When does the EU Digital Product Passport become mandatory?

The ESPR has been in force since 18 July 2024, but no passport obligation has started yet. The first is for certain batteries, from 18 February 2027.

By Jack Cook 5 October 2025
DPP Timeline Compliance ESPR

The Ecodesign for Sustainable Products Regulation (ESPR) entered into force on 18 July 2024. It does not set one deadline for every product. Each product group gets its own delegated act, and that act is what triggers the passport obligation for that group. As at 19 October 2026, no ESPR product act has been adopted, and none of the first passport obligations has started.

The first date to plan around is 18 February 2027. That is when the Battery Regulation starts requiring passports for some batteries. Everything after that date is a Commission planning date, not a legal one. This post separates the two, so you can see which dates are law and which are forecasts.

How the ESPR sets its dates

Regulation (EU) 2024/1781 repealed the old Ecodesign Directive with effect from 18 July 2024. It has no general date of application. Parts of the old Directive continue until 31 December 2026 for listed energy-related products, and until 31 December 2030 for other products.

The passport rules themselves come through delegated acts. Each act says which data a passport holds, which carrier is used, whether the passport sits at model, batch or item level, who may read and update it, and how long it must stay available. Until an act is adopted for a product, the obligation does not apply to that product. You can read the Regulation on EUR-Lex.

The working plan dates

The Commission's first working plan, COM(2025) 187 final, was published on 16 April 2025. It chose the product groups below. The timings come from the Commission's own digital product passport pages, checked on 18 October 2026. Every row is indicative. The Commission says that "Implementation timelines may evolve as legislative and technical work progresses."

Product group Adopted or indicative Indicative timing
Iron and steel Indicative Q4 2026
Aluminium Indicative Q3 to Q4 2027
Textiles, with an apparel focus Indicative Q4 2027
Tyres Indicative Q3 to Q4 2027
Furniture Indicative 2028
Mattresses Indicative 2029
Repairability, horizontal measure Indicative 2027
Recycled content and recyclability of electrical and electronic equipment, horizontal measure Indicative 2029
Energy-related products, 16 items carried forward from the earlier plan Indicative 2026 to end 2030, item by item

Adopted means the act has been published in the Official Journal or is in force. Indicative means the Commission's own planning date, which is not set in law. None of these product acts has been adopted. The working plan treats iron and steel and aluminium as intermediate products. The scope of those acts has not been set. For iron and steel, the Commission lists Q4 2026 as indicative. The Commission's Joint Research Centre published a draft proposal on steel passport content for stakeholder consultation in spring 2026. That is a draft, not an act.

Batteries come first

The first passport obligation sits in the Battery Regulation (EU) 2023/1542, not in the ESPR. Article 77(1) says that from 18 February 2027, each light means of transport (LMT) battery, each industrial battery with a capacity above 2 kWh and each electric vehicle battery placed on the market or put into service must have a battery passport. Portable batteries are not covered by that date.

The obligation applies at the point a battery is placed on the market or put into service, so makers and importers need the passport ready before a battery is placed on the market from that date. The Commission's guidance on battery passport data, published on 21 August 2026, lists 71 data points by category.

The DPP registry

The EU registry for digital product passports went live on 20 July 2026. It runs under Implementing Regulation (EU) 2026/1778, which entered into force on 6 August 2026. Under Article 13(1), the registry stores at least unique identifiers, commodity codes for imports and battery identifiers. Under Article 13(5), it issues a unique registration identifier, and that identifier is not proof of compliance.

TraceID does not register passports with the EU registry and does not connect to it.

Service providers and packaging

The delegated act for DPP service providers is not yet adopted. The Commission's page lists it for Q2 and Q3 2027, indicative. Under Article 10(4), a backup copy of a passport can be held by a DPP service provider, so this act will matter to anyone who relies on one.

Packaging is handled separately. The Packaging and Packaging Waste Regulation (EU) 2025/40 applies from 12 August 2026. The Commission says its labelling and data requirements apply from August 2028 or later, pending an implementing act. ESPR does not give packaging a passport of its own.

The UK position

The UK has no digital product passport law. The Department for Business and Trade ran a call for evidence on digital product records from 27 July 2026, and it closed on 21 September 2026. For Great Britain, the government "has not yet determined its approach". EU passport rules apply in Northern Ireland under the Windsor Framework.

What a UK supplier needs to do

Where you are based does not change the EU test. Under Article 9(1), a product covered by a delegated act can only be placed on the EU market if a passport is available for it. If you sell into the EU, check each product against the groups and dates above, and against the battery rule. Until a delegated act or the Battery Regulation covers a product, no EU passport is required for it. For sales only within Great Britain, there is no UK requirement yet.

What to do now

Start with your product list. For each product, note whether it is a battery in scope, whether it falls in one of the groups above, and which of your customers or export markets are likely to ask for passport data first. Then check where the certificates and batch records for each product are kept today. Records that sit in several places are slow to pull together when a passport is requested.

TraceID's digital product passport guide explains what a passport holds. Traced is TraceID's module for keeping product and batch records in one place.

Frequently asked questions

When is the first EU digital product passport obligation?

18 February 2027. From that date, certain electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh must have a battery passport under the Battery Regulation. Portable batteries are not covered by that date, and no ESPR product act is adopted yet.

Is a passport already mandatory for steel, aluminium or textiles?

No. None of the ESPR product delegated acts for iron and steel, aluminium, textiles, tyres, furniture or mattresses has been adopted. Their timings are indicative, running from Q4 2026 for iron and steel to 2029 for mattresses.

Does the UK have a digital product passport law?

No. The Department for Business and Trade call for evidence closed on 21 September 2026, and for Great Britain the government has not yet determined its approach. EU passport rules apply in Northern Ireland under the Windsor Framework.

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