[{"data":1,"prerenderedAt":793},["ShallowReactive",2],{"page-\u002Fguides\u002Fdigital-product-passport-access-rights":3,"related-\u002Fguides\u002Fdigital-product-passport-access-rights":771},{"id":4,"title":5,"author":6,"body":7,"category":756,"description":757,"extension":758,"heading":759,"heroImage":756,"heroImageAlt":760,"howTo":756,"layout":761,"meta":762,"navigation":763,"ogImage":764,"path":765,"publishedAt":766,"sections":756,"seo":767,"sourcePath":768,"stem":769,"updatedAt":766,"videoPosition":756,"videos":756,"__hash__":770},"pages\u002Fguides\u002Fdigital-product-passport-access-rights.md","Digital Product Passport access rights: who sees what","Mia",{"type":8,"value":9,"toc":729},"minimark",[10,17,30,41,49,54,126,129,133,144,151,154,158,285,289,292,295,299,302,305,309,316,319,323,330,337,340,344,347,359,363,377,380,402,405,410,425,428,435,439,442,450,511,526,530,533,541,624,627,631,675,683,687,691,694,698,701,705,708,712,715,719,722,726],[11,12,13],"p",{},[14,15,16],"strong",{},"TL;DR",[18,19,20,24,27],"ul",{},[21,22,23],"li",{},"Digital Product Passport access rights are set per actor: the delegated act for each product group decides who sees which data and who may change it.",[21,25,26],{},"A passport is not a public data dump. The ESPR restricts write access, requires security and fraud prevention, bars service providers from reusing your data, and allows exemptions to protect confidential business information.",[21,28,29],{},"The battery passport is the worked example: public data for everyone, detailed composition and dismantling data only for persons with a legitimate interest, and test reports only for authorities.",[11,31,32,33,40],{},"\"Will my competitors see my bill of materials?\" is the first question manufacturers ask about the Digital Product Passport, and the answer is no, not by default. Digital Product Passport access rights are built into the law. The ",[34,35,39],"a",{"href":36,"rel":37},"https:\u002F\u002Feur-lex.europa.eu\u002Feli\u002Freg\u002F2024\u002F1781\u002Foj\u002Feng",[38],"nofollow","ESPR",", Regulation (EU) 2024\u002F1781, gives each actor access according to the rights set for that actor, and leaves the detail to the delegated act for each product group. Customers, recyclers, authorities and competitors do not all see the same thing.",[11,42,43,44,48],{},"This guide covers the provisions that control access, what they mean for commercially sensitive data, how the battery passport already splits its audiences, and how a single QR code can serve all of them. The list of passport data elements is covered in ",[34,45,47],{"href":46},"\u002Fguides\u002Fdigital-product-passport-data-requirements\u002F","Digital Product Passport data requirements",". Everything below is stated as of October 2026.",[50,51,53],"h2",{"id":52},"the-dates-that-matter-for-access","The dates that matter for access",[55,56,57,70],"table",{},[58,59,60],"thead",{},[61,62,63,67],"tr",{},[64,65,66],"th",{},"Date",[64,68,69],{},"What happens",[71,72,73,82,90,98,106,118],"tbody",{},[61,74,75,79],{},[76,77,78],"td",{},"28 June 2024",[76,80,81],{},"The ESPR is published in the Official Journal, with the access rules in Articles 9 to 11",[61,83,84,87],{},[76,85,86],{},"16 July 2026",[76,88,89],{},"Implementing Regulation (EU) 2026\u002F1778 sets the arrangements for the DPP registry, including identity verification of its users",[61,91,92,95],{},[76,93,94],{},"19 July 2026",[76,96,97],{},"Deadline in Article 13(1) of the ESPR for the Commission to set up the registry",[61,99,100,103],{},[76,101,102],{},"18 August 2026",[76,104,105],{},"Deadline in Article 77(9) of the Battery Regulation for the implementing acts defining \"persons with a legitimate interest\"",[61,107,108,113],{},[76,109,110],{},[14,111,112],{},"18 February 2027",[76,114,115],{},[14,116,117],{},"Battery passport required for LMT batteries, EV batteries and industrial batteries over 2 kWh",[61,119,120,123],{},[76,121,122],{},"Per delegated act",[76,124,125],{},"Access rights for each ESPR product group",[11,127,128],{},"As of October 2026, no ESPR delegated act setting passport requirements for a product group has been adopted, so no ESPR product group has its access rights fixed yet. The battery passport is the only one with access tiers written into law and a firm date.",[50,130,132],{"id":131},"does-a-digital-product-passport-make-my-data-public","Does a Digital Product Passport make my data public?",[11,134,135,136,139,140,143],{},"No. Article 11(b) of the ESPR lists the actors who must have ",[14,137,138],{},"free and easy access"," to the passport: customers, manufacturers, importers, distributors, dealers, repairers, independent operators, refurbishers, remanufacturers, recyclers, market surveillance and customs authorities, civil society organisations, trade unions and other relevant actors. In the same sentence it qualifies that access: it is ",[14,141,142],{},"based on their respective access rights"," set out in the delegated act. Article 10(1)(g) makes regulated access an essential requirement of every passport.",[11,145,146,147,150],{},"Recital 32 states the intent. The passport should let value chain actors access, introduce or update relevant data ",[14,148,149],{},"without endangering the protection of confidential business information",". Confidentiality is one of the conditions the passport is designed around.",[11,152,153],{},"What is public is therefore decided per product group. Some information will be visible to anyone who scans the code. Other data will be visible only to named categories of professional users or to authorities.",[50,155,157],{"id":156},"what-the-espr-says-about-access-provision-by-provision","What the ESPR says about access, provision by provision",[55,159,160,173],{},[58,161,162],{},[61,163,164,167,170],{},[64,165,166],{},"Provision",[64,168,169],{},"What it says",[64,171,172],{},"What it means for confidential data",[71,174,175,186,197,208,219,230,241,252,263,274],{},[61,176,177,180,183],{},[76,178,179],{},"Article 9(2)(f)",[76,181,182],{},"The delegated act specifies which actors have access to which data",[76,184,185],{},"Access is decided per actor and per data element",[61,187,188,191,194],{},[76,189,190],{},"Article 9(2)(g) and (h)",[76,192,193],{},"The delegated act specifies who creates or updates the passport, what each may introduce or update, and how",[76,195,196],{},"Suppliers and repairers can be given write rights to specific fields only",[61,198,199,202,205],{},[76,200,201],{},"Article 10(1)(e)",[76,203,204],{},"No customer personal data without explicit consent",[76,206,207],{},"Data linked to an owner is excluded by default",[61,209,210,213,216],{},[76,211,212],{},"Article 11(b)",[76,214,215],{},"Listed actors get free and easy access based on their access rights",[76,217,218],{},"Free access is not the same access for everyone",[61,220,221,224,227],{},[76,222,223],{},"Article 11(f)",[76,225,226],{},"Rights to introduce, modify or update data are restricted by the access rights",[76,228,229],{},"No one edits a passport without the right to do so",[61,231,232,235,238],{},[76,233,234],{},"Article 11(g) and (h)",[76,236,237],{},"Authentication, reliability and integrity of data; high security and privacy; fraud avoided",[76,239,240],{},"Access control and tamper protection are compliance requirements",[61,242,243,246,249],{},[76,244,245],{},"Article 11, second paragraph",[76,247,248],{},"Service providers may not sell, reuse or process passport data beyond their service, unless agreed with the economic operator",[76,250,251],{},"Your provider cannot mine your data",[61,253,254,257,260],{},[76,255,256],{},"Article 11, last paragraph",[76,258,259],{},"The Commission may adopt implementing acts on issuing and verifying the digital credentials of actors with access rights",[76,261,262],{},"Proving \"I am a recycler\" may become a standard credential",[61,264,265,268,271],{},[76,266,267],{},"Article 7(6)(b)",[76,269,270],{},"Delegated acts may exempt substances of concern or information elements, including to protect confidential business information",[76,272,273],{},"Confidentiality can justify an exemption, within limits",[61,275,276,279,282],{},[76,277,278],{},"Article 13(6)",[76,280,281],{},"Only the Commission, national authorities and customs authorities access the registry",[76,283,284],{},"The central registry is not a public lookup",[50,286,288],{"id":287},"who-decides-which-data-is-restricted","Who decides which data is restricted?",[11,290,291],{},"The Commission does, in the delegated act for each product group. A manufacturer cannot hide data that the act makes public, and it cannot publish data the act reserves for authorities to avoid running access control.",[11,293,294],{},"What the manufacturer controls is everything around those rules: which provider stores the passport, how restricted users are authenticated, what voluntary information it adds, and how cleanly it separates public and restricted data in its own systems. Until delegated acts are adopted, the safest planning assumption is the battery pattern: a public layer, a professional layer for those who repair, remanufacture and recycle, and an authorities-only layer for compliance evidence.",[50,296,298],{"id":297},"who-can-write-to-the-passport","Who can write to the passport?",[11,300,301],{},"Read access is half of the question. Under Article 9(2)(g) and (h), the delegated act says which actors may create or update the passport, which data each may change, and how, and Article 11(f) makes that restriction an essential requirement. Where a new passport is created for a product that already has one, for example after remanufacturing, Article 11(d) requires it to be linked to the original.",[11,303,304],{},"In practice, a passport platform needs permissions at field level. A repairer may record a repair without touching the manufacturer's compliance documents, and a supplier may add component data without seeing the rest of the passport. Every change has to be attributable, because Article 11(g) requires data integrity.",[50,306,308],{"id":307},"what-can-your-passport-service-provider-do-with-your-data","What can your passport service provider do with your data?",[11,310,311,312,315],{},"Very little. The second paragraph of Article 11 says service providers storing or processing passport data ",[14,313,314],{},"shall not sell, reuse or process"," it beyond what is necessary for that service, unless the economic operator placing the product on the market specifically agrees. Article 2(32) defines the provider as an independent third party authorised by that operator, and Article 10(4) requires a back-up copy of every passport through one.",[11,317,318],{},"Read the contract, because a specific agreement with you is the only route to wider use. Check that one does not arrive by accident in a clause on \"aggregated analytics\". The Commission may also adopt delegated acts setting requirements for providers and a certification scheme; as of October 2026, it has not.",[50,320,322],{"id":321},"can-confidential-business-information-keep-substances-out-of-the-passport","Can confidential business information keep substances out of the passport?",[11,324,325,326,329],{},"Sometimes, and only within a hard limit. Article 7(6)(b) allows the Commission to provide duly justified exemptions for substances of concern or information elements in a delegated act. The grounds include technical feasibility, the existence of analytical methods and ",[14,327,328],{},"the need to protect confidential business information",". Article 5(10)(d) also requires the Commission to consider that protection when preparing ecodesign requirements.",[11,331,332,333,336],{},"The limit: substances on the REACH candidate list, point (a) of the definition in Article 2(27), cannot be exempted when present in products, components or spare parts above ",[14,334,335],{},"0.1% weight by weight",".",[11,338,339],{},"The exemption is granted by the Commission, not claimed by a manufacturer. If a formulation is genuinely sensitive, make the case during consultation on the delegated act, through your trade association or the Ecodesign Forum. Otherwise, under Article 7(7), information that makes it possible to track substances of concern must be on the product or accessible through a data carrier on it.",[50,341,343],{"id":342},"what-does-the-eu-registry-see","What does the EU registry see?",[11,345,346],{},"Less than people assume. Article 13 requires the registry to store at least the unique identifiers, plus the commodity code for products released for free circulation. The passport's content stays with the economic operator or its service provider under Article 11(c).",[11,348,349,350,353,354,358],{},"Article 13(6) limits access to the registry to ",[14,351,352],{},"the Commission, competent national authorities and customs authorities",". Implementing Regulation (EU) 2026\u002F1778 adds identity verification: an economic operator that is a legal person registers passports after proving its identity with a qualified electronic seal or a qualified electronic attestation of attributes under eIDAS, and value chain actors such as recyclers must be verified before they can act in the registry. The ",[34,355,357],{"href":356},"\u002Fguides\u002Feuropean-dpp-registry\u002F","DPP registry guide"," covers registration in detail.",[50,360,362],{"id":361},"the-battery-passport-access-tiers-in-practice","The battery passport: access tiers in practice",[11,364,365,366,371,372,376],{},"The Battery Regulation, ",[34,367,370],{"href":368,"rel":369},"https:\u002F\u002Feur-lex.europa.eu\u002Feli\u002Freg\u002F2023\u002F1542\u002Foj\u002Feng",[38],"Regulation (EU) 2023\u002F1542",", is the first passport law with access tiers written down. Its four tiers are listed in our ",[34,373,375],{"href":374},"\u002Fguides\u002Fbattery-passport\u002F","battery passport guide",". What matters here is how access works.",[11,378,379],{},"Article 77(2) divides the information into three audiences:",[381,382,383,390,396],"ol",{},[21,384,385,386,389],{},"the ",[14,387,388],{},"general public",", for point 1 of Annex XIII;",[21,391,392,395],{},[14,393,394],{},"notified bodies, market surveillance authorities and the Commission",", for points 2 and 3;",[21,397,398,401],{},[14,399,400],{},"persons with a legitimate interest",", for points 2 and 4.",[11,403,404],{},"The legitimate interest is tied to a purpose. For model data, it must concern dismantling, safety measures and detailed composition, and be essential for repairers, remanufacturers, second-life operators and recyclers to carry on their activities. For individual batteries, it must be essential to the purchaser, or those acting for it, to make the battery available to independent energy aggregators or energy market participants. Access follows what the person does with the data.",[406,407,409],"h3",{"id":408},"the-implementing-act-on-persons-with-a-legitimate-interest","The implementing act on \"persons with a legitimate interest\"",[11,411,412,413,416,417,420,421,424],{},"Article 77(9) required the Commission to adopt, ",[14,414,415],{},"by 18 August 2026",", implementing acts specifying who counts as a person with a legitimate interest, which information each may access, and to what extent they may ",[14,418,419],{},"download, share, publish and re-use"," it. One of the criteria set in the Regulation speaks directly to trade secrets: access to commercially sensitive information must be ",[14,422,423],{},"limited to the minimum necessary"," under Union law.",[11,426,427],{},"As of October 2026, we have not found that implementing act in the Official Journal. The tiers are fixed, but the list of qualifying persons and the rules on re-use are not. Plan for the tiers now and keep the qualifying rules configurable.",[11,429,430,431,434],{},"Article 78 mirrors the ESPR's safeguards: access based on Annex XIII and the implementing act, restricted write rights, no reuse of data by operators storing it on someone's behalf, and integrity, security and fraud prevention. The lesson for ESPR product groups is simple: ",[14,432,433],{},"test reports go to authorities, detailed composition goes to professionals with a purpose",", and a competitor scanning the code sees what a consumer sees.",[50,436,438],{"id":437},"how-one-qr-code-serves-every-audience","How one QR code serves every audience",[11,440,441],{},"The data carrier does not change by audience. Article 10(1)(a) of the ESPR connects the passport to a persistent unique product identifier through a data carrier, so there is one code and differentiated access happens after the scan.",[11,443,444,445,449],{},"This is where ",[34,446,448],{"href":447},"\u002Fguides\u002Fgs1-digital-link-basics\u002F","GS1 Digital Link"," helps. A GS1 Digital Link URI is a web address containing the product's GTIN and, where needed, its batch or serial number. When it is scanned, a resolver can return different responses for the same identifier: a consumer page by default, other link types for applications that ask for them, and a route to restricted data for users who sign in.",[55,451,452,465],{},[58,453,454],{},[61,455,456,459,462],{},[64,457,458],{},"Who scans",[64,460,461],{},"What they present",[64,463,464],{},"What they should get",[71,466,467,478,489,500],{},[61,468,469,472,475],{},[76,470,471],{},"A consumer or a competitor",[76,473,474],{},"A phone camera",[76,476,477],{},"The public passport view",[61,479,480,483,486],{},[76,481,482],{},"A recycler or repairer",[76,484,485],{},"Credentials showing their role",[76,487,488],{},"Dismantling, composition and safety data",[61,490,491,494,497],{},[76,492,493],{},"A market surveillance authority",[76,495,496],{},"Authority credentials",[76,498,499],{},"Test reports and compliance evidence",[61,501,502,505,508],{},[76,503,504],{},"A supplier",[76,506,507],{},"Write credentials for its fields",[76,509,510],{},"A form to add or update its component data",[11,512,513,514,517,518,521,522,525],{},"Three caveats keep this honest. ",[14,515,516],{},"The QR code is not the security",": anyone can read it, and access control sits in the passport application behind it. ",[14,519,520],{},"No law mandates this method",": the ESPR requires a carrier and identifier that comply with the ISO\u002FIEC 15459 series or equivalent, GS1 identifiers are built on that series, and GS1 Digital Link is one practical way to serve every audience with a single code. ",[14,523,524],{},"Credentials are still open",": as of October 2026, no implementing act on digital credentials under Article 11 has been adopted, so any credential scheme used today should be replaceable.",[50,527,529],{"id":528},"what-to-keep-confidential-and-what-you-cannot","What to keep confidential, and what you cannot",[11,531,532],{},"Until your delegated act is adopted, sort your data into likely tiers. This is a planning aid based on the battery model and the ESPR, not a ruling on any product group.",[11,534,535],{},[536,537],"img",{"alt":538,"src":539,"title":540},"An engineer at a desk beside a machined metal component, setting access permissions for product data on a laptop screen with toggle switches and padlock icons","\u002Fimages\u002F2026\u002F10\u002Fdpp-confidential-data-permissions.webp","Deciding what stays confidential is a data decision you can make before your delegated act arrives",[55,542,543,556],{},[58,544,545],{},[61,546,547,550,553],{},[64,548,549],{},"Data",[64,551,552],{},"Likely audience",[64,554,555],{},"Basis",[71,557,558,569,580,591,602,613],{},[61,559,560,563,566],{},[76,561,562],{},"Model information, instructions, declaration of conformity",[76,564,565],{},"Public",[76,567,568],{},"Battery Annex XIII point 1",[61,570,571,574,577],{},[76,572,573],{},"Candidate-list substances above 0.1%",[76,575,576],{},"Through the data carrier; cannot be exempted",[76,578,579],{},"ESPR Article 7(6)(b) and 7(7)",[61,581,582,585,588],{},[76,583,584],{},"Detailed composition, part numbers, dismantling sequences",[76,586,587],{},"Professionals with a defined purpose",[76,589,590],{},"Battery Annex XIII point 2",[61,592,593,596,599],{},[76,594,595],{},"Test reports proving compliance",[76,597,598],{},"Authorities only",[76,600,601],{},"Battery Annex XIII point 3",[61,603,604,607,610],{},[76,605,606],{},"Item-level usage and state data",[76,608,609],{},"Persons with a legitimate interest; no customer personal data without consent",[76,611,612],{},"Battery Annex XIII point 4; ESPR Article 10(1)(e)",[61,614,615,618,621],{},[76,616,617],{},"Prices, margins, supplier contracts",[76,619,620],{},"Not passport data",[76,622,623],{},"Not required by the texts discussed here",[11,625,626],{},"The last row answers most buyers' fears. A passport carries what the law requires plus what you choose to add. Commercial terms do not belong in it.",[50,628,630],{"id":629},"what-to-do-now","What to do now",[381,632,633,639,645,651,657,663,669],{},[21,634,635,638],{},[14,636,637],{},"Map your data to tiers",", using the battery structure: public, professional with a purpose, authorities only, and item-level.",[21,640,641,644],{},[14,642,643],{},"Identify what is genuinely confidential."," Formulations, supplier identities and test methods are the usual candidates.",[21,646,647,650],{},[14,648,649],{},"Engage early on exemptions."," If a substance disclosure would reveal a trade secret, make the case during consultation on your delegated act.",[21,652,653,656],{},[14,654,655],{},"Check your provider contract"," against the second paragraph of ESPR Article 11 and Article 78(d) of the Battery Regulation.",[21,658,659,662],{},[14,660,661],{},"Require field-level permissions"," from any passport platform, with every change logged.",[21,664,665,668],{},[14,666,667],{},"Keep the credential layer replaceable",", because implementing acts on credentials and on legitimate interest may still change how users prove who they are.",[21,670,671,674],{},[14,672,673],{},"Use one code",", and let the passport behind it decide what each user sees, so packaging never changes when access rules do.",[11,676,677,678,682],{},"Digital Link is a GS1 solution partner, and our platform builds standards-based product passports with one GS1 Digital Link QR code per product and role-based access behind it: a public view for everyone, restricted views for repairers, recyclers and authorities, and write rights limited to the fields each actor owns. If you want to work out which of your data should be public and which should stay restricted, ",[34,679,681],{"href":680},"mailto:support@digital-link.com","get in touch"," and our legal team will review your case.",[50,684,686],{"id":685},"frequently-asked-questions","Frequently asked questions",[406,688,690],{"id":689},"will-competitors-see-my-product-data-in-the-digital-product-passport","Will competitors see my product data in the Digital Product Passport?",[11,692,693],{},"Only what the public sees. The ESPR gives each actor access based on its rights in the delegated act, and in the battery passport detailed composition is limited to persons with a legitimate interest and test reports to authorities.",[406,695,697],{"id":696},"who-decides-which-passport-data-is-public","Who decides which passport data is public?",[11,699,700],{},"The Commission, in the delegated act for each product group, under Article 9(2)(f) of the ESPR. As of October 2026, none setting passport requirements has been adopted, so the battery passport is the best guide to the likely pattern.",[406,702,704],{"id":703},"can-i-refuse-to-disclose-substances-of-concern-for-confidentiality-reasons","Can I refuse to disclose substances of concern for confidentiality reasons?",[11,706,707],{},"Not on your own. The Commission can grant duly justified exemptions in a delegated act under Article 7(6)(b), including to protect confidential business information. Candidate-list substances above 0.1% weight by weight cannot be exempted.",[406,709,711],{"id":710},"can-my-passport-provider-use-my-data","Can my passport provider use my data?",[11,713,714],{},"Not beyond what storing or processing it requires, unless you specifically agree. Article 11 of the ESPR and Article 78(d) of the Battery Regulation both prohibit providers from selling or reusing the data.",[406,716,718],{"id":717},"who-counts-as-a-person-with-a-legitimate-interest-for-the-battery-passport","Who counts as a person with a legitimate interest for the battery passport?",[11,720,721],{},"Article 77(2) points to repairers, remanufacturers, second-life operators and recyclers, and to purchasers making a battery available to energy aggregators or market participants. The implementing act defining them was due by 18 August 2026; as of October 2026, we have not found it in the Official Journal.",[406,723,725],{"id":724},"does-every-user-need-a-different-qr-code","Does every user need a different QR code?",[11,727,728],{},"No. The product carries one data carrier linked to one persistent identifier. Different users get different data after the scan, through authentication in the passport application.",{"title":730,"searchDepth":731,"depth":731,"links":732},"",3,[733,735,736,737,738,739,740,741,742,745,746,747,748],{"id":52,"depth":734,"text":53},2,{"id":131,"depth":734,"text":132},{"id":156,"depth":734,"text":157},{"id":287,"depth":734,"text":288},{"id":297,"depth":734,"text":298},{"id":307,"depth":734,"text":308},{"id":321,"depth":734,"text":322},{"id":342,"depth":734,"text":343},{"id":361,"depth":734,"text":362,"children":743},[744],{"id":408,"depth":731,"text":409},{"id":437,"depth":734,"text":438},{"id":528,"depth":734,"text":529},{"id":629,"depth":734,"text":630},{"id":685,"depth":734,"text":686,"children":749},[750,751,752,753,754,755],{"id":689,"depth":731,"text":690},{"id":696,"depth":731,"text":697},{"id":703,"depth":731,"text":704},{"id":710,"depth":731,"text":711},{"id":717,"depth":731,"text":718},{"id":724,"depth":731,"text":725},null,"Digital Product Passport access rights explained: who sees which data under the ESPR, how the battery passport restricts it, and how to protect trade secrets.","md","Digital Product Passport access rights: who sees your data, and what stays confidential","Two technicians in an e-bike repair workshop scanning the same QR code on a removed battery pack: one phone shows the product page, the other a padlock","article",{},true,"\u002Fimages\u002F2026\u002F10\u002Fdigital-product-passport-access-rights-hero.webp","\u002Fguides\u002Fdigital-product-passport-access-rights","2026-10-22T12:13:00+02:00",{"title":5,"description":757},"\u002Fguides\u002Fdigital-product-passport-access-rights\u002F","guides\u002Fdigital-product-passport-access-rights","fkdtZWXatmtUYncPxv9yu0O1GPxfzdChogqSRwkuddo",[772,779,786],{"path":773,"sourcePath":774,"title":775,"heading":776,"ogImage":777,"publishedAt":778},"\u002Fguides\u002Fespr-working-plan-2025-2030","\u002Fguides\u002Fespr-working-plan-2025-2030\u002F","ESPR working plan 2025–2030: every product group and date","The ESPR working plan 2025–2030, category by category: what is prioritised, when, and what it means for you","\u002Fimages\u002F2026\u002F10\u002Fespr-working-plan-2025-2030-hero.webp","2026-10-21T12:13:00+02:00",{"path":780,"sourcePath":781,"title":782,"heading":783,"ogImage":784,"publishedAt":785},"\u002Fguides\u002Fgpsr-importer-obligations","\u002Fguides\u002Fgpsr-importer-obligations\u002F","GPSR importer obligations: traceability and recalls","GPSR importer obligations: traceability, contact details and recalls under Regulation (EU) 2023\u002F988","\u002Fimages\u002F2026\u002F10\u002Fgpsr-importer-obligations-hero.webp","2026-10-20T12:13:00+02:00",{"path":787,"sourcePath":788,"title":789,"heading":790,"ogImage":791,"publishedAt":792},"\u002Fguides\u002Feu-toy-safety-regulation-dpp","\u002Fguides\u002Feu-toy-safety-regulation-dpp\u002F","EU Toy Safety Regulation: the toy digital product passport","The EU Toy Safety Regulation and the digital product passport for toys","\u002Fimages\u002F2026\u002F10\u002Feu-toy-safety-regulation-dpp-hero.webp","2026-10-19T17:12:00+02:00",1792665732243]