Digital Product Passports attach when a product is placed on the EU market — so what happens when that product is sold again, refurbished, remanufactured or given a second life? For resellers the short answer is reassuring: the existing passport generally travels with the product. But the passport is a living record, not a birth certificate, and the interesting obligations sit exactly where circular businesses operate: substantial refurbishment, battery health updates and repurposing. Some of these rules are still settling; here is the honest picture.
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Passport obligations attach when a product is placed on the market — the first time it is made available in the EU. Selling a used product that already carries a passport is generally not a new placing on the market, so a reseller does not create a new passport: the existing one continues, reachable through the same data carrier on the product. Indeed, that is much of the point — repairers, second-hand buyers and recyclers are exactly the audiences the passport is meant to serve years after first sale, which is why passports must stay accessible for the product’s regulated lifetime, up to 15 years.
The hedge: per-product-group delegated acts define the operative details, and several are still being written. "Resale continues under the existing passport" is the sound working assumption, not yet a universally-spelled-out rule for every product group.
Cleaning, testing and reselling a product is trade. Substantially changing it is manufacturing — and EU product law has long treated an operator who significantly modifies a product, or markets it under their own brand, as taking on manufacturer-level responsibilities. Remanufacturers who rebuild products to as-new condition, swap major components or re-certify performance should expect the same logic to apply to passports: the record must reflect the product as it now is, which may mean updating the existing passport or issuing a new one under your name.
Where the line falls — repair versus substantial modification — will be shaped per product group by the delegated acts. If your business model lives near that line, build your data processes as if you will carry manufacturer duties; scaling documentation up is far easier than retrofitting it.
The battery passport makes the "living record" idea concrete. It is designed to be updated through the battery’s life: state of health, performance and durability data, and repair events are written into the passport by authorised operators as they happen, so a buyer of a used EV or e-bike battery can see its actual condition rather than its factory spec.
Second-life uses go further. When a battery is repurposed — an EV pack rebuilt into stationary storage, for example — that is a change of the battery’s status and identity that must be reflected in its passport record, with the operator performing the repurposing taking responsibility for the battery in its new life. If you refurbish or repurpose batteries, from 18 February 2027 writing to passports is part of your job, not just reading them.
One trap for circular businesses: used goods imported into the EU are being placed on the EU market, often for the first time. An importer of used or refurbished products from outside the EU should expect to carry importer duties — including ensuring a compliant passport exists for in-scope products — just as an importer of new goods does. A used e-bike shipped in from outside the EU after the battery-passport date will need its battery passport in order.
Being honest: DPP rules for the circular economy are still settling. Delegated acts will fix the details per product group, and guidance on refurbishment and second-life cases is still maturing. What is already clear is the direction — passports persist, get updated, and follow the product through its lives. PassPer’s free readiness check is a quick way to see where your products and processes stand today.
Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.