What actually applies —
and from when.

A market of urgency has grown around the “Digital Product Passport”. This page sorts it out: which EU rules actually apply to food and drink, what the passport really is, and which date belongs to which obligation. Every claim carries a source — the numbers lead to the list at the end of the page.

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The most important sentence first:

Food and drink are excluded from the Digital Product Passport under the Ecodesign Regulation. [7]

Article 1(2) of Regulation (EU) 2024/1781 expressly excludes food and feed as defined in Regulation (EC) No 178/2002 from its scope — along with medicinal products and living organisms. GS1’s own provisional DPP application standard says the same: “Explicitly excluded are e.g. food, feed, medicinal products and motor vehicles.” [19] Anyone selling you “a DPP for your food product” is selling something that legally does not exist. What applies to you instead is below — and it is concrete enough.

What actually applies
to food & drink.

Four bodies of rules touch the information on and behind your pack. Three are law in force, one is an industry initiative — each card says which it is.

Law in force · applicable since 2014

FIC — the baseline of all food information

Regulation (EU) No 1169/2011 governs the mandatory particulars: the name of the food, the ingredients list, the allergens, net quantity, the nutrition declaration, the food business operator. [1]

  • Applies to every prepacked food on the EU market
  • Defines what the label must say — and with it, the minimum a product page should answer
Law in force · since 8 December 2023

Wine: the e-label is permitted — under conditions

Since 8 December 2023, wine needs a nutrition declaration and an ingredients list. The physical label may carry the energy value alone; the rest may be provided electronically, for example via a QR code. [2] [3]

  • Condition: no collection or tracking of user data, and no marketing content on the e-label page [4]
  • Allergens and the energy value always stay on the physical label
  • Wine produced before the cut-off may sell through existing stocks
Law in force · applies since 12 August 2026

PPWR — the rulebook for your packaging

Regulation (EU) 2025/40 on packaging and packaging waste entered into force on 11 February 2025 and applies since 12 August 2026, replacing Directive 94/62/EC — with a cascade of labelling obligations through 2030. [5] [6]

  • 2027: packaging in an EPR scheme identifiable via a symbol in a QR code
  • 2028: harmonised material labels; the codes of Decision 97/129/EC are superseded
  • Important: the QR code is a permitted data carrier, not a mandate on every pack — the specifics arrive via implementing acts
Industry initiative · not law

GS1 “Sunrise 2027” — the 2D barcode at checkout

The global GS1 ambition: by the end of 2027, retail checkouts should read 2D barcodes — QR codes with GS1 Digital Link and GS1 DataMatrix — with dual 1D+2D marking during the transition. [14] (GS1’s formal name for the programme is “Ambition 2027”; “Sunrise 2027” is the common usage.)

  • No legal obligation follows from it — the pressure comes from retailers, not the legislator
  • In Austria the 2D code is being discussed as the primary data carrier from 2028; Metro Österreich already scans GS1 DataMatrix on fresh goods [15]

What the Digital Product Passport
actually is.

The Digital Product Passport is an instrument of the Ecodesign Regulation (EU) 2024/1781, in force since 18 July 2024. It is established in Articles 9 to 13 and switched on product group by product group through delegated acts — not for every product at once, and for food not at all. [7]

The first Working Plan 2025–2030 (adopted April 2025) prioritises steel and aluminium, textiles with a focus on apparel, furniture, tyres, mattresses, and energy-related products. [8] The Commission’s indicative schedule: delegated acts for iron and steel in 2026; textiles, tyres and aluminium in 2027; furniture in 2028; mattresses and ICT in 2029 — each followed by a transition of at least 18 months before obligations apply. A delegated act on DPP service providers is scheduled for adoption in the fourth quarter of 2026. [18]

Since 20 July 2026 the EU DPP Registry is live, including a testing environment; the practical rules are set by Implementing Regulation (EU) 2026/1778. [10] [11] [12] The first real deadline belongs to the battery passport: from 18 February 2027 for EV, light-means-of-transport and industrial batteries under the Batteries Regulation (EU) 2023/1542. [13]

Every deadline, one track.

All the dated obligations from the rules above, in order — colour-coded by whether they bind you as a food brand.

  1. 8 December 2023 Applies to food & drink

    Wine: nutrition declaration and ingredients list become mandatory [2] [3]

    Both may be provided electronically, e.g. via QR code — with no user tracking and no marketing content. Allergens and energy value stay on the physical label.

  2. 18 July 2024 DPP track — food excluded

    ESPR enters into force — and excludes food [7]

    The Ecodesign Regulation establishes the Digital Product Passport. Article 1(2) expressly excludes food and feed from its scope.

  3. 11 February 2025 Applies to food & drink

    Packaging Regulation (PPWR) enters into force [5]

    Regulation (EU) 2025/40, published 22 January 2025. It replaces the Packaging Directive 94/62/EC.

  4. April 2025 DPP track — food excluded

    First ESPR Working Plan 2025–2030 adopted [8]

    Prioritises steel and aluminium, textiles, furniture, tyres, mattresses and energy-related products. Food is not on the list — it cannot be.

  5. 20 July 2026 DPP track — food excluded

    The EU DPP Registry goes live [10] [11]

    With a testing environment; practical rules are set by Implementing Regulation (EU) 2026/1778.

  6. 12 August 2026 Applies to food & drink

    The PPWR applies [5] [6]

    From now on the regulation is the binding framework for every pack on the EU market — food and drink included.

  7. 30 December 2026 Applies to food & drink

    EUDR: cocoa, coffee, palm oil, soy, cattle, rubber and wood need plot geolocation [16] [17]

    Regulation (EU) 2023/1115 on deforestation-free products. The due-diligence statement requires the geolocation of the plots the commodities were produced on — origin at plot level, not country level. Micro and small enterprises and natural persons from 30 June 2027. Postponed twice, most recently by Regulation (EU) 2025/2650.

  8. 12 February 2027 Applies to food & drink

    EPR labelling: a symbol carried in a QR code [5]

    Packaging covered by an extended-producer-responsibility scheme must be identifiable via a symbol in a QR code (Art. 12 PPWR).

  9. 18 February 2027 DPP track — food excluded

    Battery passport becomes mandatory — the first real DPP deadline [10] [13]

    For EV, light-means-of-transport and industrial batteries under Regulation (EU) 2023/1542. Not for food.

  10. End of 2027 Industry initiative, not law

    GS1 “Sunrise 2027” — retail checkouts aim to scan 2D barcodes [14] [15]

    An industry initiative, not law: QR codes with GS1 Digital Link and GS1 DataMatrix at point of sale, with dual 1D+2D marking during the transition.

  11. 12 August 2028 Applies to food & drink

    Harmonised material labels; Decision 97/129/EC repealed [5]

    Harmonised material-composition labels become mandatory. The material codes of Decision 97/129/EC apply until this day — then the new specifications take over.

  12. 12 February 2029 Applies to food & drink

    Reusable packaging must carry a reusability label [5]

    The regulation's recitals name “a QR code or other standardised, open, digital data carrier” for reuse information.

  13. 1 January 2030 Applies to food & drink

    Recyclability grades A/B/C and minimum recycled content [5]

    Packaging needs a recyclability performance grade; plastic packaging 10–35% recycled content depending on type.

Every claim, cited.

As of 7 September 2026. EU primary sources unless labelled otherwise.

  1. Regulation (EU) No 1169/2011 (FIC) — EUR-Lex https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011R1169
  2. Regulation (EU) 2021/2117 (wine labelling) — EUR-Lex https://eur-lex.europa.eu/eli/reg/2021/2117/oj/eng
  3. European Commission: New rules for wine labelling, 7 December 2023 https://agriculture.ec.europa.eu/media/news/new-rules-wine-labelling-enter-application-2023-12-07_en
  4. Commission Notice C/2023/1190 (interpretive guidance) — EUR-Lex https://eur-lex.europa.eu/eli/C/2023/1190/oj/eng
  5. Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) — EUR-Lex https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
  6. European Commission: Packaging waste (topic page) https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
  7. Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products, ESPR) — EUR-Lex https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R1781
  8. First ESPR Working Plan 2025–2030 (adopted April 2025) — European Commission https://green-forum.ec.europa.eu/news/2025-2030-working-plan-2025-07-11_en
  9. European Commission: Digital Product Passport (incl. indicative delegated-act schedule) https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en
  10. European Commission: Digital Product Passport Registry now live, 20 July 2026 https://single-market-economy.ec.europa.eu/news/digital-product-passport-registry-now-live-2026-07-20_en
  11. European Commission: DPP Registry (information page) https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/dpp-registry_en
  12. EU DPP Registry (the registry itself) https://registry.product-passport.ec.europa.eu
  13. Regulation (EU) 2023/1542 (Batteries Regulation) — EUR-Lex https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542
  14. GS1: 2D Barcodes at Retail Point-of-Sale Implementation Guideline Industry initiative — not a legal act https://ref.gs1.org/guidelines/2d-in-retail/
  15. Retail Report (Austrian trade press): “GS1 Austria: Der 2D-Code kommt” Trade press, secondary source https://retailreport.at/gs1-austria-der-2d-code-kommt
  16. Regulation (EU) 2023/1115 on deforestation-free products (EUDR) — EUR-Lex https://eur-lex.europa.eu/eli/reg/2023/1115/oj/eng
  17. Council of the EU: Deforestation — Council signs off targeted revision, 18 December 2025 https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/deforestation-council-signs-off-targeted-revision-to-simplify-and-postpone-the-regulation/
  18. European Commission, Have Your Say — initiative 14382: Digital product passport, service providers https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14382-Digital-product-passport-service-providers_en
  19. GS1 GSCN 26-266 — DPP provisional application standard (release 2, June 2026) Provisional GS1 standard — not ratified https://ref.gs1.org/standards/genspecs/gscn/2026/GSCN-26-266-dpp-provisional-v2.pdf

Want to see what this looks like as a product page?

Pack Identity is the page behind the code: the FIC fields, an e-label mode for wine, packaging parts, lots.

See Pack Identity or open a real page →

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