Digital Product Passport: What Indian Exporters Need to Know Before 2027
Breathe ESG publishes this guide. We say so up front because you should know who's behind what you read. It's built from European Commission sources on the Ecodesign for Sustainable Products Regulation (ESPR) and the EU Battery Regulation, plus Indian research on textile traceability. Commission dates marked "indicative" can still move. Last updated: November 2026.
The short answer
If you sell physical products into the EU, the Digital Product Passport (DPP) will reach you, even if you never register anything in Brussels yourself. The legal duty sits with whoever places the product on the EU market, usually your EU importer or buyer. The data, though, comes from you: materials, origin, carbon footprint, recycled content, repair and recycling info.
Batteries go first, on 18 February 2027. Iron and steel, textiles, aluminium and tyres follow, with rules expected between late 2026 and late 2027 and at least 18 months to comply after that. If you export in those categories, start collecting the data now.
What is a Digital Product Passport?
A DPP is a digital record attached to a single product, batch or model. A QR code or similar data carrier on the product links to it. Depending on the product group, the passport can hold information on safety, origin, materials, repairability, environmental performance, reuse and recycling.
It comes from the EU's Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781), in force since July 2024. ESPR sets the framework. Product-specific "delegated acts" then decide exactly what each passport must contain.
Two things are worth knowing:
- The EU doesn't hold your full data. The central DPP Registry, live since 20 July 2026, stores the unique identifiers and registration data. The full passport sits with the economic operator or a DPP service provider.
- Customs can check it. The Commission says imported products can be checked at customs. No valid passport, no market access.
Does the DPP apply to Indian companies?
Yes, if your products end up on the EU market and fall into a covered product group.
Here's how it plays out in practice. Your EU importer, distributor or your own EU entity is responsible for the passport. They can't build it without your data. So the requirement shows up in your inbox as a buyer questionnaire, a tender clause or a supplier onboarding form. For battery passports, European buyers are already asking about readiness in tenders.
The timing matters too. The India-EU Free Trade Agreement was concluded in January 2026, with signing expected by the end of 2026. Lower tariffs only help if your product can legally enter the market. As Down To Earth put it, if the FTA doesn't address how Indian firms get support on ESPR and DPP compliance, the tariff savings will mostly go to larger companies.
The DPP timeline: what's due when
| When | What happens | Status |
|---|---|---|
| July 2024 | ESPR enters into force | Done |
| April 2025 | First ESPR working plan sets the priority product groups | Done |
| 19 July 2026 | Ban on destroying unsold apparel and footwear applies to large companies | In force |
| 20 July 2026 | DPP Registry goes live | Done |
| Q4 2026 | Delegated act for iron and steel | Indicative |
| 18 February 2027 | Battery passport mandatory for EV, light means of transport (LMT) and industrial batteries above 2 kWh | Fixed in law |
| Q3 to Q4 2027 | Delegated acts for textiles, aluminium and tyres | Indicative |
| 2028 | Delegated act for furniture | Indicative |
| 2029 | Delegated act for mattresses | Indicative |
Once a delegated act is adopted, companies get a transition period of at least 18 months. In practice, steel passports could land around mid-2028 and textiles around 2029. That sounds far off. Building a supply chain data trail across five tiers of suppliers takes about that long.
DPPs are also coming in through other EU laws, including the Construction Products Regulation, the Toy Safety Regulation and the Detergents and Surfactants Regulation.
Which Indian sectors are most exposed?
Textiles and apparel. Textiles are one of India's biggest export categories to Europe, and one of the most fragmented supply chains. CSTEP describes India's textile supply chain as largely a "black box", with material data that's dispersed, opaque or not digitised. Moving from fibre to yarn to fabric to garment usually means moving between different MSMEs.
Iron, steel and aluminium. These are the first ESPR product groups in line, and they're already in scope for CBAM. If you've done CBAM reporting, you have a head start on embedded emissions data.
Batteries. Any Indian maker of EV, e-two-wheeler, e-three-wheeler or industrial battery packs (above 2 kWh) selling into the EU needs a passport from February 2027. Swappable packs for e-two- and three-wheelers count as LMT batteries. Laptop and phone batteries are excluded.
Tyres and furniture. Both are in the first working plan, with rules expected in 2027 and 2028.
What data goes into a DPP?
The exact fields depend on the product's delegated act. Expect most passports to ask for some mix of:
- A unique product identifier and the responsible economic operator
- Material composition and substances of concern
- Origin and supply chain information
- Carbon footprint, often by life cycle stage
- Recycled content share
- Durability, repairability and spare parts information
- Instructions for dismantling, reuse and recycling
The battery passport gives a good preview of where textiles and steel are heading. It requires carbon footprint calculated using a prescribed method, material composition with recycled content, supply chain due diligence data, performance and durability, and safety information. Some fields are public. Others are only for authorities and people with a legitimate interest.
For most exporters, carbon footprint and recycled content are the hardest fields. They depend on data from suppliers you may never have spoken to.
Digital Product Passport vs CBAM
Many Indian exporters will face both. They ask for overlapping data in different ways.
| CBAM | Digital Product Passport | |
|---|---|---|
| What it covers | Embedded emissions in imported goods | Full product sustainability record |
| Product scope | Iron and steel, aluminium, cement, fertilisers, hydrogen, electricity | Grows by product group: batteries, steel, textiles, aluminium, tyres, furniture and more |
| What it costs you | A carbon price paid through CBAM certificates | No direct fee, but no passport means no market access |
| Data focus | Emissions | Emissions plus materials, origin, durability, repair and recycling |
| Who's responsible | Authorised CBAM declarant in the EU | Economic operator placing the product on the EU market |
If you already track product-level emissions for CBAM, reuse that work. A product carbon footprint built on clean activity data feeds both. Our guide to CBAM-ready emissions tracking tools covers the CBAM side in detail.
What Indian exporters should do now
- Map your exposure. List what you ship to the EU, by product group. Check it against the ESPR working plan and the Battery Regulation. Mark which ones have rules coming first.
- Ask your EU buyers what they need. They carry the legal duty. Find out what data they expect from you, in what format and by when. Don't wait for the questionnaire.
- Map your supply chain past tier 1. For textiles, that means spinners, weavers, processors and dye houses. For steel and aluminium, it means where the metal is made and with what energy. Start with your top suppliers by volume.
- Build product-level carbon data. Company-level Scope 1 and 2 won't be enough. You need emissions per product or batch, and that leans heavily on Scope 3 data from suppliers.
- Get your material data in order. Fibre composition, recycled content and substances of concern, with documents to back them up.
- Pick one system of record. Spreadsheets emailed between tiers won't survive a DPP audit. Whatever you use, it should link every number back to its source.
How Breathe ESG helps
Breathe ESG supports all major global reporting frameworks, including BRSR and BRSR Core, GRI, CSRD and ESRS, CDP and CBAM. For exporters getting ready for the DPP, that gives you a single place to manage the data that keeps coming back across regimes: product carbon footprints, value chain and supplier data, and emissions that hold up to an audit.
It's software plus people:
- ESG consulting and fractional CSOs to map your EU exposure and build your data plan
- Breathe Academy to train your team on ESPR, CBAM and supply chain data
- Breathe Zero, a community of ESG professionals working through the same rules
- Breathe SAFE for EHS tracking across your sites
See how Breathe ESG works on your own data.
FAQs
Is the Digital Product Passport mandatory?
Yes, for product groups covered by a delegated act or by another EU law that requires one. The first mandatory passport is for batteries, from 18 February 2027. Other groups become mandatory once their delegated act is adopted and the transition period of at least 18 months ends.
Does the DPP apply to companies outside the EU?
The legal duty sits with the economic operator placing the product on the EU market. In practice, non-EU manufacturers supply most of the data, and imported products can be checked at customs.
When does the DPP apply to textiles?
The Commission's indicative timeline puts the textiles delegated act in Q3 to Q4 2027. With a transition period of at least 18 months, mandatory passports for textiles would likely start around 2029.
What is the battery passport?
A DPP required under the EU Battery Regulation (Regulation (EU) 2023/1542). From 18 February 2027 it applies to EV batteries, light means of transport batteries and industrial batteries above 2 kWh placed on the EU market.
Is the DPP the same as CBAM?
No. CBAM puts a carbon price on embedded emissions in certain imports. The DPP is a product-level data record covering materials, origin, footprint, durability and recycling. They share some data, especially emissions.
What is the DPP Registry?
A central EU registry, live since 20 July 2026. It stores each passport's unique identifier and registration data, not the full passport.
Sources
- European Commission, Digital Product Passport
- European Commission, EU-India Free Trade Agreement concluded
- Regulation (EU) 2024/1781, Ecodesign for Sustainable Products Regulation
- Regulation (EU) 2023/1542, EU Battery Regulation
- CSTEP, Digital Product Passports: Enabling Transparent Textile Supply Chains in India (July 2026)
- Down To Earth, Is the India-EU FTA equitable? Europe's Digital Product Passport raises questions (March 2026)
- EVreporter, Battery Passport 2027: what makers exporting to the EU actually have to do (June 2026)