This article reflects the official information available as of 29 September 2026 and will be updated as new legislative documents are released.
The European Union is preparing a significant update to the rules governing how products are placed and controlled on the EU market.
The European Product Act package, which foresees the revision of the 3 Regulations - New Legislative Framework, Market Surveillance Regulation, Standardisation Regulation - is expected to modernise the horizontal framework behind EU product rules and market surveillance, making product legislation more coherent, digital and easier to enforce.
One development is particularly relevant for companies preparing for Digital Product Passports: the European Commission has confirmed that the package will include horizontal provisions for the Digital Product Passport (DPP).
This could extend the role of the DPP beyond the product-specific requirements already introduced under regulations such as the Ecodesign for Sustainable Products Regulation (ESPR), Batteries Regulation, Construction Products Regulation and Toy Safety Regulation.
The final scope will become clear when the legislative proposals are published. This article will be updated following the Commission’s announcement.
The European Product Act is a forthcoming package of EU legislative initiatives intended to modernise the framework governing products on the European Single Market.
Current EU planning points to:
The New Legislative Framework provides common principles for EU product legislation, conformity assessment and CE marking. The Market Surveillance Regulation governs how authorities monitor and enforce product compliance, while the Standardisation Regulation governs the European standardisation system.
Much of the existing framework dates back to 2008. Since then, digitalisation, e-commerce, direct imports and circular business models have changed how products enter the market and how their compliance needs to be assessed throughout their lifecycle.
The Commission’s evaluation found that the framework has improved consistency across EU product legislation while identifying areas that require an update. These include digital product information, market surveillance and the treatment of products that are repaired, refurbished or otherwise modified after first being placed on the market.
Digital Product Passports already appear across different areas of EU product legislation.
Under the ESPR, DPP requirements are introduced through product-specific delegated acts. These acts determine which products are affected, which data must be included and when the obligations apply.
Other legislation uses the DPP for different regulatory purposes. The Batteries Regulation, Construction Products Regulation and Toy Safety Regulation all introduce Digital Product Passport requirements, although the information and objectives vary by product category.
The Toy Safety Regulation provides a particularly relevant example. Its DPP forms part of the product conformity framework and includes information such as product and manufacturer identification, the EU declaration of conformity, applicable legislation, harmonised standards and CE marking.
Read more about the Digital Product Passport for toys.
The Commission has confirmed that the European Product Act package will include horizontal provisions for the Digital Product Passport, alongside measures intended to improve information sharing and enforcement against non-compliant products, particularly in e-commerce.
The precise legal role of these provisions will depend on the Commission proposals. However, their inclusion suggests that the DPP could become relevant to the wider infrastructure used to demonstrate and enforce product compliance.
Preparatory work for the European Product Act provides an indication of the direction under consideration.
The Commission’s consultation on the revision of the New Legislative Framework focused on three principal areas: Digital Product Passports, circularity and conformity assessment bodies.
It considered whether information currently held in separate compliance documents could increasingly be made accessible through the DPP, including:
These options do not determine what will appear in the final proposals. They do show that policymakers are considering a role for the DPP that extends beyond the sustainability and ecodesign information with which it is often associated.
The European Parliament has taken a similar position, suggesting that the DPP could support both access to product information and the establishment of conformity, building on the model introduced for toys.
If this direction is reflected in the Commission proposals, the DPP would become more closely connected with the systems and evidence companies use to demonstrate product compliance.
A broader regulatory role also makes the technical architecture of the DPP increasingly important.
Different regulations may require different information without needing entirely separate passport systems. The European Digital Product Passport standards already establish a shared technical foundation covering areas such as:
The European Product Act will help clarify whether this common infrastructure will also support wider product compliance requirements across EU legislation.
Product compliance information is often distributed across systems, documents, suppliers and internal teams.
A more horizontal role for the DPP could increasingly connect these information flows.
Companies preparing their product data and compliance systems should therefore consider:
The Commission proposals should provide greater clarity on several questions:
Publication of the proposals will begin the EU legislative process. It will not introduce immediately applicable requirements, and the texts may change during negotiations between the European Parliament and the Council.
This article will be updated following publication of the European Commission’s proposals.
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