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European Product Act (EPA) – Proposal for a New Framework Aligning Product Legislation with the Digital Era

Tilkal - The European Product Act (EPA) is a proposed legislative package resulting from the revision of the New Legislative Framework (NLF).

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European Product Act (EPA) – Proposal for a New Framework Aligning Product Legislation with the Digital Era
Photo by Donald Giannatti / Unsplash

[Updated May 13, 2026]

What. The European Product Act (EPA) is a proposed legislative package resulting from the revision of the New Legislative Framework (NLF). It aims to modernize EU product legislation by integrating digital tools, circular economy principles, and enhanced market surveillance to strengthen the Single Market in the digital age.
When. Expected adoption by the European Commission in the third quarter of 2026, following parallel revisions of the Standardization Regulation (EU 1025/2012), New Legislative Framework Regulation, and Market Surveillance Regulation.
Products. All products placed on the EU market, with a focus on harmonizing digital requirements, circularity, and compliance across sectors, including electronics, toys, construction, textiles, and consumer goods.
Who. Manufacturers, importers, distributors, online marketplaces, and economic operators placing products on the EU market.

Context: The New Legislative Framework (NLF) and Its Revision

The New Legislative Framework (NLF), adopted in 2008, serves as the foundation for EU product legislation, including directives and regulations such as the CE marking, conformity assessment procedures, and market surveillance rules. The NLF was designed to:

  • Improve the functioning of the Single Market for goods.
  • Strengthen market surveillance to ensure product safety and compliance.
  • Clarify the use of CE marking and harmonize conformity assessment processes.
  • Provide a toolbox of measures for sector-specific product legislation.

However, the NLF was developed before the rise of e-commerce, digitalization, and circular economy principles, creating gaps in addressing modern challenges such as:

  • The proliferation of online marketplaces and their role in product compliance.
  • The need for digital tools (e.g., Digital Product Passports) to enhance traceability and transparency.
  • The integration of sustainability and circularity into product design and lifecycle management.

The revision of the NLF is part of a broader effort to align EU product legislation with the European Green Deal, Circular Economy Action Plan, and Digital Decade Policy Programme. The European Product Act (EPA) will emerge from this revision, alongside updates to the Standardization Regulation and Market Surveillance Regulation, forming a cohesive legislative package.

Objectives of the European Product Act (EPA)

The EPA aims to reframe Single Market access by addressing key challenges in the digital and circular economy. Its primary objectives include:

1. Digital Transformation of Product Legislation

  • Introduce digital compliance tools, such as Digital Product Passports (DPP), to standardize and streamline product information.
  • Replace fragmented data carriers (e.g., multiple QR codes, labels) with a single EU QR code covering all regulatory requirements.
  • Enhance traceability and transparency across supply chains, supporting circular economy practices.

2. Strengthening the Circular Economy

3. Enhancing Market Surveillance and Enforcement

  • Establish a dedicated EU-level market surveillance authority to coordinate cross-border enforcement and address non-compliance in e-commerce.
  • Recognize online marketplaces as economic operators, making them co-liable for non-compliant products sold on their platforms.
  • Improve cooperation between national authorities to ensure consistent enforcement across the EU.

4. Simplifying Compliance for Businesses

  • Reduce administrative burdens by harmonizing digital requirements and standardizing compliance documentation.
  • Support innovation and competitiveness by providing clear rules for emerging technologies and business models.
  • Foster trust in the Single Market by ensuring high safety, sustainability, and quality standards for all products.

Key Proposals Under the European Product Act

The EPA is expected to introduce several transformative measures to modernize EU product legislation:

1. Single EU QR Code

  • Replace multiple data carriers (e.g., separate QR codes for CE marking, DPP, and other requirements) with a single, standardized EU QR code.
  • The QR code will link to a centralized digital platform containing all regulatory information, including:CE marking and Declaration of Performance (DoP).Digital Product Passport (DPP) data (e.g., material composition, sustainability metrics).Market surveillance and compliance documentation.

2. Digital Product Passport (DPP) Integration

  • The EPA will formalize the role of DPPs as a tool for material traceability, transparency, and circularity across all product sectors.
  • DPPs will become a mandatory requirement for products placed on the EU market, building on sector-specific implementations (e.g., CPR 2024/3110 for construction products, Batteries Regulation).
  • The EPA will define standardized data fields for DPPs, ensuring consistency and interoperability across sectors.

3. Online Marketplaces as Economic Operators

  • Online marketplaces (e.g., Amazon, eBay) will be recognized as economic operators under the EPA, making them co-liable for non-compliant products sold on their platforms.
  • Marketplaces will be required to:Verify the compliance of products before listing them.Remove non-compliant products from their platforms upon notification by authorities.Cooperate with market surveillance authorities to ensure enforcement.

4. EU-Level Market Surveillance Authority

  • A new EU-level authority will be established to:Coordinate cross-border market surveillance and enforcement actions.Address non-compliance in e-commerce, where products often bypass traditional regulatory checks.Support national authorities in conducting inspections, testing, and product recalls.

5. Alignment with International Standards

  • The EPA will align with international standards (e.g., ISO, IEC) to ensure global interoperability and reduce barriers to trade.
  • CEN and CENELEC, the European standardization organizations, will play a key role in developing harmonized standards for digital tools, circularity, and compliance.

The Digital Product Passport (DPP) is a central pillar of the EPA, serving as a digital tool for transparency, traceability, and circularity. The EPA will build on existing sector-specific DPP implementations (e.g., CPR 2024/3110, Batteries Regulation, ESPR) to create a unified framework for all products placed on the EU market.

Role of DPPs in the EPA

  • Standardization: The EPA will define mandatory data fields for DPPs, ensuring consistency across sectors. This includes:Product identification (e.g., unique identifier, manufacturer details).Sustainability information (e.g., carbon footprint, recyclability, material composition).Compliance documentation (e.g., CE marking, test reports, certificates).Lifecycle data (e.g., repair instructions, end-of-life management).
  • Interoperability: DPPs will be machine-readable and linked to the single EU QR code, enabling seamless access to product information for regulators, businesses, and consumers.
  • Circular Economy Support: DPPs will facilitate reuse, recycling, and material recovery by providing stakeholders with detailed information on product composition and end-of-life options.
  • Market Surveillance: DPPs will enhance traceability and enable authorities to quickly identify non-compliant products, reducing the risk of counterfeit or unsafe goods entering the market.

Synergies with Existing Regulations

The EPA will complement and reinforce sector-specific DPP requirements, such as:

  • Construction Products Regulation (CPR) 2024/3110: DPPs for construction materials, including sustainability and performance data.
  • Batteries Regulation: DPPs for batteries, covering material sourcing, carbon footprint, and recycling information.
  • Ecodesign for Sustainable Products Regulation (ESPR): DPPs for a wide range of consumer products, focusing on durability, reparability, and circularity.

By standardizing DPPs across sectors, the EPA will reduce fragmentation and create a cohesive digital ecosystem for product compliance and sustainability.

What’s at Stake for Businesses and Stakeholders?

The EPA represents a paradigm shift in EU product legislation, with significant implications for businesses, regulators, and consumers:

For Businesses

  • Compliance Costs: Companies will need to invest in digital tools (e.g., DPPs, QR codes) and supply chain transparency to meet new requirements.
  • Market Access: Non-compliance with the EPA could result in product bans, fines, or reputational damage, particularly for companies selling through online marketplaces.
  • Opportunities for Innovation: The EPA will create opportunities for businesses to differentiate themselves through sustainable and circular product design.
  • Supply Chain Resilience: Enhanced traceability and transparency will help businesses identify risks (e.g., forced labour, hazardous materials) and improve resilience.

For Online Marketplaces

  • Increased Liability: Marketplaces will be co-liable for non-compliant products, requiring robust compliance verification processes.
  • Operational Changes: Marketplaces will need to integrate digital tools (e.g., DPPs, QR codes) into their platforms and cooperate with authorities.

For Regulators and Authorities

  • Enhanced Enforcement: The EPA will provide regulators with new tools (e.g., DPPs, EU-level authority) to combat non-compliance and protect consumers.
  • Cross-Border Cooperation: The proposed EU-level market surveillance authority will improve coordination between national authorities, reducing fragmentation.

For Consumers

  • Greater Transparency: Consumers will have easy access to product information (e.g., sustainability, safety, compliance) via DPPs and QR codes.
  • Improved Safety and Sustainability: The EPA will ensure that products placed on the EU market meet high standards for safety, circularity, and environmental performance.

For the Single Market

  • Reduced Fragmentation: The EPA will harmonize digital requirements and compliance processes, reducing barriers to trade within the EU.
  • Global Competitiveness: By aligning with international standards and promoting innovation, the EPA will enhance the EU’s global leadership in sustainable and digital product regulation.

Next Steps and Timeline

The EPA is part of a broader legislative package that includes revisions to the Standardization Regulation and Market Surveillance Regulation. The timeline for adoption and implementation is as follows:

  • 2024–2025: Public consultation and impact assessment by the European Commission.
  • Q3 2026: Expected adoption of the EPA by the European Commission.
  • 2026–2027: Legislative process in the European Parliament and Council.
  • 2027–2028: Entry into force and phased implementation of the EPA, including DPP requirements.
  • 2028 onwards: Full applicability of the EPA, with ongoing reviews and updates based on feedback.

Businesses and stakeholders are encouraged to engage in the consultation process and prepare for the transition by:

  • Assessing current compliance processes and identifying gaps.
  • Investing in digital tools (e.g., DPPs, QR codes) and supply chain transparency.
  • Monitoring developments in standardization (e.g., CEN/CENELEC) and sector-specific regulations.

For More Information

For further details on the European Product Act (EPA) and its implications, consult the following resources:

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