What ESPR Annex III Requires
ESPR Annex III lists the categories of information that the Digital Product Passport must contain, as a minimum. Delegated acts for specific product categories will specify which of these data categories apply, and may add product-specific data fields beyond those listed in Annex III. Annex III is therefore the floor — the minimum data that every DPP must contain — not the ceiling.
Annex III organises DPP data into two groups: information about the product itself, and information about the product's supply chain and compliance documentation. The product information covers physical and performance characteristics. The supply chain and compliance information covers the manufacturer's identity, the EU Declaration of Conformity, and the technical documentation.
Annex III Data Categories — Full List
| Annex III Category | Data Fields | Purpose |
|---|---|---|
| Product identification | GTIN, model identifier, batch/serial number, product passport identifier | Unique identification of the product and its DPP record |
| Manufacturer information | Name, address, country, EU Authorised Representative details | Responsible party identification for market surveillance |
| Product characteristics | Material composition, dimensions, weight, colour | Physical product description |
| Substances of concern | Substance name (IUPAC/CAS), location in product, concentration | Safe handling, recycling, and end-of-life management |
| Carbon footprint | CO2e per functional unit, methodology used, verification status | Climate impact transparency |
| Recycled content | Percentage by material type, verification method | Circular economy compliance |
| Durability and reliability | Expected lifetime, test standards applied, warranty duration | Product longevity transparency |
| Repairability | Repairability score, spare parts availability, repair manual URL | Right to repair support |
| Reusability | Reuse potential, refurbishment instructions | Circular economy support |
| Upgradability | Upgradable components, upgrade instructions | Product lifetime extension |
| End-of-life information | Disassembly instructions, recycling instructions, waste classification | Recycler guidance |
| Conformity documentation | EU Declaration of Conformity URL, CE marking date, notified body ID | Regulatory compliance verification |
| Technical documentation | Technical file reference, test report references | Market surveillance access |
| Energy performance | Energy efficiency class, energy consumption in use | Energy label alignment |
| Environmental footprint | Water consumption, land use, other environmental indicators | Comprehensive environmental transparency |
How Delegated Acts Use Annex III
Each ESPR delegated act for a specific product category selects the relevant Annex III data categories and specifies the exact data fields, units, and measurement methodologies for that product. For example, the battery delegated act (implemented through the Battery Regulation) selects carbon footprint, recycled content, substances of concern, and State of Health from Annex III, and adds battery-specific fields such as capacity, energy density, and cycle life that are not in Annex III.
Manufacturers must check the delegated act for their product category to determine exactly which Annex III data categories apply and what the specific data field requirements are. The Annex III list alone is not sufficient — the delegated act provides the product-specific implementation details.
Data Accuracy and Verification
ESPR Article 8(5) requires that DPP data be accurate, complete, and up to date. Manufacturers are responsible for the accuracy of the data in their DPPs. For certain high-impact data fields (such as carbon footprint and recycled content), delegated acts may require third-party verification of the data before it can be included in the DPP. The verification requirements will be specified in the applicable delegated act.
Access Levels for Annex III Data
Not all Annex III data is accessible to all actors. ESPR Article 8(4) establishes three access levels: public data (accessible to anyone via the product QR code), restricted data (accessible to market surveillance authorities and customs), and confidential data (accessible only to the manufacturer and authorised parties). The delegated act for each product category specifies which data fields are public, restricted, or confidential.
Annex III Data Categories: The Complete List
Annex III of ESPR (Regulation EU 2024/1781) specifies the categories of information that may be required in a Digital Product Passport. The annex lists twelve data categories: (1) general product information including the unique product identifier, product model identifier, and manufacturer details; (2) information on the product's components and materials, including substances of concern; (3) information on the use of the product, including maintenance requirements and consumables; (4) information on the end-of-life treatment of the product, including disassembly instructions and recyclability; (5) information on the product's environmental performance, including energy efficiency, carbon footprint, and recycled content; (6) information on the product's social performance, including supply chain due diligence; (7) information on the product's safety, including hazardous substances and safety instructions; (8) information on the product's conformity, including the EU Declaration of Conformity reference; (9) information on the product's economic performance, including spare parts pricing and availability; (10) information on the product's functional performance, including durability and reliability data; (11) information on the product's digital aspects, including software version and update policy; and (12) other information specified in the delegated act for the product category.
Mandatory vs Optional Annex III Data Fields
Not all twelve Annex III data categories are mandatory for every product category. The delegated act for each product category will specify which data categories are mandatory, which are optional but recommended, and which are not applicable. The EU Battery Regulation's DPP specification — which serves as the template for ESPR — makes categories 1, 2, 5, 7, 8, and 11 mandatory for all battery types, with additional mandatory fields specific to each battery chemistry. Manufacturers should not wait for the delegated act for their product category to begin collecting Annex III data — the categories are stable and manufacturers can begin building their data collection systems now based on the Annex III framework.
Substances of Concern: The ESPR SCIP Database Connection
Annex III category 2 requires disclosure of substances of concern in the product. Under ESPR, a substance of concern is any substance that meets the criteria in Article 2(28) — substances on the REACH Candidate List (substances of very high concern, SVHCs), substances restricted under REACH Annex XVII, substances regulated under other EU legislation (RoHS, POPs Regulation, Biocidal Products Regulation), and substances identified in the delegated act as requiring disclosure. The ESPR DPP substance disclosure requirement is directly linked to the SCIP database (Substances of Concern In articles as such or in complex objects/Products) operated by ECHA (European Chemicals Agency). Manufacturers that are already submitting SCIP notifications to ECHA can use their SCIP data as the basis for the ESPR DPP substance disclosure.
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Register Your Digital Product Passport →Annex III Data Categories in Detail
ESPR Annex III specifies the categories of information that may be required in a Digital Product Passport. These categories are not all mandatory for every product — the specific data requirements for each product category are determined by the relevant delegated act. However, Annex III provides the framework within which all DPP data requirements must fit. Understanding Annex III is essential for manufacturers who want to anticipate the data requirements for their products before the relevant delegated act is adopted.
The Annex III data categories are organised into the following groups. First, product identification data: the product model identifier, the batch or serial number, the date of manufacture, the place of manufacture, and the manufacturer's contact information. Second, product performance data: the product's performance on the parameters specified in the delegated act (such as energy efficiency, durability, repairability, and recyclability). Third, material composition data: the materials used in the product, including the percentage of recycled content and the presence of substances of concern. Fourth, supply chain data: information on the origin of key materials and components, including supply chain due diligence information. Fifth, end-of-life data: instructions for disassembly, recycling, and disposal of the product and its components. Sixth, compliance data: references to the applicable delegated acts, harmonised standards, and conformity assessment procedures.
The Annex III data categories are designed to be comprehensive enough to support a wide range of policy objectives — from energy efficiency labelling to supply chain due diligence to end-of-life management. Not all of these data categories will be required for every product. The delegated act for each product category will specify which Annex III data categories are required and what the specific data requirements are within each category.
Frequently Asked Questions
No. Annex III provides the framework of possible data categories, but the specific data requirements for each product are determined by the relevant delegated act. Not all Annex III data categories will be required for every product. The delegated act will specify which categories are required and what the specific data requirements are.
No. Delegated acts can only require data that falls within the Annex III data categories. If the Commission identifies a need for data that is not covered by Annex III, it would need to amend ESPR to add the new data category before it could be required in a delegated act. This provides legal certainty for manufacturers about the scope of possible DPP data requirements.
The EU Battery Regulation's Battery Passport data requirements are broadly aligned with the ESPR Annex III data categories. The Battery Passport can be considered a specific implementation of the ESPR DPP framework for batteries. Manufacturers of battery-containing products will need to ensure that their ESPR DPP links to the Battery Passport for the battery component.
Annex III specifies the categories of information that may be required in a DPP. Annex VI specifies the conformity assessment procedures that manufacturers must follow to demonstrate that their products meet the requirements of a delegated act. These are separate but related requirements — the DPP data (Annex III) is the output of the conformity assessment process (Annex VI).
ESPR includes a review mechanism that allows the Commission to update the Annex III data categories in response to technological developments and new policy priorities. The Commission is required to review ESPR by 2030 and may propose amendments to the Annex III data categories at that time. Manufacturers should monitor the ESPR review process for potential changes to the data category framework.