Short answer
The Digital Product Passport under ESPR is a digital product record reached through a data carrier such as a QR code, and the first mandatory passports, under the Batteries Regulation, apply to certain batteries from 18 February 2027. Passport data belongs in the PIM. A DAM governs the packaging artwork that prints the data carrier and the new PPWR labels, with each artwork version linked to the data it shows.
What PPWR and ESPR change for product content
The Packaging and Packaging Waste Regulation (PPWR) and the Ecodesign for Sustainable Products Regulation (ESPR) add regulated labels, data carriers and product data that packaging artwork must show correctly.
The PPWR, Regulation (EU) 2025/40, applies from 12 August 2026 and brings harmonised packaging labels through implementing acts. The ESPR, Regulation (EU) 2024/1781, creates the Digital Product Passport and fills it product group by product group through delegated acts. Both regulations move compliance data into structured systems and onto the pack.
This page is orientation for DAM and PIM teams. It gives no legal advice: confirm the obligations for your products and markets with counsel and your packaging compliance lead.
PPWR dates and labelling status
The PPWR has applied since 12 August 2026, and its harmonised labelling rules depend on Commission implementing acts that the Commission was still preparing in October 2026.
The table lists what DAMSelection verified on EUR-Lex and Commission pages on 14 October 2026, with status labels as published.
| Date | What applies | Status |
|---|---|---|
| 22 January 2025 | Regulation (EU) 2025/40 published in the Official Journal | Fact |
| 11 February 2025 | PPWR enters into force | Fact, in force |
| 12 August 2026 | PPWR applies; Directive 94/62/EC is repealed, with some provisions continuing | Fact, applies |
| 12 August 2026 | Deadline for implementing acts on harmonised labels under Articles 12(6) and 13(2) | Fact; the sorting label act was still in preparation on the Commission implementation page in October 2026 |
| 12 February 2028 | Packaging covered by Article 9 must be designed for composting | Fact |
| 12 August 2028 | Harmonised labels under Article 12(1) apply, or 24 months after the implementing acts enter into force, whichever is later | Fact |
| December 2025 | Environmental Omnibus proposes suspending the authorised representative duty for direct sales to consumers in other Member States | Proposed amendment, under examination |
The Commission guidelines of 30 March 2026, C(2026) 2151, describe the labelling rules that artwork teams must plan for. Each harmonised label depends on implementing acts that set the final design.
- Harmonised sorting labels for all packaging under Article 12(1).
- Reusable packaging labels with a QR code or other standardised open digital data carrier under Article 12(2).
- Packaging in a deposit return system sits outside the sorting label duty, and Member States may require a harmonised colour label for it under Article 12(1).
- Harmonised deposit return labels are part of the implementing acts due under Article 12(6).
ESPR and Digital Product Passport timeline
The Digital Product Passport starts with batteries in February 2027, while ESPR passports for steel, textiles and other groups follow their delegated acts with at least 18 months of transition.
| Date | What applies | Status |
|---|---|---|
| 18 July 2024 | ESPR enters into force | Fact, in force |
| 16 April 2025 | First ESPR and Energy Labelling Working Plan adopted, with review in 2028 | Fact |
| 9 February 2026 | Rules on derogations from the destruction ban and on disclosure of discarded unsold goods adopted | Fact |
| 19 July 2026 | Ban on destroying unsold clothes, clothing accessories and footwear for large companies; medium-sized companies from 2030 | Fact, applies |
| 20 July 2026 | Digital Product Passport Registry operational | Fact |
| 18 February 2027 | Passport mandatory for certain batteries: electric vehicle, light means of transport and industrial batteries above 2 kWh | Fact, applies from |
| Q4 2026 | ESPR delegated act for iron and steel | Planned, indicative Commission timeline |
| 2027 | ESPR delegated acts for textiles, aluminium and tyres | Planned, indicative |
| 2028 and 2029 | Furniture, then mattresses | Planned, indicative |
Fact: the Commission states that once a product is registered, the Registry generates a unique URI for its passport. A digital data carrier, such as a QR code, links the physical product to that passport.
Where images fit in a Digital Product Passport
A Digital Product Passport holds product data such as safety, origin, materials, repairability and recycling information, and the delegated act for each product group sets the exact list.
Fact: the Commission's passport page describes those data categories and does not mention images. DAMSelection assessment: product images play three supporting roles, and none of them makes the DAM the passport system.
- The packaging and the product carry the data carrier, which is printed artwork the DAM governs.
- Instructions, safety leaflets and repair guides may be passport content in some product groups, and those documents often live in the DAM.
- Consumer-facing passport pages may reuse approved product images delivered from the DAM by URL.
Watch each delegated act for the data list of your product group. Iron and steel is first on the Commission timeline.
The PIM and DAM split
The PIM owns the regulated product data, and the DAM owns the artwork and documents that display or support it.
Read DAM vs PIM for the full division. The table applies it to packaging and passport content, as a DAMSelection assessment.
| Element | System of record | DAM role |
|---|---|---|
| Material composition per packaging component | PIM or PLM | Artwork shows the matching sorting label |
| Passport data per product | PIM, feeding the passport | Supplies document and image links |
| Unique product identifier and passport URI | PIM or ERP | Artwork prints the QR code or data carrier |
| Packaging artwork per market and language | DAM | Versions, approvals, final print files |
| Instructions and safety documents | DAM | Versioned files linked to the product |
| Deposit return label per Member State | PIM rule, DAM artwork | Market variants of the artwork |
Check how well your PIM and DAM candidates connect in the PIM and DAM Fit Map.
Why packaging artwork belongs in a governed system
Packaging artwork carries regulated labels, recycling marks, claims and data carriers, so each change needs approval, a version history and a link to the product and the market.
Shared drives keep files and lose the reason behind each change. A DAM with version control and approval workflows records who approved which label on which version. DAMSelection assessment: for a CPG brand, one label rule change can touch hundreds of artwork files across markets. The DAM must find them within three filters.
See the DAM shortlist for CPG packaging artwork and DAM for consumer packaged goods for candidate platforms.
Linking artwork versions to regulated data
Artwork stays compliant when every artwork version records which product, packaging component and data version it represents.
Model these links in the metadata schema before the first demo. DAMSelection rule of thumb: run the steps below as part of the shared PIM and DAM data model.
- Give each artwork file the product identifiers it covers, such as GTIN and internal SKU, as linked records.
- Link the artwork to each packaging component and its material composition record in the PIM.
- Store the data version or effective date the artwork was approved against.
- Store the label set shown on the artwork: sorting label, reuse label, deposit label and QR code target.
- Trigger a review task when the PIM changes a linked attribute or a label rule.
- Block release of print files whose linked data changed after approval.
Agree ownership of each step in the DAM governance model.
What to test with vendors
Vendors should prove artwork-to-data links on the buyer's own packaging files in a scripted demo.
Add these scenarios to your scripted DAM demo.
- Show an artwork file linked to three GTINs and two packaging components from the PIM.
- Change a material in the PIM and show the review task that the DAM raises.
- Compare two artwork versions and show which label changed and who approved it.
- Find every artwork file for one market that carries a given deposit return label.
- Show how the QR code target on the artwork is stored and checked against the PIM.
Frequently asked
Does the Digital Product Passport include product images?
The Commission's passport page lists safety, origin, materials, repairability and recycling data, and does not mention images. The delegated act for each product group sets the required data. Instructions, safety documents and approved images can still support the passport, delivered from the DAM by link.
When does the Digital Product Passport become mandatory?
The first mandatory passports apply to certain batteries from 18 February 2027. ESPR passports follow product delegated acts, with at least 18 months of transition after adoption. The Commission's indicative timeline puts iron and steel first, with textiles, aluminium and tyres in 2027.
When do PPWR labels apply?
The PPWR has applied since 12 August 2026. Harmonised labels under Article 12(1) apply from 12 August 2028, or 24 months after the implementing acts enter into force, whichever is later. The Commission was still preparing the sorting label act in October 2026.
Should packaging artwork live in the DAM or the PIM?
Packaging artwork should live in the DAM, with versions, approvals and final print files. The PIM holds the regulated data the artwork displays. Link each artwork version to the product identifiers and data version it represents, so a data change triggers an artwork review.
Was the PPWR postponed?
The PPWR was not postponed: it has applied since 12 August 2026. The Commission's Environmental Omnibus of December 2025 proposes a targeted change to the authorised representative duty. The Parliament and Council were still examining that proposal on the Commission page checked in October 2026.
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste (EUR-Lex)
- Regulation (EU) 2024/1781, Ecodesign for Sustainable Products (EUR-Lex)
- Regulation (EU) 2025/40 on packaging and packaging waste, EUR-Lex
- European Commission: Packaging waste
- European Commission: PPWR implementation timeline
- European Commission: Guidelines on the implementation of the PPWR, Annex to C(2026) 2151, 30 March 2026
- European Commission: Guidance on the Digital Batteries Passport, 21 August 2026
- Regulation (EU) 2024/1781 (ESPR), EUR-Lex
- Regulation (EU) 2023/1542 (Batteries Regulation), EUR-Lex
- European Commission: Ecodesign for Sustainable Products Regulation
- European Commission: Implementing the ESPR
- European Commission: Digital Product Passport
- European Commission: Ban on destruction of unsold clothes and shoes enters application