If you already register products in EPREL, the digital product passport looks like the same job twice: another EU database, another set of product data, another registration obligation. It is a fair question and the answer is genuinely nuanced — for some products EPREL is expected to do the passport’s job, for others it will not, and at least one product group sits squarely in both regimes.
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EPREL — the European Product Registry for Energy Labelling — is a public database run by the European Commission under Regulation (EU) 2017/1369. Since 1 January 2019, suppliers have had to enter the required information for every energy-labelled product they place on the EU market, before placing it. It covers energy-related products: fridges and freezers, washing machines, tumble dryers, dishwashers, ovens and range hoods, televisions, lamps and luminaires, air conditioners, space and water heaters, solid-fuel boilers, ventilation units, vacuum cleaners, professional refrigerated cabinets — and tyres.
Note who carries it: the obligation sits with the supplier, which is not always the manufacturer. Where the manufacturer is established in the EU, that manufacturer registers and keeps the data current. Where it is not, the obligation follows whoever places the product on the market — the same logic that governs the battery passport.
The digital product passport comes from the Ecodesign for Sustainable Products Regulation, (EU) 2024/1781, and separately for batteries from (EU) 2023/1542. It is a wider record: material composition, substances of concern, carbon footprint, durability, recycled content, repair and end-of-life information — reached through a data carrier on the product itself, with tiered access for consumers, repairers, recyclers and authorities. EPREL, by contrast, is a registration database about energy performance; it does not put a resolvable record on the product.
The Commission’s stated approach is that energy-related products continue to use the energy label and EPREL, while other regulated products get a digital product passport. In other words, ESPR does not intend to make you build a parallel database for a fridge whose energy data is already in EPREL — an existing equivalent digital system can serve the purpose for that product group.
That is the reassuring half. The complication is that the passport asks for more than energy performance. Substances of concern, recycled content, disassembly and repair information are not EPREL fields. So for an energy-related product the realistic outcome is not “EPREL instead of a DPP” but “EPREL plus whatever the delegated act for your group adds on top” — and exactly how the two are stitched together is being worked out act by act, which is why nobody can hand you a definitive mapping today.
Tyres are the clearest example of genuine double exposure. Tyres are energy-labelled and therefore already in EPREL, and tyres are also one of the priority final product groups named in the first ESPR working plan. A tyre manufacturer should expect to deal with both regimes rather than either one.
And one category sits outside this argument entirely: batteries. The battery passport is not an ESPR delegated act at all — it is a standalone obligation under (EU) 2023/1542, mandatory from 18 February 2027 for EV batteries, LMT batteries (no capacity threshold) and industrial batteries above 2 kWh. EPREL has no bearing on it whatsoever.
Tyres can tick three of those boxes at once. Most companies tick one.
The good news is that the underlying work converges even where the regimes do not. Both EPREL and any passport obligation demand the same discipline: an authoritative, current, per-model record of what your product is made of and how it performs, with someone accountable for keeping it accurate.
Two practical consequences worth planning around. First, the accountable party is the same in both regimes — whoever places the product on the EU market — so if you are an importer discovering EPREL duties, expect the passport duty to land on you too. Second, neither obligation is a one-off filing. EPREL data must be kept up to date, and a passport must stay resolvable for the product’s regulated lifetime, which for batteries runs up to 15 years. Anything you build should assume maintenance, not submission.
If you want to know precisely which fields you already hold, the complete battery-passport field list is published free — as a page and as JSON or CSV under CC BY 4.0, no sign-up. Or run the free readiness check to see which regimes touch your catalogue.
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