The EU internal market is one of the largest and most efficient economic zones in the world. High product standards, consistent consumer protection, fair competition - this secures the prosperity of us all. The concept of the free movement of goods combined with the EU Declaration of Conformity is unique in the world and has worked well for years - as long as everyone plays by the rules.
The problem is that many no longer do.
Cheap products that simply ignore the applicable standards are flooding the market. The calculation is simple: ignoring compliance saves money, gives you an unfair competitive advantage - and ultimately puts consumers at risk. Only products that meet these high requirements are actually allowed on the market. And that also costs money.
Many have recognized the weaknesses of the system. There are simply too few gatekeepers - market surveillance and customs - and too many doors. Some platforms in the fast fashion and cheap import sector exploit this by deliberately overloading individual ports and airports. It's like being in a club: you look for the door with the weakest doorman, who can only check a fraction - one in a thousand - of the goods anyway.
The EU has recognized this. In the background, everything is being put in place to solve the problem in the long term. And here comes the crucial point: this will not only affect the supposedly bad guys. Everyone will have to go through the door in future.
Because in future, the bouncer will no longer stand in front of the door - he will stand behind it. The door itself will become the access control. The single window of customs is the door. The entry ticket is the Digital Product Pass.
And that doesn't just apply to importers. Regular visitors - the EU manufacturers - also have to show their entry ticket once. If you don't have a DPP, you can't get in.
The new Detergents Regulation (EU) 2026/405 shows us in black and white how this works in practice.
The ticket is called the Digital Product Pass
The new club rules are already written - in black and white, in the Official Journal of the European Union. The Detergents Regulation (EU) 2026/405, in force since March 22, 2026, is an example of how the digital turnstile works. Not as a declaration of intent, but as a finished set of rules with specific articles, clear deadlines and a binding deadline: September 23, 2029.
The entry ticket is the Digital Product Pass. What needs to be included - product identifier, manufacturer, ingredients, product code and proof of conformity - is set out in Annex VI. It is issued by the manufacturer before entry, not afterwards. And it must be entered in the register - the EU's central guest list, regulated in Article 24.
The door itself is the single window of European customs. Anyone wishing to pass through hands over their registration ID. The door automatically checks whether a valid entry exists. No entry, no release. Electronically, automatically, from September 23, 2029 - Article 25 paragraph 4.
And a detail that many people don't yet have on their radar: Until now, the choice of goods code has often been a tax decision. In future, it will also be a compliance decision - because Annex VII links the DPP obligation directly to the goods code. Anyone who declares incorrectly here will get stuck at the door.
The bouncer in the club
But the door is not the only check. Even those who are already in aren't safe yet.
There are also bouncers patrolling the inside of the club. That’s is market surveillance - regulated in Chapter VI, Article 26. Its job is different from that of the digital turnstile. The turnstile checks whether a ticket exists. Market surveillance checks whether the ticket is correct by comparing what is in the digital product passport with what is actually in the product.
And this is the crucial difference to the old system. In the past, the doormen had to search actively - spot checks, complaints, tips. Reactively. Today, they have access to the guest list. They can call up every entry, compare it with the product and intervene in the event of non-compliance - withdrawal, recall, market ban.
Incidentally, this applies to everyone. EU manufacturers who sell without a valid DPP are also committing a formal non-conformity under Article 29. The difference: in the case of imports, the turnstile stops the goods at the border. With EU manufacturers, the doorman in the club takes action.
And be careful: even regulars can be kicked out of the club.
The side door is connected to the main entrance
The detergent regulation is a side door. Not unimportant - but not the main entrance either. What is currently being installed here is the proof of concept: a digital turnstile, a register, an automatic connection to customs. Everything is ready for September 23, 2029, documented in a legal act that shows how it works.
What is being tested at the next door will soon arrive at the main entrance. The ESPR - the Ecodesign Regulation for Sustainable Products (EU) 2024/1781 - is rolling out the same system product group by product group. The Commission's work plan is concrete: iron and steel from 2026, textiles and tires from 2027, aluminum and furniture from 2028, mattresses from 2029. At the same time, sectoral legislation such as the Battery Regulation (EU) 2023/1542 will take effect - independently, but with the same infrastructure, the same register, the same single window.
And the legislator has openly named the connection. Recital 47 of the Detergents Regulation states: Detergents are to be transferred to the scope of the ESPR in the medium term. The side door will be connected to the main entrance.
One system. Many doors. And soon the same rule will apply to all of them: no ticket, no entry.
If you want to continue partying, you need a ticket
If you want to continue partying, you should get your ticket as soon as possible.
In concrete terms, this means putting the Digital Product Pass at the top of your agenda. Keep an eye on the ESPR and sectoral legislation. Understand which door will be retrofitted next - and be ready in good time.
Because the DPP will be the central market access issue in the coming years. Not one of many. The central one. Those who understand and act early will have a head start. Those who ignore it risk ending up in front of a closed door.
And if you're thinking: I'll just go and party somewhere else - be warned. Other clubs are also rewriting their rules. China is currently installing the same door - technically perhaps a little differentl, but the principle is the same: digital verification as a condition for market access.
The party goes on. But only with a ticket.
Would you like to find out more about the digital product passport? Then also read:
→ EU: Digital Product Passport ready for standardization, September 07, 2023
Support from Globalnorm
Globalnorm supports manufacturers and distributors in the classification of regulatory requirements, including for the introduction of the Digital Product Passport.
Author's note
This article has been machine translated into English.
