China and ESPR: Digital Product Passport Requirements for China Exporters to the EU

ESPR Regulation (EU) 2024/1781 applies to all products placed on the EU market, regardless of where they are manufactured. China exporters in Electronics and semiconductors, Batteries and EVs, Solar panels and other sectors must comply with ESPR Digital Product Passport requirements before their products can enter the EU market after the applicable compliance dates. This page covers what China manufacturers and exporters need to know about ESPR compliance.

China's Export Profile and ESPR Exposure

China exports to the EU include products across multiple ESPR-regulated categories. The key sectors affected are:

• Electronics and semiconductors
• Batteries and EVs
• Solar panels
• Textiles and apparel
• Machinery and equipment

The EU is a major export destination for China manufacturers. ESPR compliance is not optional for products destined for the EU market — it is a legal requirement that will be enforced at EU customs from 19 July 2026 for general DPP compliance, and from 18 February 2027 for the Battery Passport specifically.

ESPR Compliance Requirements for China Manufacturers

China manufacturers exporting to the EU must complete four steps before their products can legally enter the EU market after the applicable ESPR compliance dates. First, they must appoint an EU Authorised Representative — a natural or legal person established in the EU who is responsible for DPP registration, the EU Declaration of Conformity, and communication with EU market surveillance authorities. Second, they must compile technical documentation for each product model, demonstrating compliance with the applicable ecodesign requirements. Third, they must create a Digital Product Passport for each product model (or individual unit, where required) and register it with a compliant DPP registry. Fourth, they must affix a QR code data carrier to each product or its packaging, linking to the DPP record.

Key ESPR Deadlines for China Exporters

EU Authorised Representative: What China Manufacturers Need

Under ESPR Article 16, non-EU manufacturers must appoint an EU Authorised Representative before placing products on the EU market. The Authorised Representative must be a natural or legal person established in an EU member state. They are responsible for ensuring the DPP is registered, the EU Declaration of Conformity is drawn up, the technical documentation is compiled, and the CE marking is correctly affixed. The Authorised Representative must be named in the EU Declaration of Conformity and their contact details must be accessible via the DPP.

The Authorised Representative does not need to be the importer or distributor — they can be a specialist compliance service provider. Many China manufacturers use EU-based compliance consultancies as their Authorised Representative. The cost of an Authorised Representative service typically ranges from €1,000–€5,000 per year depending on the number of product models and the complexity of the compliance requirements.

Digital Product Passport Registration for China Exporters

Once the technical documentation is complete and the EU Declaration of Conformity is drawn up, China manufacturers must register their products' Digital Product Passports with a compliant DPP registry. The registry assigns a unique DPP identifier to each product model (or unit, where required) and generates the GS1 Digital Link URL that is encoded in the product's QR code. The DPP data must be kept accurate and up-to-date throughout the product's lifetime — including updates to State of Health data for batteries and updates to spare parts availability for electronics.

Africa's first ESPR-compliant DPP registry — digitalproductpassports.co.za — is available to China manufacturers and exporters. The registry supports all ESPR product categories and provides GS1 Digital Link-compliant QR code generation, JSON-LD data hosting, and EU Declaration of Conformity document management.

China's ESPR Exposure: The World's Largest Exporter Faces the World's Most Comprehensive Product Regulation

China is the EU's largest single source of imports and faces the most comprehensive ESPR exposure of any non-EU country. Chinese manufacturers are affected by virtually every ESPR delegated act: electronics (smartphones, laptops, televisions), batteries (EV batteries, industrial batteries), solar panels, textiles, packaging, and more. The Battery Passport alone will affect hundreds of Chinese battery manufacturers who supply EV batteries to European automakers.

Chinese solar panel manufacturers face particular scrutiny under ESPR. The EU's Solar Energy Strategy and the ESPR solar panel delegated act will require solar panels to carry a DPP disclosing carbon footprint, recycled content, and end-of-life recyclability. Chinese solar panels dominate the EU market — accounting for over 80% of EU solar panel imports — and will need to comply with ESPR DPP requirements to maintain EU market access.

China's ESPR Exposure: The World's Largest Exporter to the EU

China is the EU's largest trading partner and the world's largest exporter of electronics, batteries, solar panels, electric vehicles, and many other products that will be subject to ESPR requirements. Chinese manufacturers face the most significant ESPR compliance challenge of any non-EU country — not because the requirements are more stringent for Chinese products, but because the scale of Chinese exports to the EU means that the number of products requiring DPP registration is enormous.

Chinese electronics manufacturers (Xiaomi, Oppo, Vivo, OnePlus, Huawei, TCL, Hisense, Haier, Midea, Gree) collectively account for a large share of the EU market for smartphones, televisions, household appliances, and other electronics. All of these manufacturers must register DPPs for their EU-market products from the date the applicable ESPR delegated act enters into force. The scale of this compliance challenge requires Chinese manufacturers to begin preparation now.

Chinese Battery Manufacturers and the Battery Passport

China manufactures approximately 75% of the world's EV batteries (CATL, BYD, CALB, Gotion, EVE Energy, and others). All of these manufacturers must register Battery Passports for EV batteries exported to the EU from 18 February 2027. The Battery Passport requires carbon footprint data (CO2e per kWh), recycled content data (cobalt, lithium, nickel, natural graphite), and supply chain due diligence documentation. Chinese battery manufacturers must begin collecting this data now to be ready for the 2027 deadline.

Carbon Footprint: The Key Challenge for Chinese Manufacturers

The carbon footprint requirement is the most challenging aspect of ESPR compliance for Chinese manufacturers. China's electricity grid is still heavily coal-dependent, which means products manufactured in China using grid electricity have a significantly higher carbon footprint than equivalent products manufactured in the EU using renewable energy. The ESPR DPP will make this difference visible to EU buyers, creating competitive pressure on Chinese manufacturers to reduce their manufacturing carbon footprint by sourcing renewable energy for their production facilities.