For years, European product compliance has rested largely on declarations: a manufacturer stated that a product met the rules, and that statement was usually accepted until someone had reason to question it. That model is ending. Europe is moving from declared compliance to demonstrated compliance, where every claim about a product must be supported by documentation that can be produced, examined and verified.

Three regulatory fronts now converge on the same demand: product data backed by evidence that can be checked. Packaging, batteries and, more broadly, the products covered by the Digital Product Passport framework all require companies to hold structured, traceable and durable records rather than one-off statements.

Packaging: the PPWR already applies

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied since 12 August 2026. Under Article 15, manufacturers must, for each packaging type:

  • carry out a conformity assessment under Article 38;
  • draw up the technical documentation set out in Annex VII;
  • issue an EU Declaration of Conformity under Article 39.

These documents must be kept for 5 years for single-use packaging and 10 years for reusable packaging. Under Article 16, suppliers of packaging and packaging materials must provide manufacturers with the information needed to demonstrate conformity, which means the evidence chain extends upstream.

Several substantive requirements are already in force: the minimisation of substances of concern, the 100 mg/kg combined limit for lead, cadmium, mercury and hexavalent chromium, and limits on PFAS in food-contact packaging. Later phases will add harmonised labels from 2028 and recyclability performance grades and recycled content targets from 2030. Each of these will require data that can be traced to its source.

Batteries: the passport from 18 February 2027

Under Article 77 of the Batteries Regulation, Regulation (EU) 2023/1542, from 18 February 2027 every electric vehicle battery, every light means of transport (LMT) battery and every industrial battery with a capacity above 2 kWh placed on the EU market must have a battery passport, accessible through a QR code. The passport must include:

  • general information on the battery and its manufacturer;
  • the carbon footprint;
  • the recycled content of cobalt, lead, lithium and nickel;
  • the due diligence report on raw material sourcing;
  • the battery's material composition;
  • information on state of health and expected lifetime.

Responsibility is clear: the economic operator placing the battery on the market owns the passport data and must keep it accurate and up to date throughout the battery's life.

Textiles: the passport is being prepared now

The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (ESPR), sets the general framework for the Digital Product Passport in Articles 9 to 15. Article 13 requires the Commission to set up the EU DPP registry by 19 July 2026. Passports linked to that registry will become the standard way to show what a product is made of and how it should be handled at end of life.

The same regulation already applies to apparel. Since 19 July 2026, large companies can no longer destroy unsold apparel and footwear (Article 25). They must also disclose the unsold consumer products they discard and the reasons (Article 24). Disposal decisions are now a matter of public record.

Textiles are a priority product group in the ESPR Working Plan 2025-2030, and the delegated act setting their requirements is in preparation. The data it will call for is already clear:

  • fibre composition;
  • recycled content;
  • substances of concern;
  • repair and recycling information;
  • supply-chain data.

The delegated act will set the date when the obligation applies. Products, however, are designed long before that date. Brands designing collections today are fixing that data today, whether or not they record it.

What to do now

Three practical steps apply across packaging, batteries and textiles:

  • Map your products and packaging. List what you place on the EU market and identify which regime applies to each item.
  • Build the evidence file as you produce. Collect supplier data at source, when it is generated. Do not try to reconstruct it later, when suppliers have changed and records are incomplete.
  • Keep the record alive. These duties run for years: 5 to 10 years for packaging technical documentation, and the whole life of the battery for the battery passport. The file must stay accurate, accessible and up to date for that entire period.

This is the work Ledger Consortium does. We provide an Italian, governed digital-evidence infrastructure that brings company and supplier data together in one place. That data is anchored on a governed distributed ledger, so every record carries a verifiable date and origin. We also manage regulatory updates over time, so the evidence keeps pace with the rules. In Italy, the service is distributed with Il Sole 24 Ore through Valore24. To see how it works in practice, see the demo, or browse more news and guides.