Digital Product Passport or digital manual: what is the difference?
A Digital Product Passport is a data record the EU will require for selected product groups, one group at a time. A digital manual is how your customers learn to use the product, and no regulation has to arrive before you can offer one. Only batteries have a fixed passport date so far.
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- General information, not legal advice
What is a Digital Product Passport?
The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, entered into force in July 2024. It lets the Commission set product rules through delegated acts, group by group. A Digital Product Passport (DPP) is defined there as a set of data specific to a product, holding what the applicable delegated act lists, and reached electronically through a data carrier such as a QR code (Article 2(28)).
The essentials, from Articles 9 to 11 and Annex III:
- It is a condition of sale. Where a delegated act requires a passport, the product can be placed on the EU market only if the passport is available (Article 9(1)).
- The delegated act decides the details: the data, which data carrier and where it goes, whether the level is model, batch or item, who may see what, who may update it and how long it stays available (Article 9(2)).
- It must meet technical requirements: a persistent unique product identifier, open and interoperable data, controlled access rights and data integrity (Articles 10 and 11).
- It needs a back-up. The economic operator placing the product on the market makes a back-up copy available through a DPP service provider (Article 10(4)).
The obligation also reaches exporters. A manufacturer must ensure the passport is available before placing the product on the market (Article 27), and an importer must ensure the same for what it brings in (Article 29). If you make in India and sell into the EU through an importer, expect that importer to ask you for the data.
How does it differ from a digital manual?
Both can sit behind a QR code, which is why they get confused. They answer different questions: a passport tells the market what a product is made of and how it can be repaired and recycled, and a manual tells the owner how to use it.
| Digital Product Passport | Digital manual or product page | |
|---|---|---|
| Why it exists | Required by a delegated act for a product group. | Your choice, to help customers and reduce support. Some rules allow or expect digital instructions under conditions. |
| Who it serves | Customers, repairers, recyclers, customs and market surveillance authorities, each with their own access rights. | Owners, installers and your support team. |
| Contents | Set by the delegated act from the list in Annex III: identifiers, compliance documents, materials and sustainability data, and more. | Whatever helps: setup, videos, troubleshooting, warranty, spare parts. |
| Identifier | A persistent unique product identifier that meets the listed standards. | Any stable web address you control. |
| Level | Model, batch or item, as the delegated act says. | Usually one page per model. |
| Registration | Unique identifiers go in the EU registry. | None. |
| Where it applies | Products placed on the EU market in a covered group. | Anywhere. |
There is some overlap. Annex III allows a passport to include user manuals, instructions, warnings or safety information where other EU law requires them, and the delegated act decides whether it does for your group. A passport may therefore point at a manual, but a manual page on its own is not a passport. It has none of the identifier, registry, access-rights or back-up requirements.
When does it apply?
Check the date type before you plan around it. Most of the dates below are when the Commission expects to adopt a delegated act, not when you must comply. ESPR Article 4 says a delegated act can’t apply earlier than 18 months after it enters into force, except in justified cases, and the Commission’s page describes a transition of at least 18 months after adoption.
| Product group | Date | What the date means | Source |
|---|---|---|---|
| LMT batteries, industrial batteries above 2 kWh, EV batteries | 18 February 2027 | Passport mandatory. Set in law. | Regulation (EU) 2023/1542, Art. 77 |
| Iron and steel | Q4 2026 | Indicative adoption of the delegated act. | Commission DPP page |
| Construction materials | Q2 2027 | Indicative delegated act, under the Construction Products Regulation. | Commission DPP page |
| Textile apparel, aluminium, tyres | Q3–Q4 2027 | Indicative adoption of delegated acts. | Commission DPP page |
| Furniture | 2028 | Indicative adoption. | Commission DPP page; COM(2025) 187 |
| Mattresses; recycled content rules | 2029 | Indicative adoption. | Commission DPP page; COM(2025) 187 |
| Repairability rules, possibly including consumer electronics and small household appliances | 2027 | Indicative adoption of a horizontal measure. Scope still to be refined. | COM(2025) 187 |
| Household washing machines and dishwashers | 2026 | Indicative adoption of ecodesign and energy label measures. No passport date stated. | COM(2025) 187 |
| Household refrigerators and freezers | 2028 | As above. | COM(2025) 187 |
| Mobile phones and tablets; tumble dryers | End of 2030 | As above. | COM(2025) 187 |
| Everything else | Not set | No date. The Commission can still set requirements for groups outside the plan, and the plan has a mid-term review in 2028. | COM(2025) 187 |
Two general points from the working plan: every product that gets ecodesign measures will have a passport unless an alternative digital system gives equivalent information, and the plan names the EU energy-label database (EPREL) as an example for energy-labelled products. So an appliance with an EU energy label may not need a separate passport, but its delegated act will say. On the infrastructure side, the Commission reports that the DPP registry went live on 20 July 2026, and it lists a delegated act for service providers in 2027.
You may see a single “DPP deadline” quoted. There isn’t one. If you see a date for your product that isn’t in a delegated act or the Commission’s own timeline, treat it as a guess.
Who needs which, and when?
Use your situation, not the headlines:
| Your situation | Passport | Digital manual |
|---|---|---|
| You sell only in India | Not required by these EU rules. | Useful now. See the India page. |
| You export batteries of the covered types to the EU | Yes, from 18 February 2027. Plan now. | Useful alongside it. |
| You export apparel, furniture, tyres, mattresses, steel or aluminium to the EU | Likely, once the delegated act is adopted and applies. Watch the act and talk to your importer. | Useful alongside it. |
| You export appliances or electronics to the EU | Not yet set. Read the measures for your product as they appear, including how EPREL is treated. | Useful now. GPSR and sector rules still decide what stays on paper. |
| You export machinery to the EU | No group called machinery in the working plan, though it lists items such as welding equipment and electric motors. Check yours. | Machinery Regulation digital instructions apply from 20 January 2027. |
For what must still travel with the product in the EU, see GPSR and QR codes and the Machinery Regulation guide. Neither a passport nor a manual page removes those obligations by itself.
Can one QR code do both?
Nobody can say yet for most products. The delegated act specifies which data carrier to use, how it is laid out and where it goes (Article 9(2)(b) and (c)), and the carrier must meet the listed standards (Article 10(1)(c)). Until your delegated act exists, you can’t know whether the code on your box today would qualify.
The practical reading: don’t redesign your packaging for a passport that has no specification. Print the code your customers need now. When your delegated act appears, follow it, and expect the passport carrier to be a separate piece of artwork unless the act allows otherwise.
Where ItemDocs fits, and where it doesn’t
ItemDocs is not a Digital Product Passport provider. It has no GS1 Digital Link resolver, no connection to the EU registry, no role-based passport access and no item-level identifiers. Its unit of work is one page per product model, and it won’t make a product ESPR-compliant.
What it does is the customer-help side: one permanent code that opens the manual, videos, troubleshooting, warranty registration, spare parts and support. If your product group has a passport date, you need a DPP service provider or specialist passport software, which is a different kind of tool. You can run both. See how the product page works, and model-level versus serialised codes if a vendor is telling you that you need per-unit codes today.
- List your products and the markets you sell them in. If none reach the EU, stop here for now.
- Match each one to the table above, using the Commission’s page rather than a blog.
- For batteries of the covered types, read the Commission’s Digital Batteries Passport guidance.
- Ask your EU importer what data it expects from you, and when.
- Before buying passport software, read the delegated act or its draft. Ask vendors which level it requires and how they meet the back-up and registry rules.
- Don’t hold back customer help while you wait: manuals and support can go online now.
Sources
Checked
Links open the original documents.
- [1]Regulation (EU) 2024/1781 (ESPR): Articles 2, 4, 9, 10, 11, 13, 27, 29, 80 and Annex IIIEUR-Lex
- [2]Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187 finalEuropean Commission, via the Council of the EU
- [3]Digital Product Passport: overview and indicative timelineEuropean Commission
- [4]The Digital Product Passport for iron and steelEuropean Commission
- [5]Regulation (EU) 2023/1542 on batteries and waste batteries: Article 77EUR-Lex
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