A working almanac Thursday, 12 November 2026
Reviery

 —  5 min read

Why is the EU giving products a passport?

A ban on destroying unsold clothes led me to a much bigger EU idea, the digital product passport. What it is, who gets one first, and how much of it is already running.

On 19 July this year a rule kicked in that I had completely missed while it was being made. Big companies in the EU are no longer allowed to destroy clothes and shoes they couldn’t sell, so shredding or incinerating last season’s jackets just to clear the warehouse is off the table. Medium-sized firms follow in 2030. The smallest businesses are exempt.

I took it for a one-off law about fashion waste. When I looked up where it came from, it turned out to be a single article in a much bigger regulation, the Ecodesign for Sustainable Products Regulation, which everyone shortens to ESPR. The same regulation brings something that will eventually reach far beyond clothes: the digital product passport.

So I’m starting a series on it. I read what the law and the Commission actually say, write down what I understood and link everything. This first post covers what a product passport is, and how much of it exists yet.

A passport, but for a thing

The legal definition is drier than the name. The ESPR calls a digital product passport “a set of data specific to a product”, reachable electronically through a data carrier. In plain terms, a code on the product (a QR code, for example) is tied to a unique product identifier, and that identifier doubles as a web link. Scan the code and you land on the passport.

The Commission’s own description is friendlier. It calls the passport “a digital container for products, components, and materials” and then adds the part I found most interesting: “By scanning the data carrier, different users can access the DPP information relevant to them.” One code, several views. The regulation even spells out who is meant to get free access according to their rights. Customers are on that list, and so is everyone who fixes, refurbishes or recycles things for a living. Customs and market surveillance authorities are there as well, and further down you find civil society groups and trade unions.

Most of us have already seen something close to this on the EU energy label. Newer labels carry a QR code that leads to EPREL, the EU’s database of energy-labelled products, and the Commission dates those codes to 2021. I’ll admit I had never really noticed it until I went looking. The passport is meant to go a good deal further, with information for repair, reuse and recycling, and with different views for different people.

The law is a framework, which explains a lot

This is what changed my picture most. The ESPR has been in force since 18 July 2024, and on its own it requires exactly zero passports. What it sets up is a framework. Article 9 says a product can only be placed on the market “if a digital product passport is available in accordance with the applicable delegated acts”. Those delegated acts are separate pieces of law for individual product groups, and each will spell out what its passport has to contain.

Then comes a waiting period. Article 4(4) says such an act can’t apply earlier than 18 months after it enters into force, apart from justified exceptions. Companies get time to collect the data, which seems fair. It also means that any headline along the lines of “passports for everything from next year” deserves a second look.

Who goes first

Batteries, and they don’t even come through the ESPR. The EU’s Battery Regulation from 2023 has its own passport. From 18 February 2027 every LMT battery (the kind in e-bikes, e-mopeds and e-scooters), every industrial battery above 2 kWh and every electric-vehicle battery placed on the EU market needs one. The Commission calls batteries “the first product group for which a DPP will become mandatory in the European Union.”

The battery passport hangs off a QR code too, and it is split by audience. Some of it is for the general public. Some is only for people with a legitimate interest, such as a repairer or a recycler. A third part is reserved for notified bodies, market surveillance authorities and the Commission. That’s the “different views” idea from above, in the first passport that will actually be required.

For everything under the ESPR, the Commission publishes an indicative timeline. Iron and steel are first, with their rules planned for the last quarter of 2026. Textiles, aluminium and tyres are pencilled in for the second half of 2027, and furniture for 2028. “Indicative” is doing a lot of work in that sentence. As of early November no ESPR product group has its passport rules yet, and once the 18 months are added on, even steel won’t need passports before 2028, by my count.

What already happened this summer

July 2026 is when this stopped being purely theory. The destruction ban that started all this for me has applied since 19 July to apparel, clothing accessories and footwear.

The registry arrived at the same time. The ESPR gave the Commission until 19 July 2026 to set one up, and the Commission’s timeline marks it as operational from 20 July. Despite the name, it doesn’t hold the passports. The Commission describes it as an indexing service that stores identifiers and registration details plus a little high-level metadata, rather than the detailed product information in the passport itself. Who gets to look into it, and whether that adds up to a central database of everything we buy, is a question I want to come back to.

Why go to all this trouble?

The Commission frames it around sustainability and circularity, which in plain words means keeping products in use for longer and recovering the materials at the end. Looking at who gets access, I’d put it more bluntly. The passport carries information to the people who keep things in use or take them apart once they’re done, and it gives inspectors and customs their own way in.

I can picture that working for a recycler who needs to know what’s inside an e-bike battery. Whether ordinary shoppers will scan anything is another matter, given how long it took me to notice the code on an energy label. My impression is that the design has already accepted this. Much of the value sits in the parts that consumers will never open.

Coming up

Next I’ll look at the battery passport, because it’s the first one that actually has to exist, and the law already spells out what goes into it. The clothes side, including what exactly the destruction ban covers, gets a post of its own later.

Sources

I checked every one of these in November 2026:

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