What the ESPR requires of a data carrier
The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (ESPR), in force since 18 July 2024, requires a passport to be connected through a data carrier to a persistent unique product identifier (Article 10). It names no technology: a data carrier is a linear barcode, a two-dimensional symbol or another automatic identification medium a device can read, so NFC and RFID chips qualify as well as QR codes.
Article 10(1)(c) pointed carriers and identifiers to the ISO/IEC 15459 series in Annex III, or an equivalent standard, until harmonised standards were published. Since 15 July 2026, EN 18219 (unique identifiers) and EN 18220 (data carriers) are harmonised: a passport whose carrier and identifier follow them is presumed to meet the Article 10 and 11 requirements those standards cover (Implementing Decision (EU) 2026/1736).
Each product group's delegated act sets the rest (Articles 9(2) and 10): which carriers may be used, their layout and position (product, packaging or accompanying documentation), and whether one passport covers a model, a batch or each item.
When the passport becomes mandatory
There is no single DPP deadline; each product group starts when its act applies. Only the battery date is fixed in law; the others come from the Commission's indicative DPP timeline. Under ESPR Article 4(4), a delegated act normally applies no earlier than 18 months after it enters into force (earlier only in duly justified cases), so adoption dates are not compliance dates. The EU DPP Registry, which stores unique identifiers, went live on 20 July 2026.
| Product group | Legal basis | Position in September 2026 |
|---|---|---|
| LMT, industrial (over 2 kWh) and electric vehicle batteries | Batteries Regulation (EU) 2023/1542, Article 77 | Required from 18 February 2027 |
| Iron and steel | ESPR delegated act | Adoption planned for Q4 2026 |
| Construction products | Construction Products Regulation delegated act | Adoption planned for Q2 2027 |
| Textile apparel, aluminium, tyres | ESPR delegated acts | Adoption planned for Q3–Q4 2027 |
| Furniture | ESPR delegated act | Adoption planned for 2028 |
| Mattresses | ESPR delegated act | Adoption planned for 2029 |
The battery passport requires a QR code
Regulation (EU) 2023/1542 requires a battery passport from 18 February 2027 (unchanged in the July 2025 consolidated text) for each light means of transport (LMT) battery, industrial battery above 2 kWh and electric vehicle battery (Article 77). It is reached through a QR code linked to a unique identifier, both following ISO/IEC 15459 (Article 77(3)).
From that date all batteries carry a QR code (Article 13(6)), printed or engraved visibly, legibly and indelibly on the battery or, where that is not possible or not warranted given its nature and size, on its packaging and accompanying documents (Article 13(7)). Article 13(8) lets the Commission add other smart labels by delegated act; until then, an NFC or RFID tag on a battery is an optional extra, never a substitute.
QR code, NFC or UHF RFID as the carrier
A QR code is the cheapest carrier; NFC adds a tap and, with the right chip, authentication; UHF RFID reads in bulk but not with a phone. The Commission's DPP FAQ says QR codes and NFC chips are being considered per product group.
EN 18220:2026, the harmonised carrier standard, covers two-dimensional symbols (QR Code, Data Matrix) and radio-frequency carriers (HF RFID, NFC, and RAIN (UHF) RFID per ISO/IEC 18000-63). It sets requirements for encoding, reading, print quality, durability and placement, and includes a radio-frequency privacy clause. Secure elements and cryptographic features are out of scope.
| Criterion | QR code | NFC tag (13.56 MHz) | UHF RFID label |
|---|---|---|---|
| Read by | Any phone camera or scanner | NFC phones and HF readers, at a few centimetres | UHF readers, many tags at once, at 865–868 MHz in the EU (ETSI EN 302 208); not phones |
| Copying | A photograph copies it | Static URLs can be copied; NTAG 424 DNA adds a per-tap check | A plain EPC can be written to another tag |
| Main DPP role | Access with any phone camera | Consumer tap, authentication, surfaces where print wears | Supply-chain, retail and returns processes |
| From Proud Tek | Printed on our labels, confirmed per quotation | NTAG213 and NTAG 424 DNA labels | UHF labels and inlays |
Unique identifiers and GS1 Digital Link
ESPR's unique product identifier is a unique string that also enables a web link to the passport; Annex III lists the GTIN (ISO/IEC 15459-6) among passport data. ESPR does not require GS1, but for products already carrying GTINs, GS1 Digital Link turns them into a web address.
A Digital Link address joins a domain, /01/ plus the GTIN and /21/ plus a serial number. Printed in a QR code and written to an NFC tag as an NDEF URI record, the same address opens one passport from both carriers. For UHF, GS1's EPC Tag Data Standard 2.3 (October 2025), referenced by EN 18220, added encodings that carry a domain name with the EPC, so a tag decodes to a web address.
Decide the level early: a model-level passport can use one carrier design throughout; batch or item level needs variable-data printing and per-item encoding.
Choosing a tag for each product type
Where the delegated act allows a chip, a practical pairing for consumer goods is a printed QR code plus an NFC label holding the same URL, locked after encoding. A suitable NFC tag runs on ISO/IEC 14443 or 15693 (both referenced by EN 18220), holds your URL as an NDEF URI record, can be permanently locked, and reads on your product's surface for its whole life.
- Packaging and consumer goods: an NTAG213 NFC label (144 bytes of user memory, per the NXP datasheet), with the same URL printed as a QR code.
- Products at risk of counterfeiting: an NTAG 424 DNA label (NFC Forum Type 4, AES-128), whose SUN feature adds a changing, verifiable code to the URL on each tap (NXP). Check that your DPP resolver accepts the extra parameters.
- Supply chain, retail inventory and returns: UHF RFID labels, or dry and wet UHF inlays for your own converting, encoded with a serialised EPC and paired with a consumer-facing carrier.
- Garments and textiles: a sewn-in woven tag built like our textile laundry tags, or a care label with a UHF inlay inside; any printed QR code is agreed in the quotation and wash-tested. The Commission's textile apparel page expects the carrier on the product itself. Our woven laundry tag holds an OEKO-TEX Standard 100 certificate (ask for its scope).
- Hard goods and metal housings: a custom RFID tag, on-metal, encapsulated or shaped to fit, sampled per project.
- One tag for phone and warehouse: chips such as EM Microelectronic's em|echo-V (EM4425) put NFC (Type 5 Tag) and UHF (ISO/IEC 18000-63, EPC Gen2v2) on one die with shared memory. Dual-frequency tags are a custom build; ask about sampling.
NFC labels 
Woven textile UHF tags
Designing a carrier that lasts the product's life
A passport must stay available for at least the product's expected lifetime (Article 9(2)(i)), and Recital 37 asks for the carrier on the product itself where possible so the data stay reachable. Design for that unless your delegated act allows packaging or documentation; a swing tag cut off at the till will not do it.
- Print and encode the same identifier and check they match on every piece, as our encoding service does.
- Lock what should not change: write-protect the URL or EPC after encoding.
- Test on the product, not the bench: metal and liquids detune antennas; washing, heat and abrasion wear print and inlays.
- Make it recognisable: EN 18220 covers indicators that help people find a DPP carrier; follow your delegated act's layout.
Who does what in a DPP programme
The tag supplier provides the carrier; the passport, its data and its registration belong to the economic operator, often with a DPP service provider.
| Task | Responsible | Where it is set |
|---|---|---|
| Collect and maintain product data | Brand owner or importer | ESPR Article 9 and the delegated act |
| Allocate identifiers (GTIN, serial) | Brand owner | ESPR Annex III; EN 18219 |
| Host the passport | Economic operator or DPP service provider | ESPR Article 11(c) |
| Keep a back-up copy | Independent DPP service provider authorised by the operator | ESPR Articles 2(32) and 10(4) |
| Upload identifiers to the EU registry | Economic operator placing the product on the market | ESPR Article 13(4) |
| Resolver, access rights and authentication checks | Brand's IT team or DPP provider | ESPR Articles 10 and 11 |
| Chip, antenna, label construction and print | Tag manufacturer | Your specification (citing EN 18220 where required), proved on samples with your provider's app or readers |
| Encode, lock and read back each tag | Tag manufacturer or your own team | Your identifier file |
What Proud Tek supplies for DPP carriers
Proud Tek is an RFID and NFC tag, label and card factory in Shenzhen, producing since 2008. For DPP programmes we make NTAG213 and NTAG 424 DNA NFC labels, UHF RFID labels of all kinds, dry and wet UHF inlays, woven textile tags and custom tags, encoded from your identifier file. Construction, print and encoding are confirmed per order and proved on samples.
We do not supply DPP software, hosting, resolvers, registry upload, product data, life-cycle assessment or legal advice, nor UHF readers, RFID label printers or UHF encoders; our reader range is desktop NFC readers, used for encoding and testing. Standard items generally take 2–3 weeks, large orders are scheduled individually, and quotations follow within one business day of a workable inquiry.
To quote or sample, send us:
- Product and carrier: product group and delegated act if known, carrier type and position (product, packaging or documents), identifier level, and one sample URL or EPC scheme.
- Surface and environment: material, space, QR size, and exposure to washing, heat, outdoors or metal.
- Locking and keys: what to lock; for NTAG 424 DNA, whether your integrator personalises the keys or we prepare an agreed configuration. Never send key values in an inquiry.
- Volumes: quantity, annual volume and destination.
Published 2026-09-26 · Updated 2026-09-26
