Brazil and ESPR: Digital Product Passport Requirements for Brazil Exporters to the EU

ESPR Regulation (EU) 2024/1781 applies to all products placed on the EU market, regardless of where they are manufactured. Brazil exporters in Agricultural products and food, Mining and metals, Textiles and other sectors must comply with ESPR Digital Product Passport requirements before their products can enter the EU market after the applicable compliance dates. This page covers what Brazil manufacturers and exporters need to know about ESPR compliance.

Brazil's Export Profile and ESPR Exposure

Brazil exports to the EU include products across multiple ESPR-regulated categories. The key sectors affected are:

• Agricultural products and food
• Mining and metals
• Textiles
• Chemicals
• Furniture

The EU is a major export destination for Brazil manufacturers. ESPR compliance is not optional for products destined for the EU market — it is a legal requirement that will be enforced at EU customs from 19 July 2026 for general DPP compliance, and from 18 February 2027 for the Battery Passport specifically.

ESPR Compliance Requirements for Brazil Manufacturers

Brazil manufacturers exporting to the EU must complete four steps before their products can legally enter the EU market after the applicable ESPR compliance dates. First, they must appoint an EU Authorised Representative — a natural or legal person established in the EU who is responsible for DPP registration, the EU Declaration of Conformity, and communication with EU market surveillance authorities. Second, they must compile technical documentation for each product model, demonstrating compliance with the applicable ecodesign requirements. Third, they must create a Digital Product Passport for each product model (or individual unit, where required) and register it with a compliant DPP registry. Fourth, they must affix a QR code data carrier to each product or its packaging, linking to the DPP record.

Key ESPR Deadlines for Brazil Exporters

EU Authorised Representative: What Brazil Manufacturers Need

Under ESPR Article 16, non-EU manufacturers must appoint an EU Authorised Representative before placing products on the EU market. The Authorised Representative must be a natural or legal person established in an EU member state. They are responsible for ensuring the DPP is registered, the EU Declaration of Conformity is drawn up, the technical documentation is compiled, and the CE marking is correctly affixed. The Authorised Representative must be named in the EU Declaration of Conformity and their contact details must be accessible via the DPP.

The Authorised Representative does not need to be the importer or distributor — they can be a specialist compliance service provider. Many Brazil manufacturers use EU-based compliance consultancies as their Authorised Representative. The cost of an Authorised Representative service typically ranges from €1,000–€5,000 per year depending on the number of product models and the complexity of the compliance requirements.

Digital Product Passport Registration for Brazil Exporters

Once the technical documentation is complete and the EU Declaration of Conformity is drawn up, Brazil manufacturers must register their products' Digital Product Passports with a compliant DPP registry. The registry assigns a unique DPP identifier to each product model (or unit, where required) and generates the GS1 Digital Link URL that is encoded in the product's QR code. The DPP data must be kept accurate and up-to-date throughout the product's lifetime — including updates to State of Health data for batteries and updates to spare parts availability for electronics.

Africa's first ESPR-compliant DPP registry — digitalproductpassports.co.za — is available to Brazil manufacturers and exporters. The registry supports all ESPR product categories and provides GS1 Digital Link-compliant QR code generation, JSON-LD data hosting, and EU Declaration of Conformity document management.

Brazil's ESPR Exposure: Mining, Agriculture, and Chemicals

Brazil is a major exporter of iron ore, steel, aluminium, and agricultural commodities to the EU. The iron and steel delegated act and aluminium delegated act will directly affect Brazilian steel and aluminium producers. Brazil is also subject to the EU Deforestation Regulation (EUDR), which requires supply chain due diligence for commodities linked to deforestation — including soy, beef, and timber. The ESPR furniture delegated act will require Brazilian furniture manufacturers to provide wood species identification and FSC/PEFC certification.

Brazil's ESPR Exposure: Agricultural Products, Mining, and Packaging

Brazil's ESPR exposure is primarily in agricultural products (soy, coffee, beef, sugar, orange juice) and mining (iron ore, bauxite, lithium). Agricultural products are generally not directly subject to ESPR, but they may be affected by ESPR packaging requirements — the packaging used for Brazilian agricultural exports to the EU will need to comply with ESPR packaging requirements. Brazil's mining sector is significant for ESPR supply chain requirements — Brazilian iron ore is used in EU steel production, and Brazilian lithium is used in EV batteries.

Brazil is a significant producer of lithium, with major deposits in Minas Gerais state. Brazilian lithium producers who supply to battery manufacturers exporting to the EU must be prepared to provide supply chain due diligence documentation that meets the Battery Regulation's requirements. The Responsible Lithium Initiative provides a supply chain due diligence framework that Brazilian lithium producers can use.

Brazilian Steel and ESPR

Brazil is a major producer of steel, with companies including Gerdau, CSN, and Usiminas exporting steel to the EU. The ESPR iron and steel delegated act (expected 2026-2027) will set requirements for recycled content, carbon footprint, and the Digital Product Passport for steel products placed on the EU market. Brazilian steel manufacturers should monitor the development of this delegated act and prepare for DPP registration.