Indonesia and ESPR: Digital Product Passport Requirements for Indonesia Exporters to the EU
ESPR Regulation (EU) 2024/1781 applies to all products placed on the EU market, regardless of where they are manufactured. Indonesia exporters in Palm oil and derivatives, Batteries and nickel, Tyres and rubber 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 Indonesia manufacturers and exporters need to know about ESPR compliance.
Indonesia's Export Profile and ESPR Exposure
Indonesia exports to the EU include products across multiple ESPR-regulated categories. The key sectors affected are:
- Palm oil and derivatives
- Batteries and nickel
- Tyres and rubber
- Textiles
- Furniture
The EU is a major export destination for Indonesia 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 Indonesia Manufacturers
Indonesia 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 Indonesia Exporters
| Deadline | Requirement | Affected Indonesia 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 | Palm oil and derivatives |
| 2027–2028 | Textiles DPP expected mandatory | Batteries and nickel |
| 2027–2028 | Electronics DPP expected mandatory | Tyres and rubber |
| 2028–2030 | Further product categories (furniture, construction, chemicals) | Sector-dependent |
EU Authorised Representative: What Indonesia 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 Indonesia 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 Indonesia Exporters
Once the technical documentation is complete and the EU Declaration of Conformity is drawn up, Indonesia 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 Indonesia 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.
Indonesia's ESPR Exposure: Nickel, Batteries, and Palm Oil
Indonesia is the world's largest producer of nickel — a critical raw material for EV batteries. The Battery Regulation's recycled content requirements for nickel will directly affect Indonesian nickel miners and processors. Indonesia is also the world's largest producer of palm oil, which is used in cosmetics, food, and biofuels — sectors that may face ESPR DPP requirements in future delegated acts.
Indonesia's tyre manufacturing sector — which supplies natural rubber-based tyres to the EU market — will be affected by the tyres delegated act. Indonesian tyre manufacturers will need to disclose recycled rubber content, carbon footprint, and tyre wear microplastic emissions in their tyre DPPs.
Indonesia's ESPR Exposure: Palm Oil, Batteries, and Nickel
Indonesia's ESPR exposure is concentrated in three areas: palm oil (used in packaging and consumer products), batteries (Indonesia is the world's largest producer of nickel, a key battery material), and electronics (Indonesia is a growing electronics manufacturing hub). Indonesia's nickel industry is particularly significant for ESPR — nickel is a critical raw material used in EV batteries, and the EU Battery Regulation requires supply chain due diligence documentation for nickel used in EV batteries.
Indonesian nickel 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 IRMA (Initiative for Responsible Mining Assurance) standard is widely recognised for nickel supply chain due diligence, and Indonesian nickel producers who obtain IRMA certification will be better positioned to supply to EU-market battery manufacturers.
Palm Oil and ESPR Packaging Requirements
Palm oil is widely used in food packaging, cosmetics packaging, and other consumer product packaging. The ESPR packaging delegated act is expected to set requirements for bio-based content in packaging, which may affect the use of palm oil-derived materials in packaging. Indonesian palm oil producers should monitor the development of the ESPR packaging delegated act and the EU Deforestation Regulation (which applies to palm oil) to understand how these regulations interact.
Indonesia's Palm Oil Sector and ESPR Sustainability Requirements
Indonesia is the world's largest producer of palm oil, and palm oil is a key ingredient in many products sold in the EU — food products, cosmetics, cleaning products, and biofuels. The EU Deforestation Regulation (EUDR, EU 2023/1115) requires operators placing palm oil products on the EU market to conduct due diligence and verify that the palm oil was not produced on deforested land. While the EUDR is a separate regulation from ESPR, the two regulations share the same underlying principle — supply chain transparency and traceability. Indonesian palm oil producers that are implementing EUDR compliance systems (geolocation data, deforestation-free certification, supply chain traceability) are building the same data infrastructure that will be needed for ESPR DPP compliance for palm oil-containing products.
Register Your Indonesia Products' Digital Product Passports
Indonesia 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 →Indonesia's Export Sectors and ESPR Compliance
Indonesia is a major exporter of palm oil, nickel, coal, and textiles to the EU. The ESPR delegated acts for batteries (which use nickel) and packaging (which may use palm oil-based materials) are the most directly relevant for Indonesian exporters. Indonesia is the world's largest producer of nickel, which is a critical material for EV batteries. The EU Battery Regulation's supply chain due diligence requirements will require battery manufacturers to disclose the origin of the nickel in their batteries, which will affect Indonesian nickel miners and processors.
Indonesia's palm oil industry faces significant pressure from the EU Deforestation Regulation, which prohibits the placing on the EU market of products associated with deforestation, including palm oil. ESPR packaging requirements may also affect Indonesian palm oil-based packaging materials. Indonesian exporters should monitor both the EU Deforestation Regulation and ESPR packaging requirements for impacts on their products.
Frequently Asked Questions
The EU Battery Regulation requires battery manufacturers to disclose the origin of the critical raw materials in their batteries, including nickel. Indonesian nickel miners and processors must provide supply chain due diligence information to battery manufacturers who use their nickel. This information will be included in the Battery Passport.
Palm oil is an agricultural commodity, not a manufactured product, so it is not directly subject to ESPR. However, products that contain palm oil (such as food packaging, cosmetics, and biofuels) may be subject to ESPR requirements. The EU Deforestation Regulation is the primary regulation affecting Indonesian palm oil exports to the EU.
The EU and Indonesia are negotiating a Comprehensive Economic Partnership Agreement (CEPA). ESPR requirements apply to all products in the EU market regardless of trade agreements. Indonesian exporters must comply with ESPR requirements to maintain their EU market access, regardless of the outcome of the CEPA negotiations.
Indonesia is a significant exporter of textiles and garments to the EU. The ESPR delegated act for textiles will require Indonesian textile manufacturers to comply with DPP data disclosure requirements for fibre composition, recycled content, and substances of concern. Indonesian manufacturers should begin preparing for compliance by assessing their supply chains and collecting material composition data.
Indonesia is developing a domestic battery manufacturing industry, leveraging its large nickel reserves. Indonesian battery manufacturers who export to the EU must comply with the EU Battery Regulation's Battery Passport requirements. The Battery Passport requirement takes effect from February 2027 for EV batteries and industrial batteries above 2 kWh.