Do I need a Digital Product Passport?
If you place in-scope products on the EU market — including as a US or UK Shopify brand exporting to EU customers — the EU's Digital Product Passport rules will apply to you. Timing depends on your product category: batteries are first, with the mandatory deadline on 18 February 2027.
The short answer
Yes — if you sell to EU customers.
The Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781), which came into force on 18 July 2024, requires a Digital Product Passport (DPP) for products in designated categories placed on the EU market. “Placed on the EU market” covers e-commerce sales to EU consumers — your physical business address does not matter.
Requirements are being phased in by product category. No DPP delegated act is in force today (mid-2026), but the first deadline — batteries — arrives on 18 February 2027. Other categories follow on their own schedules.
Who is in scope
ESPR applies to any economic operator that places an in-scope product on the EU market. This includes:
- EU-based manufacturers and importers (the primary obligated parties)
- Non-EU (US, UK, Australian, etc.) brands selling direct-to-consumer into the EU
- Shopify merchants fulfilling EU orders from outside the EU
- Marketplaces and fulfilment providers acting as the importer of record
There is no EU-establishment requirement and no sales-volume exemption. If your product reaches an EU consumer, the regulation applies once your product category has an active delegated act.
US / UK Shopify brands — the key point
Selling through Shopify to EU customers is sufficient to bring you into scope. You do not need a warehouse, office, or legal entity in the EU. If a delegated act covers your product category, you must comply on the same schedule as EU-based sellers.
Which products and when
DPP requirements are activated category by category through delegated acts. The schedule below reflects the position as of mid-2026; all future dates are subject to formal adoption of the relevant delegated act.
Batteries — 18 February 2027 (first deadline)
EV batteries, light-means-of-transport batteries, and industrial batteries above 2 kWh. Portable and consumer batteries are excluded from this wave. This is the earliest mandatory DPP deadline across all product categories.
Textiles — adoption ~2027, enforcement ~late 2028–mid 2029
Textiles (including apparel and footwear) are an ESPR priority category. The Commission's preparatory work (a JRC study) is underway, with a formal proposal expected in late 2026 and adoption expected around 2027. Enforcement is realistically late 2028 to mid-2029. These dates are still evolving — monitor the European Commission's ESPR working plan updates.
Other ESPR priority categories
The first ESPR working plan covers six priority groups: textiles, furniture, mattresses, tyres, iron/steel, and aluminium. Each will receive its own delegated act and enforcement date. Timelines for these categories beyond textiles have not yet been formally set.
EU DPP Registry — 19 July 2026
The European Commission is required to stand up a DPP registry by 19 July 2026. This registry is a pointer directory: it stores product identifiers and resolves them to the URL where your DPP data is hosted. It does not host the passport data itself — that responsibility falls to a compliant DPP service provider.
What to do now
Even if no delegated act yet applies to your product category, the data collection required for a DPP typically takes 6–18 months. Starting now means you won't be scrambling against a regulatory deadline.
- Audit your catalog. Identify which products you sell into the EU and map them to the ESPR working-plan categories. Prioritise any products in battery, textile, or other priority groups.
- Gather supplier and materials data. DPPs require component-level information: materials, recycled content, supplier certifications, country of origin. Begin requesting this from your supply chain now.
- Assign a compliance owner. Designate someone internally (or an EU-authorised representative if you have no EU entity) to monitor delegated act progress and own the DPP programme.
- Start passports early. Creating draft passports before they are legally required lets you identify data gaps, train your team, and iterate without deadline pressure.
- Check your readiness score. Use our free DPP Readiness Scan to get a category-specific gap report in minutes.
How PassportBox helps
PassportBox is built specifically for Shopify brands — including US and UK merchants exporting to the EU — who need to get DPP-ready without enterprise-level complexity or cost.
- Shopify sync: import your product catalog automatically; no CSV wrangling required.
- Passport builder: structured templates aligned to ESPR data field requirements, including materials, components, and supplier records.
- QR code labels: generate print-ready QR labels (ISO/IEC 18004) that resolve to your hosted passport URL.
- Compliance scoring: real-time score per passport so you know what data is missing before a deadline arrives.
- SMB pricing: plans starting at a fraction of enterprise DPP solutions — designed for growing brands, not global corporations.
Common questions
- I'm a US brand selling into the EU — does this apply to me?
- Yes. The ESPR applies to any product placed on the EU market, regardless of where the seller is established. US and UK Shopify merchants who ship or sell to EU consumers are directly obligated once delegated acts for their product category take effect. There is no EU-establishment exemption.
- Is there a DPP requirement for every product right now?
- No. DPP requirements are being phased in category by category through delegated acts adopted under ESPR. No delegated act is in force today (mid-2026). The first mandatory DPP applies to certain batteries — effective 18 February 2027. Other categories, including textiles, follow on their own schedules.
- Which product category has to comply first?
- Batteries are first. EV batteries, light-means-of-transport batteries, and industrial batteries above 2 kWh must carry a DPP from 18 February 2027. Portable and consumer batteries are excluded from this first wave. Textiles are a priority ESPR category but the delegated act is expected to be adopted around 2027 with enforcement realistically starting late 2028 to mid-2029.
- I sell clothing/textiles — when do I need to comply?
- The textile delegated act is expected to be adopted around 2027, with enforcement realistically late 2028 to mid-2029. These timelines are still evolving — the Commission's preparatory work (a JRC study) is underway, with a formal proposal expected in late 2026. You are not legally required to have a DPP for textiles today, but starting data collection now dramatically reduces the compliance burden when the deadline arrives.
- What is the EU DPP registry and do I need to register?
- The EU DPP registry (due 19 July 2026) is a pointer directory — it stores product identifiers and resolves them to the URL where your DPP data is hosted. It does not host the passport data itself. Once delegated acts for your category are in force, your products will need to be registered so regulators and consumers can look up the DPP. PassportBox handles the data hosting side.
- What if I only sell a small volume to the EU?
- ESPR does not include a de-minimis sales-volume exemption. If you place an in-scope product on the EU market — even a single unit — the regulation applies. Small and medium businesses are subject to the same substantive requirements, though the EU does provide some SME guidance resources.
Disclaimer: This is general information, not legal advice. Regulatory requirements and dates are evolving — verify against official EU sources.