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

ESPR Regulation (EU) 2024/1781 applies to all products placed on the EU market, regardless of where they are manufactured. Vietnam exporters in Electronics and semiconductors, Solar panels, Textiles and footwear 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 Vietnam manufacturers and exporters need to know about ESPR compliance.

Vietnam's Export Profile and ESPR Exposure

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

• Electronics and semiconductors
• Solar panels
• Textiles and footwear
• Furniture
• Tyres

The EU is a major export destination for Vietnam 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 Vietnam Manufacturers

Vietnam 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 Vietnam Exporters

EU Authorised Representative: What Vietnam 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 Vietnam 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 Vietnam Exporters

Once the technical documentation is complete and the EU Declaration of Conformity is drawn up, Vietnam 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 Vietnam 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.

Vietnam's ESPR Exposure: Electronics, Solar, and Textiles

Vietnam has emerged as a major electronics manufacturing hub, with Samsung, Intel, and LG operating large facilities in the country. Vietnamese electronics exports to the EU — including smartphones, semiconductors, and consumer electronics — will be subject to the electronics delegated act. Vietnam is also a significant exporter of solar panels and tyres, both of which face ESPR delegated acts.

Vietnam's furniture sector — which exports wooden furniture and home furnishings to the EU — will be affected by the furniture delegated act. Vietnamese furniture manufacturers will need to provide wood species identification, FSC/PEFC certification, and formaldehyde emission data in their furniture DPPs.

Vietnam's ESPR Exposure: Electronics and Solar

Vietnam has become a major manufacturing hub for electronics and solar panels, with major manufacturers including Samsung, LG, Intel, and many Chinese solar panel manufacturers operating large production facilities in Vietnam. Vietnamese electronics exports to the EU will be subject to the ESPR electronics delegated act, and Vietnamese solar panel exports will be subject to the ESPR solar panel delegated act.

Vietnam's electronics manufacturing sector is dominated by foreign-owned factories (Samsung, LG, Intel, Foxconn) that manufacture products for global brands. These factories will need to comply with ESPR requirements for the products they manufacture, including DPP registration. The foreign brand owners are responsible for ESPR compliance, but they will need to collect supply chain data from their Vietnamese factories to populate the DPP.

Vietnam and the EU Battery Regulation

Vietnam is a growing producer of lithium-ion batteries, with several Chinese battery manufacturers (CATL, Gotion) establishing production facilities in Vietnam. Vietnamese-manufactured batteries exported to the EU must comply with the Battery Passport requirement from 18 February 2027. Vietnam is also a significant producer of rare earth elements — a critical raw material used in electric motors and other products — and Vietnamese rare earth producers must be prepared to provide supply chain due diligence documentation.