Digital Product Passport for Food: What Applies in 2026

As of October 2026, there is no mandatory digital product passport for food. The EU regulation that creates product passports, the Ecodesign for Sustainable Products Regulation, explicitly excludes food and feed. When people talk about a "food product passport", they mean a voluntary, batch-level record of origin and handling that a buyer can open from a code on the pack.

That gap between the legal term and everyday use causes confusion. This guide explains what a digital product passport is, where it is actually required, how barcodes are changing at checkout, and what a food brand can sensibly do now.

What is a digital product passport?

A digital product passport (DPP) is a structured set of data about a specific product that can be opened electronically through a data carrier on the product, such as a QR code. In EU law, the concept comes from the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (ESPR). It lets the Commission set, product group by product group, what information must travel with a product: materials, repairability, recycled content, substances of concern, and similar sustainability data.

ESPR is a framework. It does not itself require a passport for anything. The detailed requirements come later, in delegated acts for each product group.

Does the digital product passport apply to food?

No. Article 1(2) of ESPR lists products the regulation does not apply to, and food and feed, as defined in the EU General Food Law Regulation (EC) No 178/2002, are on that list. So no ESPR delegated act can require a passport for a jar of honey or a bag of coffee.

That does not mean food has no data rules. Food is covered by its own body of law, including labelling, food safety and traceability rules. Food traceability in the EU rests on the "one step back, one step forward" duty in Article 18 of Regulation 178/2002, and coffee, cocoa and some other commodities are also covered by the EU Deforestation Regulation. Neither of these is a product passport, and neither requires a consumer-facing record.

What was the first mandatory digital product passport?

Batteries. The EU Batteries Regulation, Regulation (EU) 2023/1542, requires a battery passport for light means of transport batteries, electric vehicle batteries, and industrial batteries above 2 kWh. The European Commission's battery passport page describes batteries as "the first product group for which a DPP will become mandatory in the European Union", with the requirement applying from 18 February 2027 to relevant batteries placed on the EU market.

Batteries are a useful reference even for food brands, because they show what a mandatory passport looks like in practice: a unique identifier per item, a set of required data fields, a QR code on the product, and access rules about who sees what.

What does "product passport" mean in food?

In food, the term is used informally. Brands, platforms and consultants use "product passport" or "digital passport" for a record that follows a batch from source to shelf and can be opened by scanning the pack. Typical contents:

• Where the raw material came from: farmer or supplier, place, harvest date.
• Processing steps and dates.
• Who held the product at each stage.
• Supporting documents: lab reports, certificates, photos.

That is batch-level traceability with a public view. It is useful, and buyers increasingly ask for it, but it is not a legal DPP. If you describe your QR page as a "digital product passport", be clear that it is voluntary and not issued under ESPR or any certification scheme. Otherwise customers may read it as an official document.

Where do GS1 Digital Link and Sunrise 2027 fit?

These are about the barcode itself, not about passports.

GS1 Digital Link is a GS1 standard that puts a product's GS1 identifiers, such as its GTIN, into a web address, so a single QR code can work at the checkout and also open web content. GS1 US describes it as connecting a product's unique identity to online information that brands control. See our GS1 Digital Link glossary entry.

Sunrise 2027 is GS1's industry target for retail point-of-sale systems to scan 2D barcodes. According to GS1 US, the aim is for retailers to be able to read 2D codes, such as QR codes using GS1 Digital Link and GS1 DataMatrix, by the end of 2027. GS1 US advises brands to add 2D codes to existing packaging and to update existing QR codes to GS1 Digital Link with a GTIN. GS1 US also says the existing EAN/UPC barcode is not going away and will keep scanning after 2027. Sunrise 2027 is an industry initiative, not a law.

For food brands, the practical point is that one QR code may eventually do two jobs: price lookup at the till and opening product information. If your packaging uses a GTIN and you sell through large retailers, ask your GS1 member organisation how they expect 2D codes to be handled. A separate trace QR code, which is what most batch traceability tools print today, can sit alongside the retail barcode. IndiTrace's batch QR codes are of this kind. They are not GS1 Digital Link codes.

What can a food brand do about product passports today?

There is no deadline to meet, which means you can build the records at your own pace. A reasonable order:

1. Define your batches. Decide what one lot is (a day's production, one harvest, one blend) and give each a code that is printed on the pack.
2. Record the source of each batch. Supplier or farmer, place, dates, quantity, grade. This is the part buyers ask about most.
3. Record handovers. Each time the product changes hands, note who, when and how much.
4. Attach evidence. Lab results, certificates and photos, linked to the batch they belong to.
5. Give buyers a way to see it. A QR code that opens a web page for that batch, readable in any browser without an app or login.
6. Keep claims accurate. Say what is recorded and by whom. A record being tamper-evident, for example fingerprinted on a blockchain, shows it has not been edited since it was confirmed. It does not prove the facts in it.

IndiTrace supports steps 1 to 5: batch records, custody transfers, attached documents, and a public trace page per batch with a map of the route. It does not certify products or issue regulatory passports. The food brands page describes the setup, and the pricing page lists the plans, including a free starter pack.

If the EU or another market later creates a food-specific passport, the requirements will be set out in law with defined data fields. Brands that already keep clean batch records will be adapting an existing system rather than starting from nothing.

Questions

Q: Is there a digital product passport for food in the EU? No. As of October 2026, the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 excludes food and feed from its scope, so no mandatory food DPP exists under it.

Q: What is the first mandatory digital product passport? The EU battery passport under Regulation (EU) 2023/1542. The European Commission says it applies from 18 February 2027 to EV, light means of transport and industrial batteries above 2 kWh.

Q: Is GS1 Digital Link the same as a digital product passport? No. GS1 Digital Link is a standard for encoding product identifiers in a web address inside a barcode. A passport is the data behind it. A Digital Link code can point to passport data, but the two are separate things.

Q: What does Sunrise 2027 mean for food packaging? It is GS1's industry target for retail checkouts to scan 2D barcodes by the end of 2027. Brands are encouraged to add 2D codes, and the existing EAN/UPC barcode continues to scan.

Q: Can a food brand call its QR trace page a product passport? It can use the term informally, but it should say clearly that the page is voluntary and not issued under ESPR or any certification scheme.