Summer 2026 marks a regulatory turning point for product manufacturers in the EU: the central DPP Registry goes live, the Battery Regulation activates its first QR code requirements, and the GS1 Sunrise 2027 countdown leaves little room for hesitation. This article summarizes what is actually required by the end of 2027 — and what companies need to do right now.
The Central DPP Registry: Infrastructure for the Digital Product Passport
What the Registry Stores — and What It Doesn't
The ESPR Regulation (EU) 2024/1781 deliberately keeps the central Registry lean: it stores only the product's Unique Identifier (UID), the resolver endpoint, and the associated commodity code. Product data, sustainability information, and supply chain documents are not stored centrally — they remain with the manufacturer or an accredited data service and are linked via the resolver.
The European Commission published the draft Implementing Regulation on April 29, 2026. According to current reports, the first version of the Registry is expected to be operational in July 2026 — coinciding with the ESPR framework regulation's date of application on July 18, 2026.
For economic operators, this means: anyone placing products on the market from that date onward must be able to register a valid UID and provide a reachable resolver endpoint. The regulation also requires that Registry entries remain available and up to date for at least 10 years after a product's last placement on the market.
Resolver Architecture and GS1 Digital Link
If you use GS1 Digital Link as the carrier format, you can route to different datasets via structured link types — such as gs1:sustainabilityInfo or gs1:epcis — without changing the URL in the QR code. This is technically elegant: a single QR code on the product can return different responses depending on the calling system — the consumer-facing page, the recycling portal, or the machine-readable ESPR declaration of conformity.
A minimal resolver response example in JSON-LD:
{
"@context": "https://gs1.org/voc/",
"@type": "Product",
"gtin": "04012345678901",
"linkset": [
{
"href": "https://brand.example/dpp/04012345678901",
"type": "gs1:sustainabilityInfo",
"hreflang": ["de", "en"]
},
{
"href": "https://brand.example/epcis/04012345678901",
"type": "gs1:epcis"
}
]
}
For platforms like qr3.app that generate GS1 Digital Link-compatible QR codes, this resolver mechanism is the core of DPP compliance.
Battery Regulation: August 2026 as the First Hard Deadline
QR Code Requirements and Minimum Data Obligations
The Battery Regulation (EU) 2023/1542 is the first ESPR-adjacent regulation with a concrete QR code date: starting August 2026, all batteries sold in the EU must carry visible QR codes linking to information on capacity, chemistry, and hazardous substances. This requirement applies regardless of whether the full Battery DPP is yet mandatory — the QR code with basic labeling is due earlier.
In parallel, the Commission launched a consultation in May 2026 on exemptions from battery removability requirements: according to Osborne Clarke, relief may be available for wearables and medical devices. This does not, however, affect the labeling obligations.
The Commission's "Battery Logic" pilot, which launched on May 15, 2026, is testing digital passports for LFP-based stationary battery systems of Chinese origin. Verified ISO 14067 carbon footprint data is expected by September 2026. The pilot program illustrates how tightly DPP infrastructure and customs controls will be integrated going forward — a preview of the planned Circular Economy Act, whose legislative proposal the Commission expects in Q3 2026 and which would require mandatory DPP checks at EU external borders from 2028 onward.
Timeline for Textiles and Other Product Categories
The first product-specific delegated regulations for textiles are expected to take effect in 2026/2027 under the ESPR schedule. In this context, the Fair Trade movement has published recommendations for the ESPR Textiles Delegated Act, calling for the DPP data architecture to be designed so that SMEs and smallholder farmers in third countries are not structurally disadvantaged. This is not merely a political statement: if you source from suppliers in emerging markets, you need to factor in their ability to contribute data to the DPP architecture.
GS1 Sunrise 2027: Why the Shift to 2D Codes Can No Longer Be Postponed
What Sunrise 2027 Actually Means
The GS1 Sunrise 2027 date marks the point at which retailers must operate point-of-sale systems capable of reading 2D barcodes — and at which brands can no longer treat GS1 Digital Link QR codes as a niche solution. Major retailers have already announced that 2D-capable checkout systems will be a baseline requirement from 2027.
The GS1 General Assembly 2026, which opened on May 18 in Warsaw, has the finalization of the Sunrise 2027 roadmap as a central agenda item. GS1 UK describes in a recent industry briefing how GS1-enabled QR codes are being used to link unique product identities to real-time content — while simultaneously establishing ESPR compliance.
Practical Implications for Manufacturers
The transition is not purely a technical challenge. If you are still printing only linear EAN/UPC codes today, you face three parallel requirements:
- Format change: The GS1 Digital Link QR code must encode the GTIN, batch number, expiration date, and — where applicable — serial number in a structured way, not as a free-text URL.
- Resolver operation: The resolver referenced in the QR code must be permanently reachable and must serve the link types expected by the DPP Registry.
- Data maintenance: ESPR mandates a minimum retention period of 10 years — meaning database upkeep well beyond the product's shelf life.
Platforms that offer bulk import and automated resolver management address the third point in particular: if you manage thousands of SKUs, manually maintaining product data is simply not feasible.
What to Do Now: A Practical Checklist
Regardless of your industry, the current developments point to three immediate areas of action:
By July 2026:
- Determine whether your products fall under the ESPR framework regulation and whether a UID registration process is in place.
- Set up and test a resolver endpoint — ideally GS1 Digital Link-compliant.
- Design your internal data storage for 10-year availability.
By August 2026 (Batteries):
- Attach QR codes with minimum required data (capacity, chemistry, hazardous substances) to all battery products.
- Prepare ISO 14067 carbon footprint data if LFP systems are part of your portfolio.
By End of 2026 / 2027 (Sunrise & Textiles):
- Plan and budget the migration from linear barcodes to GS1 Digital Link QR codes.
- Structure supply chain data for the Textiles DPP — especially for suppliers in third countries.
- Clarify point-of-sale system compatibility with your retail partners.
The regulatory density of the next 18 months is unusually high. Starting your infrastructure planning now lets you avoid parallel workstreams under time pressure — and puts you in a stronger position once the product-specific delegated regulations fill in the details.
