Digital product passport in aviation: is there a duty?

What we checked

On 11 November 2026 we searched EUR-Lex for acts on the digital product passport and read the Ecodesign Regulation, the working plan and the Battery Regulation. We found no passport for aircraft or aircraft parts. A negative finding is not proof. Before deciding, check whether anything has been published since.

The Ecodesign Regulation applies to all physical goods, including components and intermediate products (Art. 1(2)). Its exclusions name road, agricultural and forestry vehicles and two- and three-wheel vehicles, not aircraft (Art. 1(2)(h)). A duty only arises with a delegated act for a product group (Art. 9(1)), and the working plan COM(2025) 187 does not provide one for aviation.

Batteries in aviation

The Battery Regulation places batteries used for traction in aviation transport among the industrial batteries (recital 15 Regulation (EU) 2023/1542). From 18 February 2027, every industrial battery with a capacity above 2 kWh placed on the market or put into service needs a battery passport (Art. 77(1)). All other batteries carry a QR code with required information (Art. 13(6)).

Not covered are batteries in equipment intended to be sent into space and in equipment for the protection of Member States’ essential security interests, arms, munitions and war material (Art. 1(5)). More on the page product passport for batteries.

Timeline with status

Where aviation suppliers can still be affected

Through intermediate products. Steel and aluminium are in the working plan. There the Commission is examining whether to set information requirements only or to include final products with a high steel or aluminium content. Which final products those would be has not been decided.

Through products on the ground and in the cabin that belong to a group, such as electrical equipment. Whether a future act covers products for aircraft is set by the act itself. The basics are in the guide Digital product passport: deadlines and product groups.

What you can do today

• List every battery in your products with category and capacity.
• For industrial batteries above 2 kWh, decide who issues the battery passport.
• Keep material data on steel and aluminium parts per batch retrievable.
• Once the acts on steel and aluminium are published, check them for included final products.
• Follow the status in the deadline tracker.

Further reading

• The product passport module: permanent address, QR code and documents per product
• The basics in the guide Digital product passport: deadlines and product groups
• Every date per product group in the deadline tracker
• All industries at a glance: product passport by industry

Frequently asked questions