manufactured.

The ESPR uses a two-tier structure. The regulation itself sets the minimum requirements that apply to all products. Sector-specific delegated acts — adopted by the European Commission for each product category — then add additional requirements. This means a textile manufacturer must comply with both the general ESPR requirements and the Textile Delegated Act once it is adopted.

The EU Commission has published a methodology report (JRC145830) that explains how data requirements for each delegated act will be determined. The methodology prioritises data that is: (1) verifiable by third parties, (2) machine-readable, (3) available throughout the supply chain, and (4) relevant to the product's environmental impact.

The 13 Core Data Fields

These fields are required for all products under ESPR Annex III. Sector-specific delegated acts will add additional fields for each product category.

Unique Product Identifier (UID)

ESPR Art. 9(1)(a)

A unique identifier that distinguishes this specific product from all others. Must follow a standardised format — GS1 GTIN, ISO/IEC 15459 IAC, or equivalent. The UID is the primary key for all DPP lookups.

Example: DPP-ZA-2026-a3f8c2d1e9b47f2a

Product Model / Type / Batch / Serial Number

ESPR Art. 9(1)(c)

The manufacturer's internal product identification. Batch number enables recall management. Serial number enables individual unit tracking for high-value products.

Example: Model: GTX-100 | Batch: 2026-Q1-0042

Commodity Code

ESPR Art. 9(1)(b)

The HS (Harmonised System) code and EU TARIC code for the product. Required for customs processing. For textiles: HS Chapter 61 (knitted) or 62 (woven). For batteries: HS 8507.

Example: HS 6109.10 (T-shirts, singlets, cotton)

Manufacturer Name and Address

ESPR Art. 9(1)(d)

Legal name and registered address of the manufacturer. Must match the company's national business registry entry (CIPC, CAC, RDB, or equivalent).

Example: Gqeberha Textiles (Pty) Ltd, 12 Industrial Ave, Gqeberha, 6001, ZA

Country of Origin

ESPR Annex III §2(c)

ISO 3166-1 alpha-2 country code for the country where the product was substantially manufactured or transformed. For textiles: where cutting and sewing occurred. For batteries: where cells were assembled.

Example: ZA (South Africa)

Material Composition

ESPR Annex III §4

Complete list of materials by weight percentage. For textiles: fibre composition. For batteries: active materials (cathode, anode, electrolyte). For electronics: plastics, metals, rare earth elements.

Example: 60% Cotton, 35% Polyester, 5% Elastane

Recycled Content

ESPR Annex III §4(b)

Percentage of recycled material by weight, broken down by pre-consumer and post-consumer recycled content. Certification standard must be specified (GRS, RCS, or equivalent).

Example: 15% post-consumer recycled polyester (GRS certified)

Substances of Concern

ESPR Annex III §5

All substances listed in REACH Annex XIV (Authorisation List), REACH Annex XVII (Restriction List), or the ESPR Substances of Concern list, present above threshold concentrations.

Example: None detected above REACH threshold concentrations

Carbon Footprint

ESPR Annex III §6

Embedded carbon expressed in kg CO₂ equivalent per unit (cradle-to-gate or cradle-to-grave as specified by the delegated act). Must follow the applicable Product Environmental Footprint Category Rules (PEFCR).

Example: 3.2 kg CO₂e per unit (cradle-to-gate, PEFCR Apparel v1.3)

Durability and Repairability

ESPR Art. 7(2)(d)

Expected product lifetime, availability of spare parts, repairability score (where applicable), and links to repair manuals. For electronics: software update support period.

Example: Expected lifetime: 3 years | Repairability: High (single-material)

Repair and Disassembly Instructions

ESPR Annex III §7

Step-by-step instructions for repair, maintenance, and disassembly. Must be available to consumers, repair professionals, and recyclers. For complex products: must include tool requirements and safety warnings.

Example: Machine washable 40°C. No bleach. Tumble dry low.

End-of-Life Handling

ESPR Annex III §8

Specific recycling pathway, collection point information, and whether the product contains mixed materials that require special handling. Must include the applicable waste classification code.

Example: 100% recyclable via textile collection stream. EWC 20 01 11.

Certifications and Compliance Declarations

ESPR Annex III §9

All applicable third-party certifications with certificate numbers, issuing body, and expiry dates. EU Declaration of Conformity reference. Test report references.

Example: GOTS No. ZA-GOTS-2025-0891 (exp. 2027-03-31)

Data Carrier Requirements

ESPR Article 9(2) requires that every DPP must be accessible via a machine-readable data carrier physically attached to the product, its packaging, or its accompanying documentation. The data carrier must be durable for the expected lifetime of the product.

Accepted data carrier formats include: QR codes (ISO/IEC 18004), Data Matrix codes (ISO/IEC 16022), NFC chips (ISO/IEC 14443), RFID tags (ISO/IEC 18000), and GS1 Digital Link URIs. The choice of carrier depends on the product type, expected lifetime, and use environment.

For textiles, the QR code on a care label or hang tag is the standard approach. For batteries, an NFC chip embedded in the battery housing is preferred because it remains accessible throughout the battery's operational life. For construction products, a QR code on a durable label affixed to the product is standard.

Tiered Access Rights

Consumers

Product identity, material composition, care instructions, repairability information, end-of-life instructions, certifications.

Economic Operators

All consumer data plus: supply chain information, test results, compliance declarations, batch-level data, and supplier information.

Competent Authorities

All data including confidential commercial information, full supply chain data, internal test reports, and non-public compliance documentation.

Frequently Asked Questions

What are the mandatory data requirements for a Digital Product Passport?

Under Regulation (EU) 2024/1781 (ESPR), every Digital Product Passport must contain: (1) a unique product identifier, (2) product model/type/batch/serial number, (3) relevant commodity codes, (4) manufacturer name and address, (5) country of origin, (6) material composition including substances of concern, (7) recycled content percentage, (8) carbon footprint data, (9) durability and repairability information, (10) hazardous substances, (11) repair and disassembly instructions, (12) end-of-life handling instructions, and (13) applicable certifications. Additional fields are required by sector-specific delegated acts.

What data carrier is required for a Digital Product Passport?

ESPR Article 9(2) requires that the DPP data carrier must be a QR code, 2D barcode, NFC chip, RFID tag, or equivalent machine-readable identifier. The data carrier must be physically attached to the product, its packaging, or its accompanying documentation. It must be durable for the expected lifetime of the product. For textiles, the carrier is typically a QR code on the care label or hang tag.

Who can access the data in a Digital Product Passport?

ESPR Article 9(3) establishes tiered access rights. Consumers have access to: product identity, material composition, care instructions, repairability information, and end-of-life instructions. Economic operators (brands, importers, retailers) have access to: all consumer data plus supply chain information, test results, and compliance declarations. Competent authorities (customs, market surveillance) have access to all data including confidential commercial information. Repair and recycling operators have access to disassembly and material composition data.

What is the difference between ESPR DPP requirements and sector-specific DPP requirements?

ESPR Regulation (EU) 2024/1781 establishes the general framework and minimum data requirements that apply to all products. Sector-specific delegated acts then add additional requirements for each product category. For example, the Textile Delegated Act will require fibre composition by weight percentage and Product Environmental Footprint (PEF) scores. The Battery Regulation (EU 2023/1542) requires state of health data and supply chain due diligence. Manufacturers must comply with both the general ESPR requirements and any applicable delegated act.

Does the DPP need to contain the actual product documents?

No. The DPP contains structured metadata about the product — not the source documents themselves. The Africa DPP Registry uses a privacy-first architecture where source documents are processed in the user's browser to extract the SHA-256 hash and metadata. The document is never uploaded to the registry. This approach complies with POPIA and GDPR while maintaining the forensic integrity of the DPP record.

Ready to Mint a Compliant DPP?

The Africa DPP Registry's AI Extraction Chain reads your compliance documents and pre-populates all 13 required fields. Register free and mint your first passport today.

Related Resources

DPP Example: What a Real Passport Contains DPP for Textiles: Requirements and Timeline DPP Implementation: Step-by-Step Guide DPP Timeline: Every Deadline 2024–2030 DPP 2027: Which Products Are Mandatory EU ESPR Regulation: Full Overview

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Every page in this knowledge cluster is cross-referenced to the EU ESPR Regulation (EU) 2024/1781. Navigate the complete framework below.

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