It does not matter where your product is made. If it is placed on the EU market, the applicable requirements must be met.
EU Desk · For companies outside the EU
New EU product rules are coming. Find out what they mean for what you sell.
A Digital Product Passport is a digital record that EU product rules can require for certain products placed on the EU market. If your company is outside the EU, those requirements can still apply to products you sell into Europe. Tell us what you sell and receive a sourced Product Exposure Report showing what may apply, the dates we can establish, what is still open, and the official sources behind it.
How EU Desk works ↓Click here to get started →First Product Exposure Report free. Company email required. Secure magic link, no password.
Where applicable EU product legislation requires a Digital Product Passport, an in-scope product will need to meet that requirement from the applicable date in order to be placed on the EU market.
From 18 February 2027, EV batteries, light means of transport batteries, and industrial batteries above 2 kWh need a battery passport. Other priority product groups follow on their own timelines.
For businesses outside the EU
Digital Product Passport questions from non-EU companies.
EU Desk is not a general Digital Product Passport service. It is built for companies outside the European Union that make, export or sell products for the EU market.
What is a Digital Product Passport?
A Digital Product Passport is a digital record that EU product rules can require for certain products placed on the EU market. The exact information, data carrier and product level depend on the EU rules that apply to that product group.
Does a Digital Product Passport apply to companies outside the EU?
It can. EU Digital Product Passport obligations apply to in-scope products placed on the EU market whether they are manufactured in the EU or imported. A company outside the EU therefore needs to understand which product rules apply and which economic operator carries each responsibility.
Do imported products need a Digital Product Passport?
Where the applicable EU legislation requires a Digital Product Passport, imported products are included. The European Commission states that Digital Product Passport registration may also be relevant for customs clearance and release for free circulation.
When will my products need a Digital Product Passport?
The timing depends on the product category and the EU legislation that covers it. Battery passport requirements begin on 18 February 2027 for specified battery categories, while other product groups follow their own legal timelines.
Is yellow3 EU Desk for companies based inside the EU?
No. yellow3 EU Desk is specifically for businesses outside the European Union that sell products into Europe. EU-based buyers use the yellow3 Digital Product Passport Buyer Platform instead.
Official EU basis: European Commission · Digital Product Passport for economic operators ↗ · European Commission · Digital Product Passport Registry ↗
Product Exposure Report example
See what your sourced report contains.
EU Desk builds a sourced Product Exposure Report from your product description and the official material returned for it. This illustrative report uses the same evidence structure, source treatment and print-ready format as the report you receive.
yellow3 EU Desk · Product Exposure Report
European product exposure from the regulatory evidence held
Industrial batteries above 2 kWh sold into the European Union
▣Illustrative exampleThe real report uses the customer’s own product description and returned evidence.
- Generated
- 22 September 2026 · 07:45 UTC
- Record ID
- PER-2026-09-22-EXAMPLE
- Record type
- Product Exposure Report
- Official sources cited
- 3
01
Product and market route
What you sell and how it reaches EU customers
Your own answers. They start the analysis and are never presented as regulatory evidence.
Industrial batteries above 2 kWh sold into the European Union
Your company outside the EUEU importerPlaces on EU marketMarketplaceSales channelEU customer
First reaches the EU: An EU importer places it on the market · Direct online sales: Online marketplace · EU responsible person: EU importer · EU partner sells under its own name or brand: No, under our name or brand
02
Current position · Upcoming position
What applies now, kept apart from what is coming
An upcoming item carries its obligation state. Nothing here is stated as required from a date unless the source says exactly that.
Applicability to your products stays proposed until a named person confirms it. Human company-specific confirmation is not included in the free report.
Adopted, not yet applicable
Battery passport, from 18 February 2027. Potentially applicable to this product. Regulation (EU) 2023/1542 Article 77
03
Economic-operator roles
Who holds which role on this route
Derived only from your answers and the provisions cited. A role your answers leave open is shown as not established, never guessed.
PartyRole on this routeState and source
PartyYour company (outside the EU)Role on this routeSupplies the EU importer, which places the product on the market.State and sourceFrom your answer and the source
ESPR (EU) 2024/1781 Article 2(44)
ESPR (EU) 2024/1781 Article 2(44)
PartyYour EU partnerRole on this routeEU importer
Places the product on the EU market.
Named by you as the responsible person under Regulation (EU) 2019/1020 Article 4(2). Sells the product under your name or brand.State and sourceYour answer
ESPR (EU) 2024/1781 Article 2(44) · Regulation (EU) 2019/1020 Article 4(2)
Places the product on the EU market.
Named by you as the responsible person under Regulation (EU) 2019/1020 Article 4(2). Sells the product under your name or brand.State and sourceYour answer
ESPR (EU) 2024/1781 Article 2(44) · Regulation (EU) 2019/1020 Article 4(2)
PartyOnline marketplaceRole on this routeSales channel, not an ESPR economic operator.State and sourceFrom your answer and the source
ESPR (EU) 2024/1781 Article 2(54)
ESPR (EU) 2024/1781 Article 2(54)
04
Responsibility map
Each duty, who answers for it and who performs it
Only duties with an established legal state are listed. Digital Product Passport duties under the Ecodesign for Sustainable Products Regulation have none until a delegated act covers the product group; see section 07.
DutyStateAccountablePerformerEvidence
DutyKeep passport data accurate and up to date
Regulation (EU) 2023/1542 Article 77(4)StateAdopted, not yet applicableAccountableEU importerPerformed byNot recordedEvidenceNone recorded
Regulation (EU) 2023/1542 Article 77(4)StateAdopted, not yet applicableAccountableEU importerPerformed byNot recordedEvidenceNone recorded
DutyEstablish the relevant EU economic operator
Regulation (EU) 2019/1020 Article 4(2)StateApplicability to this product not establishedAccountableEU importerPerformed byNot recordedEvidenceNone recorded
Regulation (EU) 2019/1020 Article 4(2)StateApplicability to this product not establishedAccountableEU importerPerformed byNot recordedEvidenceNone recorded
05
Sales-channel implications
What each sales channel indicates
Only channel duties the cited source establishes for this product are listed.
No sales-channel duty is established for this product today. Channel duties under the Ecodesign for Sustainable Products Regulation depend on a delegated act for the product group; section 07 states who would carry them on this route.
06
Evidence-backed findings
What the regulatory record returned for this product description
Every finding below is tied to a provision held in the regulatory corpus. Model-generated prose is not used as regulatory evidence.
#RequirementEvidence position
01Article 77 Battery passportPotentially applicable
01 · Article 77 Battery passport
“From 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record (‘battery passport’).”
Scope evidence: Article 77 · “industrial battery with a capacity greater than 2 kWh”
- Instrument
- Regulation (EU) 2023/1542
- Provision
- Article 77
- Dates stated
- 18 February 2027
- Retrieved
- 2026-08-20
07
What remains open
2 items still open
Open items are preserved as uncertainty. EU Desk does not convert missing evidence into a compliance conclusion.
Not establishedWho performs the battery passport work, and under whose written authorisation.
Regulatory dependencyESPR delegated act not adopted
Product-specific ESPR Digital Product Passport requirements are not yet established for this product group. The relevant requirements depend on a delegated act for the product group. No such act is present in the current regulatory record.
If a delegated act covers this product group, the duties to register the passport and keep a back-up copy sit with the economic operator placing the product on the market (Articles 13(4) and 10(4)): on this route, the EU importer. That operator would also give online marketplaces, on request, a free copy of the data carrier or unique product identifier within five working days (Article 10(3)). Distance-selling offers would show the manufacturer’s details and, for a manufacturer outside the EU, the EU operator under Regulation (EU) 2019/1020 Article 4(2) (Article 36(1)).
ESPR (EU) 2024/1781 Article 13(4) · ESPR (EU) 2024/1781 Article 10(4) · ESPR (EU) 2024/1781 Article 10(3) · ESPR (EU) 2024/1781 Article 36(1) · Regulation (EU) 2019/1020 Article 4(2)
08
Next actions
What to establish next, in order
Each action closes one open item in section 07.
09
Sources used in this report
The official sources this point-in-time report cites
3 official sources, 9 provisions cited
Findings quote regulatory passages held by yellow3. Route rows and open items cite the provisions below, verified against the Official Journal.
- Instruments cited by findings
- 1
- Oldest maintained copy
- 2026-08-20
- Dates returned
- 1
Your words and answers start the research
The product description and route answers are used to form search hypotheses and to place duties on the route. They are never presented as though the legislation said them.
- Input
- Industrial batteries above 2 kWh sold into the European Union
- Evidence status
- Not regulatory evidence
- Product scope found
- industrial battery with a capacity greater than 2 kWh
InstrumentProvisionOfficial source
Regulatory instruments this report quotes or cites.
Evidence-backed findings returned for this product description.
Items deliberately left unresolved rather than guessed.
18 February 2027
Illustrative Product Exposure ReportFictional example. Your report is generated from your own product description and the official sources returned for it.
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01
Product Exposure ReportYour first sourced view of what may reach the products you sell.
FreeOne verified company domain
- Relevant instruments and provisions
- Known application dates
- Open questions and next step
- Official sources and dates
02
Establish your EU positionA documented European operating position for one EU-regulated product group.
€4,900One time · excluding VAT
- Requirements and timelines
- Market roles and importer responsibilities
- Evidence gaps and supplier dependencies
- Buying specification and action plan
- Additional product groups priced separately
03
Stay CurrentWe establish the position first, then keep the record current for you.
€590 / month12-month initial term · excluding VAT
- Initial establishment included
- Changes translated into product impact
- Monthly readiness update
- Additional product groups €290 / month each
- €6,490 / year, paid in advance
What we mean by product group. A product group means a product category as the EU regulates it, for example textiles, batteries or furniture. Not your own product lines.
You should not have to become an expert in European product legislation just because you sell in Europe. That is our job.
The boundary
Independent support. Your company stays responsible.
yellow3 is not a law firm, conformity assessment body or Digital Product Passport operator. We keep the evidence and regulatory record current, make uncertainty visible and support the decisions your team needs to make. The selected provider operates the passports.
No supplier pays us. That means our advice is independent of the passport provider or technology you eventually choose.