Digital Product Passport Examples: What the Four Passports That Legally Exist Today Actually Contain

Search for Digital Product Passport examples and you will mostly find renderings: a hand holding a phone, a QR code on a hangtag, a clean screen showing four or five fields a designer invented. They are useful for a board slide and useless for a data model.

There is a better source of examples. Four EU regulations already specify, in an annex, what a passport for their product must contain. They were written by different directorates, at different times, for different reasons - and reading them side by side tells you more about what your own passport will look like than any mockup will. The differences are not arbitrary. They show which design choices the Commission has settled and which are still up for grabs.

Example 1: the battery passport - the reference implementation

Regulation (EU) 2023/1542 is the only one of the four that bites soon: from 18 February 2027, every EV battery, every light means of transport battery, and every industrial battery above 2 kWh placed on the market needs one.

What makes it the reference example is Annex XIII, which splits the content into three access tiers:

• Public (Annex XIII point 1) - battery category, chemistry, rated capacity, nominal voltage, expected service life, carbon footprint and performance class, and recycled content percentages for cobalt, lithium, nickel and lead.
• Notified bodies, market surveillance authorities and the Commission - conformity and technical documentation.
• Persons with a legitimate interest - detailed composition, dismantling and disassembly information, and per-unit performance data such as state of health and cycle count.

Two things about this example are worth stealing. First, the passport is per unit, not per model: state of health is a property of this battery. Second, most of the commercially sensitive data is not public - the "everyone can see my bill of materials" fear that stalls DPP programmes is not what the law actually says.

And one thing to note rather than steal: the implementing act defining who counts as having a legitimate interest was legally due on 18 August 2026 and has not been adopted. The tier exists; the membership rules do not yet.

Example 2: the toy DPP - the passport that replaces the paperwork

The Toy Safety Regulation, (EU) 2025/2509, is the clearest example of a passport designed to remove an obligation rather than add one. Where the DPP contains everything the EU declaration of conformity requires, it discharges the DoC obligation outright.

Its content list is consequently conformity-shaped, not sustainability-shaped:

• unique product identifier and a clear colour image of the toy
• manufacturer and importer names, addresses and contact details
• references to the EU legislation the toy conforms to, and the harmonised standards or common specifications used
• a statement that the passport is issued under the sole responsibility of the manufacturer
• a contact route for safety concerns and complaints

It is a per-model passport, accessible through a data carrier, in the relevant EU languages, and kept for ten years after the toy is placed on the market. Not one field concerns recycled content or carbon footprint.

The lesson for anyone assuming DPP means "sustainability data": it does not. It means product data the authorities want machine-readable, and what that turns out to be depends entirely on which directorate wrote your regulation.

Example 3: the detergents DPP - a passport on a consumable

Regulation (EU) 2026/405, published in March 2026, puts a passport on every detergent and end-user surfactant placed on the EU market from 23 September 2029. A bottle of washing-up liquid is not a durable good, has no repair pathway and no second life - and it gets a passport anyway.

Its interest as an example is structural rather than substantive. The regulation requires the passport to be machine-readable, structured and searchable; tied to a unique product identifier; carried by a data carrier such as a QR code; registered in the Commission's central registry; and declared at customs when an imported product is presented at the border. Technical documentation and the passport are kept for ten years from placing on the market.

That list is ESPR's plumbing, borrowed wholesale into a chemicals regulation. It is the strongest available evidence that the identifier-carrier-registry pattern is now the EU default, and that a product being a consumable is not a reason to expect an exemption.

Example 4: the construction DPP - the one that lasts 25 years

The recast Construction Products Regulation, (EU) 2024/3110, merges the declaration of performance and the declaration of conformity into a single DoPC and makes the passport the digital layer carrying it. Content arrives per product family through delegated acts, so there is less to read today than for the other three.

What is already distinctive is duration. The construction DPP system must remain accessible for 25 years after the last product of that type is placed on the market. Compare that to ten years for toys and detergents.

If you build a passport architecture around a retention assumption of a decade and your products end up in a building, you have designed the wrong system. Persistence is a first-class requirement, not an operational detail - which is precisely why one of the six harmonised DPP standards published in 2026 is devoted to data storage, archiving and persistence.

What the four have in common - and where they diverge

	Battery	Toy	Detergent	Construction
Granularity	Per unit	Per model	Per product	Per product type
Access tiers	Three	Essentially public	Public plus authorities	Set per delegated act
Replaces paperwork	No	Yes, the DoC	Extends digital labelling	Yes, via the DoPC
Retention	Per Article 77	10 years	10 years	25 years
Hard date	18 Feb 2027	Per 2025/2509 transition	23 Sep 2029	Per delegated act

The constants are the ones to design against: a unique product identifier, a machine-readable data carrier on the physical product, registration in the central EU Registry, and a defined access model. Those four appear in every example, and they are exactly what Commission Implementing Decision (EU) 2026/1736 standardised in July 2026 when it cited the first harmonised DPP standards in the Official Journal.

The variables are content, granularity, access tiers and retention. All four are set by your sectoral act, and none of them can be safely guessed in advance.

How to use these examples

If your product group has no delegated act yet - which, in September 2026, is every ESPR product group - these four annexes are the best specification available to you. Not because your fields will match theirs, but because the shape of the obligation is now visible and stable.

Build the identifier, the carrier and the registration path now: they are invariant across all four examples and will be invariant in yours. Model the access tiers as configuration rather than as code, because the tiering differs in every regulation and, in the battery case, is still being written. Set your retention assumption from the longest-lived market you sell into, not the shortest.

And when a vendor shows you a passport mockup, ask which annex it came from. If the answer is "our design team", you are looking at a rendering, not an example.