The back-up requirement

Is a back-up copy required by law?

Yes, product group by product group. The company that places a product on the market must make a back-up copy of its Digital Product Passport available through a digital product passport service provider (ESPR, Regulation (EU) 2024/1781, Article 10(4)). The rules for toys and detergents set the same duty (Regulation (EU) 2025/2509, Article 19(13); Regulation (EU) 2026/405, Article 21(12)(c)).

The aim is that the passport stays accessible even if the company goes insolvent, is liquidated or stops its activity in the EU (ESPR, Recital 38). The duty stays with the company; platforms and consultants can arrange the copy for their clients.

Which products need a back-up copy, and from when?

  • Detergents and end-user surfactants: from 23 September 2029 (Regulation (EU) 2026/405, Articles 21(12)(c) and 37)
  • Toys: from 1 August 2030 (Regulation (EU) 2025/2509, Articles 19(13) and 59)
  • Other product groups under the ESPR: once the act for the group requires a passport (ESPR, Articles 9(1) and 10(4))
  • Construction products: the acts under the Construction Products Regulation are to set up a back-up system by passport service providers (Regulation (EU) 2024/3110, Article 75(2)(f))
  • Batteries: a back-up copy is optional, and the battery passport must stay available after the company ceases to exist or stops its activity in the EU (Regulation (EU) 2023/1542, Article 78(e))

DPP Backup keeps a copy for every product group, required or optional.

Why must the back-up be independent?

The law defines a digital product passport service provider as an independent third party authorised by the company (ESPR, Article 2(32)). A copy kept by the company itself, or in the same place as the original, shares its risks. A copy kept apart, by an independent provider, stays available through changes to the company or its systems. DPP Backup acts as that provider for the back-up copy.

How long is the back-up kept?

For as long as the passport must stay available under the rules for its product group: for toys and detergents, 10 years after the product is placed on the market (Regulation (EU) 2025/2509, Article 19(2)(g); Regulation (EU) 2026/405, Article 21(2)(g)). Each passport is kept for the period set for it.

Using DPP Backup

What is DPP Backup?

A white-label service that keeps the independent back-up copy of Digital Product Passports. It works alongside the platform where your passports are created and published: it copies every published version, checks each copy against the original and keeps it for as long as the passport must stay available.

Passports are created and issued on your DPP platform, as they are today. DPP Backup keeps their back-up copy.

Who is DPP Backup for?

DPP platforms, integrators, compliance consultants and service providers that look after passports for their clients and want to offer the back-up copy too. Each client is a separate account with its own passports, back-ups and users, and all of them can be managed in one place.

Does it work with our DPP platform?

DPP Backup is built to work alongside any DPP platform. There are three ways to send passports, and you can mix them:

  • API integration: your platform sends each passport version as it is published
  • Structured file upload: passports are uploaded as JSON export files, for example in the EN 18223 format
  • Scheduled collection: DPP Backup reads new versions from your platform's EN 18222 API

The best route depends on the platform, and our team can advise on it.

What is copied?

The whole passport: its public and restricted data, with the access level of each field, its identifier and its attached documents. Every published version is kept exactly as received, with its date, next to the earlier ones.

How do we know the copy matches the original?

Each copy is stored with a checksum, a digital fingerprint of its content, and checked against the original when it is received. DPP Backup also checks the stored copies regularly, and the list of back-ups shows any passport whose copy is missing or out of date.

What happens if our DPP platform stops working?

The back-up copy is kept apart from your platform, so it stays intact. It can be made available in place of the original, so that people with a right to access the passport can still open it. Because the identifier is on the company's own domain, it can be pointed at the back-up copy and printed QR codes keep working.

What happens if the company stops trading?

That is what the back-up copy is for. The copy stays with DPP Backup, independent of the company, for the period agreed for each passport, so the passport stays available to the people who have a right to read it.

Is DPP Backup white-label?

Yes. DPP Backup works in the background, alongside your DPP platform. It copies the whole passport exactly as it is, and passports keep their identifiers, their QR codes and the company's own domain. Platforms and consultants can offer the back-up to their clients as part of their own service.

For toys and detergents, the rules also ask the passport to include the reference of the provider hosting its back-up copy.

Can we get our passports back from the back-up?

Yes. You can export every passport and every version at any time in open formats: JSON, with each passport also in the EN 18223 format. Use it to restore a passport on your platform, or to move to another provider.

Data and security

How is our data protected, and who owns it?

Back-ups are kept in European data centres, apart from the platforms where passports are created. Data is encrypted in transit and at rest, access is controlled by roles with two-factor sign-in, each client's data is kept strictly separate, and significant actions are recorded in an audit log.

The data is yours. DPP Backup keeps the copy on your behalf and uses it only to provide the back-up. Restricted data stays restricted: it is only made available to the people the rules for your product group allow.

Getting started

Contact us or email info@dppbackup.com and tell us which DPP platform you use. We set up your account, connect your passports, and the first back-ups are made.

Still have a question?

Send us a message and we'll get back to you by email.