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.
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.
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.
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]
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]
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]
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.)
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]
All the dated obligations from the rules above, in order — colour-coded by whether they bind you as a food brand.
18 July 2024 DPP track — food excluded
The Ecodesign Regulation establishes the Digital Product Passport. Article 1(2) expressly excludes food and feed from its scope.
11 February 2025 Applies to food & drink
Regulation (EU) 2025/40, published 22 January 2025. It replaces the Packaging Directive 94/62/EC.
April 2025 DPP track — food excluded
Prioritises steel and aluminium, textiles, furniture, tyres, mattresses and energy-related products. Food is not on the list — it cannot be.
30 December 2026 Applies to food & drink
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.
12 February 2027 Applies to food & drink
Packaging covered by an extended-producer-responsibility scheme must be identifiable via a symbol in a QR code (Art. 12 PPWR).
12 August 2028 Applies to food & drink
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 February 2029 Applies to food & drink
The regulation's recitals name “a QR code or other standardised, open, digital data carrier” for reuse information.
1 January 2030 Applies to food & drink
Packaging needs a recyclability performance grade; plastic packaging 10–35% recycled content depending on type.
As of 7 September 2026. EU primary sources unless labelled otherwise.
Pack Identity is the page behind the code: the FIC fields, an e-label mode for wine, packaging parts, lots.
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