PassPer / Resources / DPP language requirements
Regulatory question

No single EU-wide answer yet — but English-only is the weak position.

It is the first question anyone asks once the passport stops being theoretical, and the honest answer has two halves. There is no single EU sentence that settles it for every product. There is, however, a well-established principle in EU product law that information intended for consumers and authorities should be available in the language of the market where the product is placed — and a passport, unlike a manual, is read by people you did not ship to.

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In one line: there is no single settled EU-wide language rule for passports yet — but consumer- and authority-facing product information is generally expected in the language of the market where the product is sold, so an English-only passport is a position you will eventually have to defend.

The general principle, stated carefully

There is no single, settled EU-wide sentence that says “a Digital Product Passport must be in language X”. What exists is a long-standing principle running through EU product law: information intended for consumers and for authorities is generally expected to be available in the language or languages of the member state where the product is placed on the market, and it is the member states themselves that set which language that is for their own territory. ESPR — Regulation (EU) 2024/1781 — addresses the passport at the level of accessibility: the information has to be reachable and usable by the people entitled to see it.

The precise obligation for your product will not come from the framework regulation. It comes from the delegated act for your product group, which is where the data fields, the access tiers and the presentation detail are actually fixed. Until that act exists for your group, anyone stating the language rule with certainty is extrapolating.

Why a passport is not a manual

The instinct is to treat this like the paper documentation problem: print the manual in the languages of the countries you ship to, put it in the box, done. A passport does not work that way, because you do not control who opens it.

A manual travels with a known consignment to a known market. A passport is a live public surface. It sits behind a QR code printed on the product itself, and it is read by whoever is holding that product at the moment they scan — a shopper who bought it second-hand two countries away, a customs officer inspecting a pallet that was re-exported, a technician in a repair shop, a recycler at end of life. The product moves; the passport goes with it. No shipment manifest tells you which language that reader needs.

The second difference: a manual is finished at print time. A passport is expected to stay accurate and reachable for the product’s regulated lifetime — up to fifteen years for some groups — so whatever language decision you make has to survive a decade of edits, not a single print run.

Structural translation versus declared values

This is the distinction that makes the problem tractable, and it is worth getting right before you spend money on translation.

In practice a platform can and should hand you the multilingual structure as standard, while any value that genuinely needs to exist in several languages is supplied by you. That is exactly the line PassPer draws: eight EU languages for the structure, rendered from the scanning device’s own language preference, with your declared values untouched.

What a multi-market seller should do now

If you sell into one country this is a small question. If you sell into six, it is the difference between one passport that works everywhere and a translation project you discover late.

Being early here costs almost nothing. Being late means retrofitting language handling into passports whose codes are already printed on products in the field.

Frequently asked questions

Is there a single EU rule that says which language a DPP must be in?
Not a single settled one, no. EU product law generally expects information intended for consumers and authorities to be available in the language of the member state where the product is placed on the market, and member states set that for their own territory. The passport-specific detail is being fixed product group by product group through delegated acts under ESPR.
Can we publish an English-only passport?
You can build one, and nothing technically stops you rendering it. It is simply the weak position: it assumes every consumer, customs officer, repairer and recycler across the markets you sell into reads English. If you sell in more than one country, design for the structure to render locally — far cheaper than retrofitting it later.
Do our declared values have to be translated too?
Treat the two layers differently. Field labels, headings and units are standard regulatory vocabulary and can be translated centrally. Declared values — substance declarations, safety and care instructions, disassembly steps — are your statements and your responsibility; where they need to exist in another language, supply the wording rather than machine-translate it.
When will we know the exact requirement for our product?
When the delegated act for your product group is adopted. The first is expected around 2026 for iron and steel, with textiles indicatively 2027, and company obligations generally applying about eighteen months after an act enters into force. Anyone quoting a precise language rule for a group with no delegated act is extrapolating.

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