The most common mistake about the Digital Product Passport (DPP) is treating it as a general obligation that already applies.

The accurate position: **the Ecodesign for Sustainable Products Regulation (ESPR, (EU) 2024/1781) does not make the digital product passport mandatory for any product directly.** The duty arrives through **delegated acts adopted per product group** under Article 4 (Article 9(1)-(2)).

Why this matters

Because the answer to a vendor saying "the DPP is now mandatory, buy a system today" is a question: has a delegated act been adopted **for your product group**? If not, there is no date for you either. The Eco-Report DPP module asks about delegated act status for exactly this reason and **claims no obligation** while that status is unknown.

Preparation still pays

Chapter III of the ESPR defines the digital product passport across **7 articles**, and Annex III lists **12 data elements** that a passport may carry. Whatever a delegated act requires will come from inside this framework, so building the data pipeline early is not wasted work.

In practice the hard part is not the passport but **collecting the data from the supply chain**. Material composition, repairability and recycled content are often absent from the manufacturer's own records and have to be requested from suppliers. Starting that request after a delegated act is adopted is starting late.

The ESPR also provides for a digital product passport registry; the regulation refers to **19 July 2026** for that system.

What to do

1) Track whether a delegated act for your product group is in the working plan. 2) Map now who will supply each Annex III data element for your product. 3) Test every "the DPP is mandatory" claim with the question: **under which delegated act?**

How Nechh Eco-Report handles it

The Eco-Report DPP module produces no obligation while the delegated act status is unknown; the default option is "unknown" and the module then says "cannot decide". Annex III data elements are produced as a readiness list. Eco-Report is a preparation tool; it does not replace an official declaration or a conformity assessment.

Source: Regulation (EU) 2024/1781 (ESPR), EUR-Lex.

Publication note: This content is general information; it is not legal advice, a conformity assessment or a company-specific compliance evaluation. The final determination rests on the official text and, where needed, legal advice.