European Product Act: What It Means for Digital Product Passports

The European Product Act is the EU's planned reform of its rules for putting products on the market, and it could reshape product compliance across the EU. The Commission ran two consultations on it, and its agenda now lists the proposal for 15 December 2026.

The key question: should Digital Product Passports become the foundation for product compliance, market surveillance and online product safety?

The consultations are closed, and no date has been set for when businesses would have to comply.

Who was asked: manufacturers, importers, distributors and authorised representatives.

What was asked

• Should product labelling be fully digitalised?
• Would digital compliance data via DPPs support customs and authorities?
• Which data carrier (QR code, RFID, NFC) should access the DPP?
• Should online product listings always include the compliance information in a DPP?

What the consultation found

The Commission's factual summary of 4 March 2026 (299 responses) showed support for putting more compliance information into Digital Product Passports: 88% of those who answered the question (192 of 218) strongly agreed that a passport should include the information now in the declaration of conformity or performance. Support for digital information did not mean dropping every physical requirement: only 24% of all respondents (71 of 299) agreed that instructions should be digital only, and 60% wanted the physical CE marking to stay, complemented by a digital display. The Commission notes the responses are not representative of the wider population. These are findings, not final rules.

What the Act would do to the Digital Product Passport

The Commission says the update should bring digital solutions into product law, "e.g. by introducing the Digital Product Passport". Reporting on an unofficial draft suggests passports where sector law requires them and a simpler record for other products. That may change.

When it could apply

No application date has been established. The EU's roadmap targets the end of negotiations by Q4 2027, which does not decide when businesses would have to comply.

Why it matters and what to do now

Today's compliance model is fragmented and paper-heavy, especially in cross-border commerce. DPPs could enable structured digital compliance data, real-time authority access, and clearer online disclosure, while reducing packaging and documentation burden over time.

While the proposal is pending, structured product data and supplier evidence may reduce future work. Whether an existing passport meets future requirements will depend on the final legislation.

Learn More: Digital Product Passports by Tappr

Tappr integrates with your existing systems, filling Digital Product Passports with your compliance, traceability, and sustainability data. Our platform brings together the tools to create Digital Product Passports for EU Ecodesign requirements.

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