A textile manufacturer ships goods to a retailer in Germany. Within the next few years, that product will carry a barcode on its label; when the customer scans it, they will see the fibre composition, the recycled content share, the chemicals used in production, and what to do with the item at end of life. A product that cannot provide this data will not enter the EU market once the relevant rule takes effect. The European Union calls this the Digital Product Passport (DPP).
The DPP is one of the most concrete instruments of the circular-economy pillar of the European Green Deal. And it speaks directly to manufacturers in Türkiye: a large share of our exports goes to the EU, so a rule set there sooner or later becomes a rule on our production line. This piece lays out, in plain terms, what the passport is, how the timeline works, and where preparation begins.
What exactly is a digital product passport?
The passport is a unique digital identity attached to a product. It is linked via a data carrier — a QR code, data matrix or RFID tag — and, when scanned, gives access to structured, machine-readable data about that item. The content varies by product group, but it typically covers:
- Material and composition data (e.g. fibre composition, recycled content share)
- Repair, spare-part and maintenance information
- Chemical and hazardous-substance content
- Carbon footprint and environmental performance data
- Recycling and disposal instructions at end of life
The purpose fits in one sentence: make the product transparent and fit for the circular economy, so that the consumer, the repairer, the recycler and the auditor can all reach the same data.
The legal ground: ESPR is a framework, obligations arrive one by one
The passport rests on the EU’s Ecodesign for Sustainable Products Regulation — ESPR (Regulation (EU) 2024/1781). It was published in the Official Journal on 28 June 2024 and entered into force on 18 July 2024. The DPP is defined in Article 9 of the regulation as the core compliance mechanism.
The key point: ESPR is a framework regulation. On its own it does not say “this data is mandatory for this product.” The obligation is switched on through secondary legislation — a delegated act — that the Commission issues separately for each product group. Once rules for a product group are adopted, businesses are usually given a preparation window of 18 months or more.
The Commission adopted its first ESPR Working Plan (2025-2030) in April 2025 and set out the priority product groups. So the timeline is not a single date; it is a sequence that advances group by group.
Which products, and when?
The table below summarises the headline schedule. The dates are indicative and shift as the regulatory process moves; confirm exact obligations against European Commission and EUR-Lex sources.
| Product group | Legal basis | Status (indicative) |
|---|---|---|
| Industrial and EV batteries (above 2 kWh) | EU Battery Regulation 2023/1542 | Battery passport from 18 February 2027 |
| Iron and steel | ESPR working plan | Among the first, rules around 2026 |
| Textiles and apparel | ESPR working plan | Priority group, expected after 2027 |
| Furniture, tyres, aluminium | ESPR working plan | In later waves |
One distinction matters: the battery passport is not part of ESPR but of a separate instrument — the EU Battery Regulation (2023/1542). It is also the obligation with the clearest date: a battery passport is required for industrial and electric-vehicle batteries above 2 kWh from 18 February 2027. The ESPR groups — textiles, iron and steel, furniture — follow through their own product-specific rules.
What it means in practice for manufacturers in Türkiye
The DPP is not yet a local legal requirement in Türkiye. But that does not translate to “it doesn’t concern me.” For a manufacturer shipping to the EU, the passport becomes a technical entry condition at customs. A product without a passport will not enter the EU market once the rule applies to its group.
It is worth reading this in the same logic as CBAM. Just as CBAM asks for your carbon data, the DPP asks for your product’s material and circularity data. Both point in the same direction: selling into the EU requires keeping measured, documented, shareable data about your product. Green transition and digital transition are no longer two separate projects; the passport sits exactly where the two meet.
To produce a passport, you first need data
A DPP is, in effect, a reporting output. The quality of the output depends on the quality of the data behind it. In practice, producing a passport requires three things:
- Product and material data held digitally and in a structured way. Raw-material information from suppliers, recipes, batch/lot traceability — these should live in a single system, not scattered across spreadsheets.
- The ability to collect supply-chain data. Recycled content share, or the source of a chemical, is often not your data but your supplier’s. You need a flow that requests and verifies this data on a regular basis.
- Export via a standard, machine-readable identity. A passport is not a human-facing page; it is structured data published against defined data standards and a unique identifier (e.g. a GS1-based barcode).
İkiz Eksen’s approach builds this chain on a single line: first make production and material data measurable and digital, then consolidate it on a software backbone, and finally connect it to the compliance output — carbon report, product passport, CBAM declaration. That capability did not appear from nowhere. On the ERP side it draws on experience gained with Qera across more than 550 customers, over 15 industries and 100-plus ERP deployments, on Microsoft Azure infrastructure, and on turnkey projects delivered across Türkiye. That is why we define the twin transition approach as building the green and the digital as a single project.
Where to start
Even if the passport is not yet mandatory for your product group, preparation starts today. A sequenced starting framework:
- Identify where your product groups sit on the ESPR priority list; mark the nearest likely date.
- Map where your current product and material data lives and in what format. Fragmentation is the biggest cause of delay.
- Plan now which data (recycled share, chemical declaration) you will need to request from suppliers.
- Prepare a roadmap that builds the measure–system–report chain; share a common database with your CBAM and carbon-footprint work so you do not do the same job twice.
To draw up a roadmap specific to your organisation on this framework, you can request a meeting through the contact form or review our solutions.
Frequently Asked Questions
Is the digital product passport mandatory in Türkiye?
There is currently no local legal requirement in Türkiye. But for manufacturers exporting to the EU, the passport becomes a de facto market-entry condition once the rule takes effect for the relevant product group.
Which product carries the first mandatory passport?
The obligation with the clearest date is batteries: under the EU Battery Regulation (2023/1542), a battery passport is required for industrial and electric-vehicle batteries above 2 kWh from 18 February 2027. For ESPR groups such as textiles and steel, the timeline advances through product-specific rules; confirm exact dates against EU sources.
Are the DPP and CBAM the same thing?
No. CBAM is a border mechanism that prices the embedded carbon of imported goods; the DPP is a digital identity that carries a product’s material, circularity and environmental data. What they share: both require you to keep measured, verifiable data about your product.
What data should I start collecting for the passport?
Material and composition data, recycled content share, chemicals used, repair and spare-part information, and end-of-life instructions form the core data set. The exact list is defined by the regulation for your product group.
I’m a small business — isn’t this too early for me?
Not early — an advantage. Building the data infrastructure takes time; the preparation window granted when a rule takes effect is often tight. Setting up measurement and data discipline now is both cheaper and sturdier than scrambling later.
Sources
- European Commission — Ecodesign for Sustainable Products Regulation (ESPR)
- Regulation (EU) 2024/1781, EUR-Lex
- EU Battery Regulation — Regulation (EU) 2023/1542, EUR-Lex
- European Commission — ESPR 2025-2030 Working Plan (April 2025)