Shopify app · ESPR, Battery Regulation, PPWR

Digital Product Passport for Shopify — one passport per product, publicly accessible

Create passports in your shop, publish them at a permanent address and link them from the product by QR code. With the fields of the Battery Regulation, a material library drawn from four legal acts, and an overview of which product group is due when.

Request accessDates by product group
In review in the Shopify App Store13 product groups classifiedBattery passport from 18 Feb 2027Servers in Germany
What it stands for

A product that carries its own history

The digital product passport tries to close a gap: whoever holds a product knows almost nothing about it. What it is made of, whether it can be repaired, what to watch for when disposing of it — today that is printed on a leaflet that was thrown away long ago. The EU therefore requires this information to travel with the product: as a code leading to a page that still exists when the packaging is in the bin.

For the buyer

See what something is made of and how long it lasts before buying. Know how to care for and repair it afterwards.

For the repair shop

Spare parts, materials and instructions without going through the manufacturer — the precondition for repair staying cheaper than replacement.

For the recycler

Know which substances are inside before the machine runs. That decides whether material is recovered or burned.

For market surveillance

An identifier that belongs to the product and information that can be checked by machine — instead of paper in a folder at the importer.

For the retailer

The information that product safety, packaging and ecodesign law require anyway, in one place instead of five spreadsheets.

The legal position, honestly

There is no general passport obligation

The Ecodesign Regulation creates the product passport as an instrument but obliges no one directly. Only a delegated act for a product group determines which information a passport must contain and from when. To date exactly one passport is binding — the one for batteries, from 18 February 2027. Two more are in the Official Journal and apply from 2029 and 2030.

Anyone promising “ESPR compliance” today cannot deliver it for the planned product groups: as long as no legal act is published, nobody knows which fields it will require.
Who is affected

The duty follows the role, not the size of the company

Whoever imports directly from a third country is an importer — and carries the duties themselves, even as a pure online retailer.

Manufacturer

Whoever makes a product, or has it made, and sells it under their own name or brand. Own-brand is enough: printing your logo on a box makes you the producer of that packaging under the Packaging Regulation.

Importer

Whoever first places goods from a third country on the Union market. With direct imports that is the shop itself — the Battery Regulation then binds it just as it binds the manufacturer.

Distributor

Whoever resells goods already placed on the Union market. The passport duty then sits with the supplier, but the shop must still show the product safety information.

Authorised representative

Keeping passports on behalf of another economic operator requires a written authorisation. The app asks for it during setup and records that it exists — the authorisation itself stays with you.

Reg. (EU) 2023/1542 Art. 77(4)Reg. (EU) 2025/40 Art. 15Reg. (EU) 2023/988 Art. 16 and 19
Dates

Thirteen product groups, sorted by legal status

Binding means the act applies and names a date. Adopted means the wording is fixed but application comes later. Planned means there is only an announced adoption year — and under the ESPR at least 18 months pass between adoption and application.

Product groupStatusDateBasis
Batteries
LMT batteries with no capacity threshold, EV batteries and industrial batteries above 2 kWh.
bindingapplies from 18 Feb 2027Reg. (EU) 2023/1542 Art. 77
Detergents
Staged transitions. The creation date in your shop does not prove when something was placed on the market.
adoptedfrom 23 Sep 2029Reg. (EU) 2026/405 Chapter V
Toys
Goods placed on the market earlier under the old directive keep their status.
adoptedfrom 1 Aug 2030Reg. (EU) 2025/2509
Iron and steelplannedadoption 2026Working plan COM(2025) 187
Textiles and apparel
Often presented as a 2027 duty. 2027 is only the planned adoption year; application follows in 2029 at the earliest.
plannedadoption 2027Working plan COM(2025) 187
Tyresplannedadoption 2027Working plan COM(2025) 187
Aluminiumplannedadoption 2027Working plan COM(2025) 187
Furnitureplannedadoption 2028Working plan COM(2025) 187
Mattressesplannedadoption 2029Working plan COM(2025) 187
Energy-related products and ICTplannedadoption 2026–2030Working plan COM(2025) 187
Construction products
Its own legal framework alongside the ESPR.
plannedno dateReg. (EU) 2024/3110 Art. 75–80
Packaging
Not a product passport, but technical documentation and a declaration of conformity.
separate dutyin force since 12 Aug 2026Reg. (EU) 2025/40 Art. 12
Other products
For these the app offers the voluntary passport.
no dutyReg. (EU) 2024/1781 Art. 4
What is inside

Two profiles, one structure

A profile determines which sections and fields a passport has, which information is public, and at which level it applies — model, batch or individual item.

Battery passport — public information

Reg. (EU) 2023/1542 Annex VI Part A and Annex XIII No. 1

Model and item-level information in one passport, as Art. 77 requires

General battery information

Producer with address and single contact point, battery category, model identifier, batch or serial number, place and date of production, weight, capacity, cell chemistry, hazardous substances, usable extinguishing agent, critical raw materials above 0.1 % by weight

Performance and lifetime

Material composition, carbon footprint, responsible sourcing, recycled content for cobalt, lithium, nickel and lead, share of renewable content, rated capacity, minimum, nominal and maximum voltage, temperature range, original power capability, power limits, expected lifetime in cycles including the reference test used

Product safety

Manufacturer and, for imports from a third country, the responsible person in the Union

Voluntary product passport

No legal profile — for product groups without a legal act

Model, batch or individual item

Product

Designation, description, country of origin

Material and composition

Composition, recycled content, recyclability — the share that can be materially recovered at end of life, deliberately kept separate from recycled content

Care, repair, disposal

Care instructions, repair options, disposal information

Product safety

The same information as in the battery profile

The voluntary passport is visibly marked as voluntary. It must never look like a mandatory one — there is nothing for it to comply with.

Libraries

Materials and certificates, taken from the legal acts

Both libraries list, they do not prescribe. What belongs in a passport is decided by the act for the product group.

125
materials

109 of them with a citation in the legal act

50
textile fibre names

Mandatory designations from Annex I of the Textile Labelling Regulation

37
critical raw materials

From Annex II of the CRMA — exhaustive, not extendable

32
certificates and labels

4 of them statutory: CE, EU declaration of conformity, RoHS, REACH

Textile fibres may only be named with the designations from Annex I — “cotton” yes, an invented name no.
Critical raw materials are listed exhaustively in Annex II of the CRMA. “Nickel” in general is not in it, only battery-grade nickel.
10 entries are flagged as hazardous substances under RoHS, 15 come from the Packaging Regulation.
Labels are grouped by textiles and leather, environment and energy, social and labour standards, management systems and EU conformity — each with one sentence on what it stands for.
Once copied, an entry is your data and freely editable.
How it works

From product to passport in four steps

No code, no theme editing.

01

Sync the catalogue

The app reads products, variants and collections from Shopify. Changes arrive continuously via webhooks.

02

Fill in the passport

One section at a time, with the legal source next to every mandatory field. Material and evidence are copied from the libraries.

03

Approve and publish

The version is approved by name, frozen and given a checksum. From then on the passport has a permanent address and a QR code.

04

Show it in the shop

One click places the block in your theme. Every product page with a published passport then shows link and QR code.

Publishing

A passport is a document, not a record

Frozen versions with a checksum

Publishing creates an immutable snapshot with a checksum. Changes create a new version; the previous one stays traceable. The snapshot is written before the address points to it — a scanned code never lands in a gap.

QR code as a GS1 Digital Link

If the variant has a barcode, the app builds the standard address form that retail and authorities read. Without a barcode it issues its own identifier — and says visibly that this is not standard-compliant.

Machine-readable, not just readable

The same information as structured JSON at its own address, with a checksum and links to page and code. That is exactly what the ESPR requires: machine-readable, structured and searchable.

Public without a login

The passport page is accessible without an account and loads no fonts, scripts or images from third-party servers. No tracking, no consent banner — there would be nothing to consent to.

Evidence as files

Certificates and test reports attach to the passport. You decide per file whether it is public; files not released stay invisible even if someone guesses the address.

Registry status carried along

Every passport carries its status towards the EU registry — from “not applicable” through “ready” and “submitted” to “registered”. What is outstanding is visible at a glance.

Registry

The Commission’s digital product passport registry

The ESPR obliges the Commission to set up a registry by 19 July 2026 storing at least the unique product identifiers. The duty to register does not arise from the ESPR itself but only from the act for the respective product group.

By 19 July 2026, the Commission shall set up a digital registry (‘registry’) storing in a secure manner at least the unique product identifiers.

Reg. (EU) 2024/1781 Art. 13(1)
An entry in the registry is expressly not proof of compliance.
Passport data must be machine-readable, structured and searchable — not merely legible as a web page.
The app carries the registry status per passport but does not submit on its own.
In your Shopify shop

A passport is useless if nobody finds it

Block for the product page

One click opens the theme editor with the block ready — automatically on every product page or at a position you pick. Label, QR size, border and colours are set there.

Passport link on the product

Address, identifier and legal classification are written to the Shopify product as metafields. They are then available in the admin on the product page and to any theme.

Passport status in the product admin

A dedicated block on the Shopify product page shows whether a passport exists and whether it is published, and leads into it in one click.

The catalogue stays current

New, changed and deleted products arrive via webhooks. A deleted product does not take its passport with it — the passport remains while printed codes may be in circulation.

Working together

Four roles, separated rights

Reader

Sees passports and libraries, changes nothing. Controls they may not use are not shown at all.

Editor

Creates passports, fills them in, attaches evidence — but does not publish.

Approver

Publishes. The approval is recorded by name and frozen with the version.

Admin

Additionally manages members, master data and settings.

Data and role

What the app reads from your shop — and what it may do with passport data

A single read permission

read_products. With it the app reads products, variants and collections — title, barcode, image, collection membership.

No orders, no customers

It does not see order, customer, payment or revenue data. It holds no permission for any of it, and without permission Shopify does not release it.

Writing only on request

Writing the passport link to the product is a separate permission that you grant only when you need it.

Product passport service provider under the ESPR

Once we host a passport for you we are a service provider within the meaning of Art. 2(32) and Art. 11 ESPR. It follows that we do not sell your passport data and process it solely for the service.

Servers in Germany

Application and database run in Germany. No transfer to third countries takes place.

Deletion after uninstall

When Shopify reports the uninstall, the data is deleted. You decide separately about published passports, because printed codes may be in circulation.

Legal background

The legal acts that matter here

Every paragraph with its source. Where we quote, the wording is from the Official Journal.

Product safety

in force since 13 Dec 2024

General Product Safety Regulation — Reg. (EU) 2023/988

Applies to every consumer product, with or without a passport. In distance selling, the manufacturer, a responsible person in the EU, a product identifier and warnings must be shown — visible before anyone buys.

Applies regardless of product group.
The responsible person in the EU must be a person or company with an address in the Union.
Warnings in the language of the destination country.
Art. 19 — information in distance sellingArt. 16 — responsible person in the EUArt. 52 — date of application

Packaging

in force since 12 Aug 2026

Packaging Regulation — Reg. (EU) 2025/40 (PPWR)

Not a product passport, but a duty many shops overlook: whoever places packaging or packaged products on the market needs technical documentation under Annex VII and, based on it, an EU declaration of conformity.

Before placing packaging on the market, producers shall carry out, or have carried out, the conformity assessment procedure referred to in Article 38 and draw up the technical documentation referred to in Annex VII.

Reg. (EU) 2025/40 Art. 15(2)
“Producer” also covers whoever has packaging made under their own name or brand — the typical shop with an own-brand box.
Exception: if that party is a micro-enterprise AND the packaging supplier is in the same member state, the supplier counts as producer. Both must be true.
Retention: five years for single-use, ten years for reusable packaging.
A separate declaration for each distinct packaging specification.
Art. 15(2) and (3) — producer obligationsAnnex VII — technical documentationArt. 12 — labelling

Battery passport

from 18 Feb 2027

Battery Regulation — Reg. (EU) 2023/1542

The first binding product passport of all and to date the only one with a fixed date. It covers LMT batteries with no capacity threshold as well as EV and industrial batteries above 2 kWh. The scope of the information is exhaustively set out in Annex XIII.

It binds importers too — whoever imports such batteries carries the duty themselves.
Annex XIII requires, among others, material composition, critical raw materials, recycled content per metal, performance and lifetime data.
Annex VI Part A governs labelling, Art. 38(6) the batch or serial number.
Art. 77 — battery passportAnnex XIII — contentAnnex VI Part A — labelling

The frame: Ecodesign Regulation

in force since 18 Jul 2024

ESPR — Reg. (EU) 2024/1781

It creates the product passport as an instrument but obliges no one directly. Only a delegated act for a product group sets which information a passport must contain and from when. Creating a passport today is voluntary — and prepares data you will need anyway.

Passport data must be machine-readable, structured and searchable.
An entry in the registry is expressly not proof of compliance.
At least 18 months pass between adoption of an act and its application.
Art. 4 — duties arise per product groupArt. 10(1) — requirements on the dataArt. 13 — registry

Substances and designations

ongoing

CRMA, RoHS, REACH, Textile Labelling

These four determine how material is named and labelled in a passport. The app’s material library follows them: the 50 textile fibre names are mandatory, the list of critical raw materials and the RoHS substances come from the annexes.

Textile fibres may only be named with the designations from Annex I.
Critical raw materials: Annex II of the CRMA lists them exhaustively — “nickel” in general is not in it, only battery-grade nickel.
REACH Art. 33: duty to inform about substances of very high concern above 0.1 % by weight.
Reg. (EU) No 1007/2011 Annex IReg. (EU) 2024/1252 Annex IIDir. 2011/65/EU (RoHS)Reg. (EC) No 1907/2006 Art. 33
FAQ

Frequently asked questions

Do I need a digital product passport today?

Only the battery passport is binding so far, from 18 February 2027. Detergents follow in 2029, toys in 2030. For all other groups there are only announced adoption years and therefore no duty. Independently of that, product safety information has been required since December 2024 and, for packaging, the Packaging Regulation since August 2026.

Is it true that textiles need a passport from 2027?

No. In the ecodesign working plan 2027 is the year in which the act is meant to be adopted. Under the ESPR at least 18 months pass between adoption and application, so realistically 2029 at the earliest. As long as no act is published, nobody can say which fields it will require.

I import from China myself. Does that change anything?

Yes, considerably. Whoever first places goods from a third country on the Union market is an importer and carries the duties themselves — for batteries that means the battery passport, no matter how small the shop is.

I do not sell batteries. Is the app useful to me?

As a voluntary passport, yes: material, recycled content, care, repair and disposal at an address you can print on the product. The passport is visibly marked as voluntary. Waiting is a defensible choice too — this page will not talk you into a deadline.

What happens to my shop data?

The app reads products, variants and collections. It does not see orders, customers, payments or revenue, because it holds no permission for them. Application and database run on servers in Germany.

What do I do if a passport contains wrong information?

You withdraw it. The public page then states that the passport was withdrawn instead of leading nowhere. You correct the data and publish a new version; the earlier one stays traceable as a frozen version.

What is shown on the public passport page?

Only what you marked as public; for evidence files you decide per file. The page is accessible without a login — that is a requirement: the Ecodesign Regulation demands free and easy access.

What is a GS1 Digital Link, and do I need one?

It is the address form that retail and authorities derive from a barcode. If your variant has a barcode, the app builds the address that way. Without a barcode it issues its own identifier; the passport works the same but is not standard-compliant — and the app says so on the spot.

Does the passport change when I edit the product?

No. A published version is frozen and carries a checksum. If you change something, a new version is created; the previous one stays traceable. A QR code on packaging has to say the same thing two years later.

Do I have to register my passports in the EU registry?

That duty arises only from the act for your product group, not from the ESPR itself. The app carries the registry status per passport but does not submit on its own. An entry is, in any case, expressly not proof of compliance.

When is the app available, and what does it cost?

The app is finished and under review at Shopify. Once approved it will be in the Shopify App Store. The price is not fixed yet — write to us if you want to be among the first and we will get in touch at launch.

Does this replace legal advice?

No. We state what the regulation says and cite the source. Whether an obligation applies to you depends on your role, your size and your product — no app decides that.

Be among the first

The app is finished and under review at Shopify. Tell us briefly which products you sell — we will get in touch as soon as it is in the App Store.

Request access

Statements about EU requirements are backed by sources and do not replace legal advice. What governs is the wording of the respective legal act in its applicable version. As of September 2026.