Batteries are the blueprint
Whatever you make, study the battery passport - later categories reuse its structure and lessons.
The DPP arrives category by category through delegated acts. Batteries are the only group with a fixed statutory date; every other timeline tracks the European Commission's working plan and remains indicative until its delegated act enters into force.
Regulation (EU) 2024/1781 replaces the Ecodesign Directive and establishes the legal basis for the Digital Product Passport.
The interoperability reference model for DPP data is delivered, guiding sector pilots in textiles, electronics, tyres and construction.
A dedicated global standards committee for Digital Product Passports is launched; substantive deliverables are expected from 2028.
The framework switches on and the registry becomes operational. This is the framework activation - not yet a product-level obligation for most categories.
The Commission's responsible-sourcing guidelines shape the data layer of every battery passport.
EV, industrial and light-transport batteries above 2 kWh require a passport under the EU Battery Regulation (EU) 2023/1542 - the practical blueprint for every later category.
The textiles/apparel delegated act is expected around 2027; with the minimum ~18-month application window, mandatory passports arrive realistically no earlier than 2028.
Additional priority groups phase in, with iron & steel and ICT/electronics signalled to move fastest.
Analyses expect DPP obligations to extend to almost all product groups placed on the EU market. A first ESPR effectiveness review is also due around 2030.
As of 2026, no product-specific ESPR delegated act has yet entered into force. Dates beyond batteries follow the Commission's working plan and may shift. Treat them as planning anchors, not fixed law.
Expected implementation windows for the priority groups under the ESPR working plan.
| Product group | Expected obligation | Legal instrument | Data focus |
|---|---|---|---|
| EV, industrial & LMT batteries (> 2 kWh) | February 2027 (fixed) | Battery Regulation (EU) 2023/1542 | Critical raw materials, carbon footprint by lifecycle stage, recycled content, state-of-health |
| Textiles, footwear & apparel | No earlier than 2028 (act ~2027) | ESPR delegated act | Fibre composition, origin, recycled content, durability, supply-chain traceability |
| Iron & steel | 2028–2029 | ESPR delegated act | Lifecycle emissions, recycled content, material performance |
| ICT & electronics | 2028–2029 | ESPR delegated act | Components, repairability, material recovery, hazardous substances |
| Tyres | 2028–2029 | ESPR delegated act | Materials, durability, recyclability |
| Furniture | 2029–2030 | ESPR delegated act | Durability, materials, circular-design attributes |
| Detergents, paints, lubricants & aluminium | 2029–2030 | ESPR delegated act | Composition, environmental impact, safe handling |
| Construction products | Future phases | ESPR / CPR alignment | Lifecycle emissions, material performance, end-of-life |
LMT = light means of transport. Windows reflect the Commission working plan and industry analyses; only batteries have a fixed statutory date.
The passport is a data problem dressed up as a compliance deadline. The QR code, registry entry and file format are the easy part - what decides whether a passport holds up is assembling verifiable material, carbon-footprint and supplier data across the whole value chain.
Because no product-specific delegated act is in force yet, the coming 18–24 months are the cheapest window to build that underlying data layer before requirements are legally pinned down.
Pick your implementation guideWhatever you make, study the battery passport - later categories reuse its structure and lessons.
Data already collected for REACH, RoHS, CSRD and battery due diligence maps directly into a DPP.
Upstream data gaps are the top bottleneck. Onboarding suppliers is a multi-quarter effort - begin now.