Digital product passport in Germany (Digitaler Produktpass): the EU rules apply directly, two German acts add authorities and fines

There is no German digital product passport and there will not be one. The passport comes from two EU regulations, the ESPR and the battery regulation, which apply in Germany directly and on the same dates as everywhere else in the Union. What Germany adds is the national layer: the Batterierecht-Durchführungsgesetz (BattDG), in force since 7 October 2025, and the Ökodesign-Gesetz (ÖkodesignG), whose main provisions enter into force on 1 November 2026. They name the authorities, set the fines and fix the language of some documents. For a company selling into Germany from Poland or any other member state, the passport stays the same. What changes is who can knock on the door and what has to be in German.

One EU passport, not a German one

A regulation is binding in its entirety and directly applicable in every member state, as Article 288 of the Treaty on the Functioning of the European Union puts it. The digital product passport sits in regulations, not directives:

• Regulation (EU) 2024/1781 (ESPR), the ecodesign framework that creates the passport for product groups covered by delegated acts.
• Regulation (EU) 2023/1542, the battery regulation, with the battery passport from 18 February 2027.
• Implementing Regulation (EU) 2026/1778 on the passport registry.

So "Digitaler Produktpass" in German search results means exactly the same passport as in Spain or Poland. We described the same mechanism for Poland in DPP in Poland: which rules apply. The difference is that Germany has already passed its national acts, which makes it a good preview of what other member states will add.

Batteries: the BattDG

The Batterierecht-Durchführungsgesetz of 30 September 2025 (BGBl. 2025 I No. 233) carries out the battery regulation in Germany and replaced the old Batteriegesetz (BattG) in October 2025. It does not rewrite the battery passport. Article 77 of the regulation still decides who needs one (LMT batteries, industrial batteries above 2 kWh and EV batteries, from 18 February 2027) and what goes into it (Annex XIII). The German act adds four things that matter for the passport.

• A fine for a bad passport. Section 60(2) point 29 BattDG makes it an administrative offence to fail to ensure, contrary to Article 77(4), that the information in the battery passport is accurate, complete and up to date. Under Section 60(3) that case falls in the residual category, with a fine of up to EUR 10,000.
• Market surveillance under the German market surveillance act. Section 2(3) BattDG applies the Marktüberwachungsgesetz where the act has no special rule, and Sections 49 to 51 route notifications about non-compliant batteries from the market surveillance authority to the Commission through the Federal Institute for Occupational Safety and Health (BAuA).
• The Federal Environment Agency for waste batteries. Section 30 makes the Umweltbundesamt the competent authority for Chapter VIII of the regulation, which is waste battery management and extended producer responsibility, not the passport itself.
• Registration with stiftung ear. Producers register before making batteries available in Germany, and since 1 January 2026 they must belong to an approved producer responsibility organisation for each battery category. This is a separate, national duty that the EU passport does not replace.

The QR code is the other date to remember. Article 13(6) of the battery regulation requires a QR code on all batteries from 18 February 2027, not only on those with a passport. We explained why these are two separate obligations in two battery obligations, only one is the passport.

Everything else: the new Ökodesign-Gesetz

For products under the ESPR, Germany adopted the Gesetz über die umweltgerechte Gestaltung von Produkten (Ökodesign-Gesetz, ÖkodesignG) as Article 1 of an act of 22 June 2026 (BGBl. 2026 I No. 191). Most of it enters into force on 1 November 2026, when it replaces the Energieverbrauchsrelevante-Produkte-Gesetz (EVPG) that implemented the old ecodesign directive.

According to the Federal Institute for Materials Research and Testing (BAM), the act names BAM as the commissioned body that coordinates the market surveillance authorities of the Länder, informs the public and forwards their notifications to the Commission. The inspections themselves stay with the authorities designated under the law of each Land. According to a law firm summary of the act, fines go up to EUR 100,000 for the most serious cases and up to EUR 10,000 otherwise.

What the ÖkodesignG cannot do is start a passport obligation. Under Article 9(1) of the ESPR a product needs a passport only once a delegated act for its product group says so. For textiles that act is expected around 2027, with the obligation realistically in 2028 to 2029. Iron and steel, furniture, tyres and others follow the Commission's working plan. A German act changes who enforces, not when.

What has to be in German

The passport itself has no language rule in Article 77 of the battery regulation. The documents around it do.

• Batteries. Section 48 BattDG: instructions and safety information under Article 38(1)(a) must be in German; contact details must be in German only where they are not written in Latin script; the signed EU declaration of conformity may be kept in German or English at the manufacturer's choice and translated into German on request. Distributors must check that the instructions and information are in German.
• ESPR products. Article 7(8) of the ESPR says that information supplied under information requirements must be in a language easily understood by customers, as determined by the member state. Article 7(2)(a) makes the passport part of those information requirements. In practice, plan for a German version of the customer-facing part of the passport when you sell in Germany.

A passport page that switches language is cheaper than a second passport. The data, the identifier and the code stay the same; only the labels and descriptions change.

Selling into Germany from another member state

• One passport for the whole Union. You do not create a German passport. The same identifier, the same code on the product and the same record serve every member state, and the Commission registry is shared.
• German authorities can check it. Market surveillance acts where the product is made available. A battery sold in Germany can be inspected by a German authority, and an inaccurate passport is a fine under German law, even if your company is in Poland.
• Translate the customer-facing layer. For batteries, the instructions and safety information in German are a legal requirement already. For ESPR products, expect the same for passport information.
• Register nationally where required. Battery producer registration with stiftung ear is separate from the passport and is not covered by registering in your home country.
• Check your deadline by category, not by country. Our industries and deadlines page keeps the certain and expected dates apart.

German groundwork you can use for free

Germany is also where a lot of the passport groundwork was done, and some of it is free:

• Battery Pass, a consortium funded by the Federal Ministry for Economic Affairs, published the Content Guidance for the battery passport in 2023. The follow-up project BatteryPass-Ready released a Data Attribute Longlist v2.0 and Data Model v2.0 on 27 August 2026.
• DIN DKE SPEC 99100, published in January 2025, sets out the data attributes of the battery passport and builds on the Battery Pass guidance. DIN Media offers it free of charge.
• Catena-X, the automotive data network, runs a digital product passport use case for exchanging passport data along the vehicle supply chain.

The European passport standards themselves, published in Germany as DIN EN, are sold by DIN Media like any other standard. We summarised what they cover in DPP standards explained.

What search results get wrong

• "Germany has its own Produktpass." No. It has national acts that enforce the EU passport.
• "The BattDG introduces the battery passport." No. The battery regulation does, from 18 February 2027. The BattDG adds the authorities, the registration and the fines.
• "From 1 November 2026 every product needs a passport in Germany." No. 1 November 2026 is when the ÖkodesignG enters into force. Passport obligations still come product group by product group, with the delegated acts.

FAQ

Łukasz Głuch

Builds DPPera, a digital product passport tool for small and medium-sized companies. Reads the delegated acts so you do not have to. Writes about what he checked in the registry, not about what vendors promise.

LinkedIn