ESPR Non-Compliance Penalties: Fines, Withdrawal, Import Bans

Why ESPR Penalties Should Be on Every Manufacturer’s Radar

The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, is not voluntary guidance. It is a binding EU regulation that establishes a framework for market surveillance and penalties in cases of non-compliance. It is important, however, to distinguish between what is already fixed in law and how individual Member States will prioritise inspections, organise procedures and apply penalties in practice. For battery categories covered by battery passport rules, the first binding requirement takes effect on 18 February 2027.

Yet many manufacturers, importers and distributors still treat DPP compliance as a future concern. This article explains what happens when businesses fail to meet their ESPR obligations and how to avoid costly penalties.

Legal Basis: Where ESPR Defines Penalties

The ESPR lays out its enforcement framework across several chapters (such as Chapter XI for Market surveillance and Chapter XIV for Final provisions):

Article	Subject	Key Provision
Art. 74	Penalties	Member States must lay down rules on penalties, including fines and temporary exclusion from public procurement; they must be effective, proportionate, and dissuasive
Art. 69	Safeguard procedure	Allows Member States to act against non-compliant products, including withdrawal and recall
Chapter XI	Market surveillance	Links to Regulation (EU) 2019/1020 on market surveillance and product compliance

Critical detail: National implementation

Unlike a directive, ESPR is a regulation that applies directly in all EU Member States. However, Article 74 leaves Member States to establish the detailed penalty rules. This means:

• Each Member State defines its own fine amounts, temporary procurement exclusions and enforcement procedures
• Penalties must be “effective, proportionate, and dissuasive” (the EU minimum standard)
• Member States must notify the European Commission of their penalty regimes
• Notification to the Commission does not create a single EU-wide fine schedule

This creates a patchwork where fines for the same violation can differ significantly between Germany, France, Spain, and other markets.

What Counts as Non-Compliance?

Non-compliance with ESPR covers a broad range of violations. It is important to understand that even partial non-compliance can trigger penalties and enforcement action.

1. Missing Digital Product Passport

The most obvious violation: placing a product on the EU market without the required DPP after the applicable deadline. This applies to:

• Products without the DPP data carrier required for the relevant product category
• Products with a data carrier that leads to an empty or non-functional DPP
• Products where the DPP data carrier is not accessible to end users

2. Incomplete or inaccurate DPP data

Even if a DPP exists, it can be non-compliant if:

• Required data fields are missing (as defined in the product-specific delegated act)
• Data is materially inaccurate: for example, carbon footprint values are wrong or the material composition is incorrect
• Data is outdated: the DPP must reflect the actual state of the product
• Data format doesn’t meet technical standards: the DPP must be machine-readable

3. Non-compliant data carrier

The physical data carrier must meet specific requirements, and its permitted location depends on the applicable product rule. Under the ESPR this does not automatically mean a QR code in every case: the regulation defines a data carrier more broadly as a linear barcode symbol, a two-dimensional symbol, or another automatic identification data capture medium readable by a device. The specific format is to be set by the applicable delegated act or sector-specific regulation.

• The carrier must be open and interoperable and carry a unique product identifier, as required by Articles 9 and 10 and Annex III of the ESPR. The specific format will follow from harmonised standards and the applicable delegated or sector-specific act. GS1 Digital Link is a common technical solution but is not named as the only mandatory URL format in the ESPR itself
• It must remain machine-readable and durable throughout the product’s lifecycle
• It must lead to an accessible and functional DPP
• It must be placed in a visible location on the product, its packaging or documentation accompanying the product, as required by Article 10 of the ESPR and the applicable delegated act

The clearest exception today is batteries: Regulation (EU) 2023/1542 expressly requires a QR code. From 18 February 2027, all batteries must be marked with a QR code and, for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries, that QR code must provide access to the battery passport.

4. Failure to update DPP information

DPP data is not static. Manufacturers must update their DPPs when:

• Product composition changes
• Sustainability certifications are renewed or revoked
• Repair information or spare parts availability changes
• Any information that affects compliance becomes outdated

5. Obstruction of market surveillance

Refusing or failing to cooperate with market surveillance authorities, such as by withholding requested documentation or access to DPP data, is a separate offence with its own penalties.

Types of Sanctions

ESPR enforcement goes far beyond monetary fines. The regulation and the related Market Surveillance Regulation (EU) 2019/1020 establish a graduated system of sanctions:

Financial penalties

Financial penalties are the most direct consequence. The ESPR does not set a single EU-wide fine schedule. It requires Member States to establish penalties that are effective, proportionate and dissuasive. A reliable current assessment therefore needs to examine the first national regimes implementing sector-specific obligations, especially those for batteries, rather than present a hypothetical EU table.

Current evidence status

DPP penalty tracker by scope

As of 19 July 2026, the table distinguishes direct sanctions for a missing battery passport from penalties for data quality, marking and QR codes, as well as draft legislation.

Active table

Scope

Batteries Confirmed country examples General ESPR Framework duty, no fine table yet Other DPP sectors Sector rules emerging

The scope of sanctions differs between countries, and not every battery penalty concerns a missing passport itself.

The passport obligation for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries starts on 18 February 2027. The deadline for Member States to establish national penalties expired earlier, on 18 August 2025.

Croatia

Direct DPP sanction

Narodne novine 152/2024

Legal basis

Article 17 of the Battery Regulation implementation act

Consequence

A legal person may be fined from EUR 3,000 to EUR 30,000 for a missing passport, missing required information, defective QR access, incorrect linkage to an identifier, inaccurate, incomplete or outdated data, or failure to ensure required interoperability. Separate amounts apply to responsible persons and individuals acting in a business capacity.

Belgium

Direct DPP sanction

Act of 3 May 2024

Legal basis

Act of 21 December 1998 linked to the Act of 3 May 2024

Consequence

The national penalty regime covers Article 77, except paragraph 9, and Article 78 of the Battery Regulation. The base fine is EUR 52 to EUR 120,000. With the current multiplier of 10, this corresponds to EUR 520 to EUR 1,200,000. The multiplier should be checked against the law in force on the date of the infringement.

France

Direct DPP sanction

Decree No 2025-992

Legal basis

Decree No 2025-992 and the Consumer Code

Consequence

For products intended for consumers, infringement of Articles 77 and 78 is a fifth class offence. The maximum fine is EUR 1,500 for a natural person and EUR 7,500 for a legal person.

Germany

Data quality sanction

BattDG §60(2)(29)

Legal basis

BattDG §60(2)(29) linked to Battery Regulation Article 77(4)

Consequence

A fine of up to EUR 10,000 applies to failure to ensure that passport information is accurate, complete and up to date. This provision does not establish a direct penalty for every case of a missing passport.

Italy

Marking and QR sanction

Article 34

Legal basis

Decreto legislativo 10 febbraio 2026, n. 29

Consequence

Article 34 sets EUR 10,000 to EUR 150,000 for specified marking infringements. From 18 February 2027, the range also covers the QR code requirements in Article 13(6) and (7). It does not directly penalise the absence of a passport under Article 77(1).

Czechia

Draft

Bill No 58

Legal basis

Draft act, parliamentary bill No 58

Consequence

The bill proposes a fine up to CZK 5,000,000, including for placing a battery on the market without the required passport. The amount is not in force because parliamentary work is still ongoing.

Sweden

Framework adopted, DPP sanction proposed

Memorandum KN2026/01561

Legal basis

SFS 2025:813 and memorandum KN2026/01561

Consequence

The adopted provisions complement the Battery Regulation but do not establish a direct battery passport fine. A memorandum published on 16 July 2026 proposes a new system of environmental penalty charges that would also cover ESPR. It remains a draft.

Netherlands

Implementation in progress

Kamerstuk 36880-3

Legal basis

Battery Regulation implementation bill

Consequence

The bill broadens the basis in the Environmental Management Act so that battery rules can also cover product safety and health, with enforcement by ILT and NVWA. It establishes the need for sanctions but does not yet specify an amount for a DPP infringement.

Poland

Draft legislation in progress

UC107

Legal basis

Draft act on batteries and waste batteries

Consequence

UC107 would set the supervisory authority, conformity assessment framework and sanctions for breaches of the Battery Regulation. The public project card does not state a specific amount for a missing or defective DPP. Adoption by the Council of Ministers is planned for the third quarter of 2026.

Country examples for battery passport enforcement

Country	Status	Legal basis	Consequence	Official source
Croatia	Direct DPP sanction	Article 17 of the Battery Regulation implementation act	A legal person may be fined from EUR 3,000 to EUR 30,000 for a missing passport, missing required information, defective QR access, incorrect linkage to an identifier, inaccurate, incomplete or outdated data, or failure to ensure required interoperability. Separate amounts apply to responsible persons and individuals acting in a business capacity.	Narodne novine 152/2024
Belgium	Direct DPP sanction	Act of 21 December 1998 linked to the Act of 3 May 2024	The national penalty regime covers Article 77, except paragraph 9, and Article 78 of the Battery Regulation. The base fine is EUR 52 to EUR 120,000. With the current multiplier of 10, this corresponds to EUR 520 to EUR 1,200,000. The multiplier should be checked against the law in force on the date of the infringement.	Act of 3 May 2024
France	Direct DPP sanction	Decree No 2025-992 and the Consumer Code	For products intended for consumers, infringement of Articles 77 and 78 is a fifth class offence. The maximum fine is EUR 1,500 for a natural person and EUR 7,500 for a legal person.	Decree No 2025-992
Germany	Data quality sanction	BattDG §60(2)(29) linked to Battery Regulation Article 77(4)	A fine of up to EUR 10,000 applies to failure to ensure that passport information is accurate, complete and up to date. This provision does not establish a direct penalty for every case of a missing passport.	BattDG §60(2)(29)
Italy	Marking and QR sanction	Decreto legislativo 10 febbraio 2026, n. 29	Article 34 sets EUR 10,000 to EUR 150,000 for specified marking infringements. From 18 February 2027, the range also covers the QR code requirements in Article 13(6) and (7). It does not directly penalise the absence of a passport under Article 77(1).	Article 34
Czechia	Draft	Draft act, parliamentary bill No 58	The bill proposes a fine up to CZK 5,000,000, including for placing a battery on the market without the required passport. The amount is not in force because parliamentary work is still ongoing.	Bill No 58
Sweden	Framework adopted, DPP sanction proposed	SFS 2025:813 and memorandum KN2026/01561	The adopted provisions complement the Battery Regulation but do not establish a direct battery passport fine. A memorandum published on 16 July 2026 proposes a new system of environmental penalty charges that would also cover ESPR. It remains a draft.	Memorandum KN2026/01561
Netherlands	Implementation in progress	Battery Regulation implementation bill	The bill broadens the basis in the Environmental Management Act so that battery rules can also cover product safety and health, with enforcement by ILT and NVWA. It establishes the need for sanctions but does not yet specify an amount for a DPP infringement.	Kamerstuk 36880-3
Poland	Draft legislation in progress	Draft act on batteries and waste batteries	UC107 would set the supervisory authority, conformity assessment framework and sanctions for breaches of the Battery Regulation. The public project card does not state a specific amount for a missing or defective DPP. Adoption by the Council of Ministers is planned for the third quarter of 2026.	UC107

General ESPR penalties are a Member State legal duty.

ESPR Article 74 requires Member States to set effective, proportionate and dissuasive penalties. Specific amounts depend on national implementation and the applicable product sector.

Other DPP sectors are tracked as regulatory context for now.

Detergents (Regulation (EU) 2026/405, DPP from 23 September 2029) and toys (Toy Safety Regulation (EU) 2025/2509, DPP from 1 August 2030) are now adopted standalone DPP regimes, and further ESPR delegated acts are coming. This view still avoids listing fine amounts where official national penalty rules are not yet specific enough.

Product withdrawal from the market

Under Article 69 of the ESPR, a market surveillance authority generally first requires the economic operator to correct the non-compliance within an appropriate period. If corrective action is not taken or the non-compliance persists, the authority may restrict or prohibit the product, withdraw it from the market or recall it from users.

In practice, this may require removal from sales channels, a pause in selling existing stock and deletion of online offers. Faster action is possible where the nature of the risk or sector rules require it. Dangerous products may also be notified through the EU Safety Gate, which is not a general register of DPP non-compliance.

Import bans

Customs authorities at the external borders of the EU participate in controls of products subject to an applicable DPP requirement. If a control raises a suspicion of non-compliance, release for free circulation may be suspended and the case may be referred to the competent market surveillance authority. Following its assessment, the authority may allow release, require corrective action or impose a restriction, prohibition, withdrawal or recall.

The start date of a passport requirement does not create an automatic block on every shipment without a DPP. The scope of controls will depend on the relevant sector regime, connections to the DPP Registry, risk analysis and national practice. Return or destruction of goods requires an appropriate legal basis and satisfaction of the conditions in the applicable rules.

Commission Implementing Regulation (EU) 2026/1778 now defines the Registry’s data structure and verification mechanisms. However, its connection to the EU Single Window Environment for Customs and product-specific enforcement procedures are still being developed. The practical scope of controls will therefore continue to depend on the sector and Member State.

This is particularly relevant for importers sourcing from non-EU manufacturers who may not yet be familiar with DPP requirements.

Public disclosure and reputational harm

The ESPR and Market Surveillance Regulation provide for public disclosure of non-compliance:

• Unsafe products may be notified in EU Safety Gate; other compliance findings may be disclosed through national decisions, notices or reports
• Market surveillance authorities publish annual reports describing areas in which non-compliance has been found
• Major non-compliance cases may receive media coverage and damage brand reputation
• B2B customers increasingly check compliance status before signing supply contracts

Supply chain liability

ESPR creates a chain of responsibility across the supply chain:

• Manufacturers bear primary liability for creating and maintaining the DPP
• Importers are liable if they place non-compliant products on the EU market
• Distributors face penalties if they sell products they know, or should know, lack a compliant DPP
• Online marketplaces, under the Digital Services Act (Reg. (EU) 2022/2065), the General Product Safety Regulation (Reg. (EU) 2023/988) and the Market Surveillance Regulation (Reg. (EU) 2019/1020), must cooperate with authorities and can be required to remove listings for products that breach applicable DPP obligations
• Authorised representatives can be held liable for products they represent

Who Enforces DPP Requirements?

Market Surveillance Authorities (MSAs)

Each EU Member State designates one or more Market Surveillance Authorities responsible for enforcing product requirements. In practice, competence is sector-specific: product safety, chemicals, batteries, electronics, packaging and online sales can involve different authorities. The examples below are starting points and sector bodies, not a complete list of every competent authority in the EU:

Country	Authority	Focus
🇩🇪 Germany	BAuA (Bundesanstalt für Arbeitsschutz und Arbeitsmedizin) + Länder authorities	Federal coordination + regional enforcement
🇫🇷 France	DGCCRF (Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes)	Consumer protection and product compliance
🇪🇸 Spain	Ministerio de Consumo + Regional authorities	Coordinated national approach
🇵🇱 Poland	UOKiK (Urząd Ochrony Konkurencji i Konsumentów) + Trade Inspection	Market surveillance and competition
🇮🇹 Italy	MIMIT + sector authorities	Product safety, CE marking and sector enforcement
🇳🇱 Netherlands	NVWA + ILT + sector authorities	Consumer products, environmental requirements and sector checks
🇸🇪 Sweden	Swedac / Market Surveillance Council + sector authorities	National coordination and enforcement by specialised agencies
🇫🇮 Finland	Tukes (Turvallisuus- ja kemikaalivirasto)	Safety and chemicals agency

Authorities also use EU cooperation tools such as ICSMS, which allows market surveillance bodies in EU and EFTA countries to exchange information about non-compliant products.

Customs authorities

At the external borders of the EU, customs authorities participate in controls of imported goods. DPP verification will apply to the extent provided by the relevant sector rules and the developing connection between the DPP Registry and the EU Single Window Environment for Customs.

European Commission oversight

The European Commission monitors enforcement across Member States and can:

• Initiate infringement proceedings against states that don’t enforce properly
• Issue standardisation requests to CEN, CENELEC and ETSI and publish references to harmonised standards in the Official Journal. The technical text of those standards is drafted and published by the European Standardisation Organisations, not by the Commission
• Coordinate EU-wide enforcement campaigns targeting specific product categories
• Maintain the EU Digital Product Passport Registry. Commission Implementing Regulation (EU) 2026/1778 sets its operating rules, while the production Registry, separate testing environment and Economic Operators User Guide became available on 20 July 2026. This does not mean every product can already be registered or enforced: the guide says successful DPP registration is currently unavailable because the battery semantic catalogue is not yet defined. The act also covers batteries, construction products, toys, detergents and other Union laws that use the Registry, not only the first application involving batteries

Looking ahead: the market-surveillance rules underpinning this enforcement are also due for an update. The Commission has announced a European Product Act, with a proposal expected in Q3 2026, to modernise product market surveillance, including digital and cross-border sales. Structured DPP records could provide machine-readable evidence within that framework. See European Product Act: stronger DPP enforcement.

How Enforcement Works in Practice

At this stage, some caution is necessary: the broad outline of enforcement is already visible in the legal framework, but the exact inspection sequence will still depend on the product category, national procedure, implementing measures and market-surveillance practice. The outline below shows a likely sequence, not a single fully harmonised process already operating identically across the EU.

Step 1: Market surveillance inspection

MSAs may carry out proactive inspections and may also react to complaints, customs checks, or sector-specific control campaigns. In practice, inspections can include both physical checks (in stores or warehouses) and digital reviews (such as online listings). Where a DPP and data carrier are already required for a category, authorities will typically verify:

• Does the product have a data carrier?
• Does the QR code resolve to a valid DPP?
• Is the DPP data complete and accurate?
• Does the data match the physical product?

Step 2: Notification of non-compliance

If a violation is found, the MSA may issue a formal notification or corrective-action request to the economic operator. The exact form depends on national procedure, but it often includes:

• Description of the violation
• Deadline for corrective action (often somewhere between several days and several weeks, depending on the national procedure)
• Warning that the case may escalate if the issue is not resolved

Step 3: Corrective measures

The manufacturer or importer will typically need to:

• Fix the DPP (add missing data, correct inaccuracies)
• Provide evidence of compliance to the MSA
• Recall or update affected products if already sold
• Document corrective actions for future audits

Step 4: Penalties for unresolved non-compliance

If corrective measures are not taken within the deadline, or if the authority considers the breach serious, the following measures may be taken:

• Formal imposition of a fine
• Market withdrawal orders
• Publication of the non-compliance in official registers
• In severe cases, criminal prosecution (in Member States that classify certain violations as criminal offences)

The Battery Regulation: A Practical Example of ESPR Enforcement

The Battery Regulation (EU) 2023/1542 is currently the clearest practical reference point for how DPP enforcement may develop within the broader ESPR framework. The battery passport becomes mandatory from 18 February 2027 for categories covered by that regulation. This does not mean that enforcement practice will later be identical across every ESPR sector.

Key enforcement provisions specific to batteries:

• Battery categories covered by the battery passport rules will need to have a passport in line with Regulation (EU) 2023/1542
• From 18 February 2027, all batteries must be marked with a QR code; for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries, the QR code must lead to the battery passport
• The DPP must include state-of-health data, a carbon footprint declaration and information on recycled content
• The economic operator placing the battery on the market must ensure that the battery passport information is accurate, complete and up to date
• Member States are required to define penalties for non-compliant batteries in national implementing legislation
• Croatia, Belgium and France have adopted direct sanctions for a missing battery passport. Germany penalises data quality, while Italy penalises specified marking and QR code infringements. In Czechia, a sanction for a missing passport remains a draft

This is no longer just a theoretical discussion: manufacturers within the scope of the battery passport should expect actual supervision and enforcement once the obligation applies, even if the intensity and sequence of measures vary by national practice.

Two recent changes to the battery timeline

Two developments since this regime was first drafted change when parts of it take effect:

• Supply-chain due diligence was postponed to 18 August 2027. Regulation (EU) 2025/1561 moved the Article 48 due diligence obligations concerning the responsible sourcing of cobalt, lithium, natural graphite and nickel from 18 August 2025 to 18 August 2027. The Commission’s guidelines are now due by 26 July 2026, and reports will be submitted every three years. This matters for penalties: the highest national caps, including Germany’s EUR 500,000 ceiling, apply to failures relating to audits, strategy approval and due diligence. Those penalties can therefore be imposed only once the underlying duties apply. The passport deadline under Article 77 remains 18 February 2027. See Battery due diligence delayed to 18 August 2027.
• An act on access rights is due by 18 August 2026. By that date the Commission must specify who counts as a person with a legitimate interest and what battery-passport data that person may access (Article 77 and Annex XIII). The next battery labelling requirements also take effect on that date. These are the main milestones before the passport applies on 18 February 2027.

Cross-Border Enforcement: EU Coordination

One of the most powerful aspects of ESPR enforcement is the EU-wide coordination mechanism:

The Union procedure for cross-border non-compliance

If an authority considers that non-compliance is not limited to the territory of one Member State, it informs the Commission and the other Member States of the assessment and the required corrective action. The economic operator must take appropriate action for all affected products it has made available across the Union.

A national measure does not automatically become an identical decision in all 27 Member States. The information is communicated through the Union procedure. If the measure is considered justified, the other Member States take appropriate action in their markets. Safety Gate applies to dangerous products, not to every formal DPP non-compliance.

Joint enforcement actions

The European Commission can coordinate joint actions in which MSAs from multiple Member States simultaneously check compliance in a specific product category. These coordinated checks have been effective in other product-safety areas and provide a useful indication of how DPP enforcement practice may develop.

Financial Impact: Beyond Fines

The true cost of ESPR non-compliance extends far beyond the monetary fines:

Direct costs

• Fines and administrative penalties: ranging from thousands to hundreds of thousands of euros
• Product withdrawal costs: logistics of removing products from shelves and warehouses
• Inventory write-offs: stock that cannot be sold during the period of non-compliance
• Legal fees: for contesting or managing penalty proceedings

Indirect costs

• Lost revenue: inability to sell products during the withdrawal period
• Customer contract penalties: B2B customers may invoke penalty clauses for non-compliant deliveries
• Insurance implications: product liability insurance may not cover regulatory non-compliance
• Tender exclusions: public procurement increasingly requires ESPR compliance proof

Reputational costs

• Brand damage: public listing as a non-compliant company
• Customer trust erosion: especially among sustainability-conscious consumers
• Investor concerns: ESG ratings may be affected
• Supply chain exclusion: large retailers may remove non-compliant suppliers

How to Avoid ESPR Penalties: Compliance Checklist

The good news: ESPR compliance is achievable, especially with early preparation. Follow this checklist:

Immediate actions (start now)

1. Identify your product categories: determine which delegated acts apply to your products
2. Check your deadlines: batteries have a fixed February 2027 passport date; future ESPR categories depend on delegated acts and the Commission work plan
3. Set product identifiers: GTINs are often useful, but the mandatory identifier level and format will come from the applicable delegated or sector-specific act
4. Audit your product data: inventory what sustainability, composition, and lifecycle data you already have
5. Choose a DPP platform: select a tool that generates compliant DPPs with proper data carriers

Before your deadline

6. Create DPPs at the required level: ensure the relevant model, batch or item has a complete passport where the applicable act requires it
7. Generate and apply the right data carrier: for batteries this means a QR code; for future ESPR categories, check the format specified in the delegated or sector-specific act
8. Verify data completeness: cross-check your DPP data against the applicable delegated act requirements
9. Test the end-to-end flow: scan your QR codes and verify the DPP is accessible and accurate
10. Train your team: ensure procurement, production, and quality teams understand DPP obligations

Ongoing compliance

11. Update DPPs when products change: new materials, new certifications, new suppliers
12. Monitor regulatory updates: delegated acts may be amended with new requirements
13. Respond to MSA requests promptly: delays in providing information escalate penalties
14. Maintain an audit trail: document all DPP creation, updates and compliance activities

Don’t Wait for Enforcement to Start

You do not need perfect visibility on every future inspection detail to prepare sensibly. The direction is clear: as sector-specific obligations take effect, authorities will expect accessible product data, a functioning data carrier, and the ability to demonstrate compliance. The earlier you structure identifiers, product data, and audit trails, the lower the risk of a last-minute scramble when enforcement becomes more active.

Official Sources

• ESPR Regulation (EU) 2024/1781
• Market Surveillance Regulation (EU) 2019/1020
• Battery Regulation (EU) 2023/1542
• Regulation (EU) 2025/1561: postponement of battery due diligence to 18 August 2027
• Croatia: Battery Regulation implementation act, Article 17
• Belgium: Act of 3 May 2024
• Belgium: Act of 21 December 1998
• Belgium: Current fine multiplier
• France: Decree No 2025 992
• France: Penalty for infringement of implementing provisions
• Germany: BattDG penalty provisions
• Italy: Decreto legislativo 10 febbraio 2026, n. 29, Article 34
• Czechia: legislative history of bill No 58
• Sweden: adopted complementary provisions SFS 2025:813
• Sweden: memorandum KN2026/01561
• Netherlands: Battery Regulation implementation bill
• Poland: draft UC107
• Ecodesign / Green Forum implementation updates
• European Commission: ICSMS and market-surveillance cooperation
• Commission Implementing Regulation (EU) 2026/1778: DPP Registry
• European Commission: DPP Registry
• Italy: MIMIT, consumer product safety
• Netherlands: NVWA, product safety
• Sweden: Market Surveillance Council and sector authorities

The cost of compliance today is a fraction of the future cost of non-compliance. With self-service platforms like OriginPass, generating DPPs for your products takes minutes, not months.

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Not sure where to start? Read our step-by-step guide to creating a DPP, from product identifiers to data carriers.

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