Deadlines

When does your
product need a
Digital Product
Passport?

There is no single DPP deadline. The Ecodesign for Sustainable Products Regulation is a framework; the binding dates arrive one product group at a time through delegated acts. One group is already fixed by separate legislation.

Standards conformance

Deadlines by product group

Product group Deadline Regulatory status
Batteries 18 February 2027 · Regulation (EU) 2023/1542, Article 77. EV, LMT and industrial batteries above 2 kWh. Binding
Iron and steel Act expected Q4 2026, application from around 2028 Delegated act
Textiles Act expected 2027, application from around 2028 to 2029 Delegated act
Tyres Act expected 2027 Delegated act
Aluminium Act expected 2027 Delegated act
Furniture Act expected 2028 Delegated act
Mattresses Act expected 2029 Delegated act
Toys 1 August 2030 · Regulation (EU) 2025/2509, already adopted. Adopted
Detergents 23 September 2029 · Regulation (EU) 2026/405. Model-level passport for detergents and surfactants Adopted
Construction products Delegated act expected Q2 2027 · Regulation (EU) 2024/3110. Applies to products covered by new harmonised technical specifications. Delegated act

Delegated act dates are indicative and come from the ESPR Working Plan 2025-2030, COM(2025) 187. Application dates typically fall 18 to 36 months after adoption.

Adoption is not the deadline

Two dates matter and they are often confused. Adoption is when the delegated act is published and the required data fields become known. Application is when products placed on the market must carry a passport.

Under ESPR the gap is usually at least 18 months, and often longer. That gap is the entire preparation window, and most of it is spent collecting data from suppliers, not configuring software.

Most products
are not
covered yet

If your product is not on the list above, no Digital Product Passport is required of you today. Other ESPR rules can already apply: since 19 July 2026, large companies may not destroy unsold clothing and footwear, and the EU format for disclosing discarded unsold products applies from 2 March 2027. The working plan is reviewed periodically and coverage will widen, but there is no obligation to prepare a passport for a group that has not been named.

What is worth doing now is finding out whether your suppliers can give you the data when you ask. That answer takes longer to fix than any software decision.