India and ESPR: Digital Product Passport Requirements for India Exporters to the EU
ESPR Regulation (EU) 2024/1781 applies to all products placed on the EU market, regardless of where they are manufactured. India exporters in Textiles and apparel, Pharmaceuticals, Engineering goods 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 India manufacturers and exporters need to know about ESPR compliance.
India's Export Profile and ESPR Exposure
India exports to the EU include products across multiple ESPR-regulated categories. The key sectors affected are:
- Textiles and apparel
- Pharmaceuticals
- Engineering goods
- Chemicals
- Leather and footwear
The EU is a major export destination for India 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 India Manufacturers
India 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 India Exporters
| Deadline | Requirement | Affected India Sectors |
|---|---|---|
| 19 July 2026 | EU DPP Registry live — customs begins automated DPP verification | All sectors |
| 18 February 2027 | Battery Passport mandatory — EV batteries, industrial batteries >2 kWh | Textiles and apparel |
| 2027–2028 | Textiles DPP expected mandatory | Pharmaceuticals |
| 2027–2028 | Electronics DPP expected mandatory | Engineering goods |
| 2028–2030 | Further product categories (furniture, construction, chemicals) | Sector-dependent |
EU Authorised Representative: What India 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 India 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 India Exporters
Once the technical documentation is complete and the EU Declaration of Conformity is drawn up, India 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 India 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.
India's ESPR Exposure: Textiles and Pharmaceuticals
India is the EU's second-largest supplier of textiles after China and the EU's largest supplier of generic pharmaceuticals. The textile delegated act will significantly affect Indian garment manufacturers, particularly those in the cotton and synthetic fibre sectors. Indian pharmaceutical manufacturers face potential ESPR exposure through the chemicals delegated act, which may require DPPs for active pharmaceutical ingredients (APIs) and finished drug products.
India's engineering goods sector — which exports machinery, automotive components, and industrial equipment to the EU — will be affected by multiple ESPR delegated acts as they are published. Indian manufacturers should begin building ESPR compliance infrastructure now, particularly for supply chain data collection and DPP registration systems.
India's ESPR Exposure: Textiles, Pharmaceuticals, and Electronics
India is a major exporter to the EU in three product categories that will be subject to ESPR requirements: textiles and clothing, pharmaceuticals, and electronics. The textile sector is India's largest manufacturing sector and a major source of EU textile imports. The pharmaceutical sector exports generic medicines to the EU. The electronics sector is growing rapidly, with India becoming an increasingly important manufacturing hub for smartphones and other electronics.
India's textile exports to the EU will be subject to the ESPR textile delegated act, expected in 2025-2026. Indian textile manufacturers must prepare for DPP requirements covering fibre composition, recycled content, carbon footprint, water consumption, chemical treatments, and supply chain traceability. The supply chain traceability requirement is particularly challenging for Indian textile manufacturers, whose supply chains often span multiple states and involve hundreds of small suppliers.
India and the EU Battery Regulation
India is a growing producer of lithium-ion batteries, with major manufacturers including Tata Chemicals, Exide Industries, and Amara Raja. Indian battery manufacturers exporting EV batteries to the EU must comply with the Battery Passport requirement from 18 February 2027. India is also a significant producer of mica — a critical raw material used in battery manufacturing — and Indian mica producers must be prepared to provide supply chain due diligence documentation that meets the Battery Regulation's requirements.
Pharmaceutical Packaging and ESPR
Indian pharmaceutical manufacturers exporting to the EU must comply with ESPR packaging requirements for their product packaging. The ESPR packaging delegated act will set requirements for recycled content, recyclability, and the Digital Product Passport for pharmaceutical packaging. Indian pharmaceutical manufacturers should monitor the development of the ESPR packaging delegated act and prepare for DPP registration for their EU-market products.
Register Your India Products' Digital Product Passports
India exporters to the EU need a compliant Digital Product Passport before the applicable ESPR deadline. Register now at Africa's first ESPR-compliant DPP registry.
Register Your Digital Product Passport →India's Export Sectors and ESPR Compliance Requirements
India is a major exporter of textiles and apparel, pharmaceuticals, chemicals, and engineering goods to the EU. The ESPR delegated acts for textiles and chemicals are the most directly relevant for Indian exporters. The textiles sector is India's second-largest export sector after engineering goods, and India is one of the EU's largest suppliers of cotton textiles and garments. The pharmaceuticals sector is less directly affected by ESPR (which covers manufactured products, not medicinal products), but pharmaceutical packaging is subject to ESPR packaging requirements.
Indian textile manufacturers must comply with the ESPR delegated act for textiles, which is expected to require DPP data disclosure on fibre composition, recycled content, substances of concern, and end-of-life instructions. Indian manufacturers who export to the EU must appoint an EU authorised representative and must ensure that their products meet all applicable ESPR requirements. The Federation of Indian Export Organisations (FIEO) and the Confederation of Indian Textile Industry (CITI) are monitoring ESPR developments and providing guidance to Indian exporters.
Frequently Asked Questions
Yes. ESPR applies to all products placed on the EU market, regardless of where they are manufactured. Indian textile manufacturers who export to the EU must comply with the ESPR delegated act for textiles. The EU importer is responsible for ensuring compliance, but Indian manufacturers must provide the data needed for the DPP.
The EU and India are currently negotiating a Free Trade Agreement. ESPR requirements apply to all products in the EU market regardless of trade agreements — ESPR is a product regulation, not a trade barrier. Indian exporters must comply with ESPR requirements to maintain their EU market access, regardless of the outcome of the FTA negotiations.
Azo dyes that can release carcinogenic aromatic amines are already restricted under REACH Annex XVII. The ESPR textile delegated act is expected to require disclosure of azo dye use in the DPP and may extend the existing REACH restrictions to additional azo dyes. Indian textile manufacturers should assess their dye use and ensure compliance with both REACH and ESPR requirements.
Indian pharmaceutical packaging exports (glass vials, blister packs, plastic bottles) are subject to ESPR packaging requirements, including recyclability and recycled content requirements under the revised PPWR. Indian pharmaceutical packaging manufacturers should monitor the PPWR and ESPR packaging delegated act for requirements that affect their products.
The EU Deforestation Regulation (EU 2023/1115) prohibits the placing on the EU market of products associated with deforestation, including wood-based products. Indian exporters of wood products (furniture, paper, wood panels) must conduct due diligence on their timber supply chains. ESPR adds DPP data disclosure requirements for wood-based products, including information on timber origin and due diligence measures.