A practical guide to understanding, preparing for, and complying with the EU Digital Product Passport regulation under the Ecodesign for Sustainable Products Regulation (ESPR).
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ESPR delegated acts set a passport obligation as of August 30, 2026. The only firm deadline is the battery passport, on February 18, 2027, under Regulation (EU) 2023/1542.
The Digital Product Passport (DPP) is a structured digital record that accompanies a physical product throughout its entire lifecycle. It aggregates product-level data on materials, manufacturing, environmental impact, repairability, and end-of-life handling into a single, accessible format.
The DPP is a core requirement of the Ecodesign for Sustainable Products Regulation (ESPR), adopted by the European Parliament and Council in 2024. The ESPR replaces and extends the earlier Ecodesign Directive (2009/125/EC), which was limited to energy-related products.
Under the ESPR, the European Commission is empowered to adopt delegated acts specifying DPP requirements for individual product categories. These delegated acts define what data must be included, how it must be stored, and who can access it.
The regulation establishes that every product placed on the EU market in a covered category must carry a DPP, accessible via a data carrier (such as a QR code or NFC tag) physically attached to the product.
The DPP serves multiple policy objectives simultaneously:
While the exact data requirements will vary by product category (defined in delegated acts), the ESPR framework establishes several broad categories of information that DPPs are expected to include.
The ESPR names the categories of actors who must have free and easy access to the passport, among them customers, professional repairers, refurbishers, recyclers, market surveillance authorities and customs authorities (Article 11, point b). It sets no access tier itself and defers the split of rights to the delegated acts specific to each product group (Articles 9(2)(f) and 10(1)(g)), none of which is published to date. The groupings below are not laid down by the regulation:
Expected public access: Consumer-facing information (environmental footprint, repairability, basic product identity).
Expected regulatory authority access: Full dataset including compliance declarations, test results, and supply chain documentation.
Expected supply chain actor access: Relevant data for recyclers, repairers, and refurbishers (e.g., disassembly instructions, material composition).
The DPP obligation applies broadly to economic operators placing products on the EU market within covered product categories.
The ESPR was adopted in 2024, but the DPP requirements will be implemented progressively through delegated acts for each product category. The exact timelines depend on when each delegated act is finalized.
2024
ESPR adopted and enters into force. European Commission begins preparing delegated acts for priority product categories.
2025
Working groups develop technical standards for DPP data formats and interoperability. Pilot programs and stakeholder consultations underway.
2026
Pivotal year. On March 19, 2026, the European Commission’s Joint Research Centre (JRC) published its DPP methodology (report JRC145830), a scientific document with no legal force: a 4-step approach, data classified into 3 tiers (Essential, Strongly recommended, Voluntary), product-specific granularity (model, batch, or unique item). On July 20, 2026, the EU central DPP registry goes into service: an index rather than a host, it maps a product identifier to a web address, and the passport data stays with the operator. As of August 30, 2026, no ESPR delegated act has been published, so no ESPR passport obligation exists yet. Iron and steel are among the priority groups in the Commission’s working plan.
2027
Delegated acts for textiles, aluminium, and tyres expected to be adopted. Battery passports become mandatory in February 2027 under EU Battery Regulation 2023/1542. Textile, leather goods, and accessories brands begin implementations to prepare for ESPR compliance by mid-2028.
2028–2030
Effective ESPR compliance for textiles by mid-2028 (18 months after delegated act adoption). Progressive rollout: furniture in 2028, mattresses in 2029, then other categories (construction products, metals) as delegated acts are adopted.
Updated August 30, 2026. Two facts have changed since the previous version: the European passport registry has been in service since July 20, 2026, and its implementing regulation (EU) 2026/1778 has applied since August 6, 2026. The other dates above rest on known trajectories and may move: no ESPR delegated act has been published to date, so no ESPR deadline is firm. The only firm deadline is the battery passport, on February 18, 2027, which comes from regulation (EU) 2023/1542 and its own timetable.
The ESPR applies to nearly all physical products placed on the EU market, with exceptions for food, feed, and medicinal products (covered by other regulations). Priority product categories identified for early DPP requirements include:
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