ESPR Timeline: When Does the Digital Product Passport Arrive?

Added 4 August 2026: According to the European Commission's DPP Help Desk, the semantic catalogue and the registry APIs are planned for Q4 2026. The act on requirements for digital product passport service providers is expected around Q2 2027. What this means for manufacturers is covered in having your battery passport registered.

Update July 2026: The central DPP registry has been live since 20 July 2026, and six standards including EN 18222 are officially recognized. The three July milestones in detail: The EU DPP registry is live.

What is ESPR?

The ESPR timeline is one of the most important topics for manufacturers preparing for upcoming EU requirements. The Ecodesign for Sustainable Products Regulation (ESPR), officially Regulation (EU) 2024/1781, entered into force on 18 July 2024, establishing the legal framework for the digital product passport across the European Union. It replaces the former Ecodesign Directive 2009/125/EC, which only covered energy-related products.

To prepare today, the DPP software page shows what is already possible.

The critical difference: ESPR goes far beyond energy efficiency. It covers virtually all physical products placed on the EU market, with the exception of food, feed, and medicinal products. For each product category, the regulation mandates the introduction of a digital product passport (DPP) that provides information on sustainability, repairability, recyclability, and supply chain in a machine-readable format.

For manufacturers, this means: the digital product passport will become mandatory not just for batteries, but progressively for dozens of additional product categories: from textiles and steel to electronics. Understanding which deadlines apply today provides a strategic advantage.

How ESPR Works: Framework Regulation and Delegated Acts

ESPR functions as a framework regulation: it establishes the general principles and mechanisms but does not define the specific requirements for individual product categories. These are set through delegated acts that the European Commission adopts separately for each product group.

This two-tier system has implications for the timeline:

• ESPR itself defines the framework: what a DPP must contain, how access works (QR code, data carrier), which actors are responsible, and how market surveillance is organized.
• The delegated acts specify for each product category: which specific data must be included in the DPP, which performance requirements apply, and from which date the DPP becomes mandatory.

In practice, this means: even though ESPR is already in force, the DPP for a given product group only becomes mandatory once the corresponding delegated act has been published and the transition period specified therein has expired. The European Commission has published a working plan outlining the sequence and approximate timeframes for individual product categories.

Important: Delegated acts have historically experienced delays of 6 to 12 months. The dates listed in the timeline below (with the exception of batteries) are therefore estimates based on the current working plan and may shift.

The Complete ESPR Timeline for the Digital Product Passport

The following table shows the current status of planned DPP introductions by product category. Note: only the date for batteries is confirmed and binding. All other dates are based on the European Commission's working plan and may shift due to delays in the delegated acts.

Note: The Battery Regulation is a standalone law (not part of ESPR) but serves as the blueprint for all subsequent digital product passports. The Toy Safety Regulation (EU) 2024/1262 also has a fixed date. All other timeframes depend on the adoption of the respective delegated acts.

Not every passport duty sits in the Ecodesign Regulation. The Critical Raw Materials Regulation (EU) 2024/1252 requires, in Article 28, a label on products containing permanent magnets, from motor vehicles and light means of transport through electric motors and heat pumps to household appliances; it starts two years after the corresponding implementing act enters into force. Article 29 builds on it: from 24 May 2027, or two years after the delegated act, whichever is later, the recycled share of neodymium, dysprosium, praseodymium, terbium, boron, samarium, nickel and cobalt must be publicly available once a product's magnets together exceed 0.2 kg.

Another sector arrives with the Detergents Regulation (EU) 2026/405. Under its Article 21 manufacturers create a digital product passport before a detergent or a surfactant for end users is placed on the market. The regulation applies from 23 September 2029 under Article 37; what was lawfully on the market before may still be made available until 23 September 2030.

The calculation behind every estimated date

Product passport timelines are full of years, and almost all of them are estimates. The reason is one sentence in Article 4(4) ESPR: “The date of application of a delegated act shall be at least 18 months after its entry into force.” Exceptions are possible, but only “in duly justified exceptional cases”.

That lets you check any estimate yourself instead of believing it: once a delegated act for your product group appears in the Official Journal, add 18 months and you know the earliest possible date. As long as no act exists, any year is a guess about the Commission work plan, not about the law.

The second route to a product passport: the Construction Products Regulation

The ESPR is not the only legal basis for digital product passports. Construction Products Regulation (EU) 2024/3110 of 27 November 2024 creates a passport system of its own for construction products which, in the words of the regulation, corresponds “as far as possible to the digital product passport under Regulation (EU) 2024/1781”. If you make construction products, do not read your timeline off the ESPR alone.

For manufacturers with a mixed range that means checking, product line by product line, which act applies. Two passports under two legal bases are possible, and the requirements are similar but not identical.

A date that has nothing to do with data and still belongs here

Besides the passport, the ESPR brings a duty that timelines almost always miss. Article 25(1) provides: “From 19 July 2026, the destruction of unsold consumer products listed in Annex VII shall be prohibited.” Micro and small enterprises are exempt; for medium-sized enterprises the ban applies only from 19 July 2030.

Paragraph 2 closes the obvious detour: those not subject to the ban may not destroy unsold consumer products supplied to them for the purpose of circumventing it. For planning that means the date is fixed, it concerns logistics rather than IT, and it arrives before the first product passport.

Why Batteries Go First

The battery passport is the world's first mandatory digital product passport, and for good reason. The EU Battery Regulation (EU) 2023/1542 was adopted a full year before ESPR and serves as a proof-of-concept for the entire DPP framework.

Several factors make batteries the ideal pilot product:

• High environmental relevance: Batteries contain critical raw materials such as lithium, cobalt, and nickel. Their production is energy-intensive and supply chains span multiple continents.
• Political priority: Electromobility is a cornerstone of the European Green Deal. The EU wants to ensure that the battery sector, one of the fastest-growing industries, is set up transparently and sustainably from the start.
• Circular economy: Batteries have high recycling value. The DPP enables tracking of material composition and recyclability across the entire lifecycle.
• Technical maturity: The technical standards, notably the DIN SPEC 99100, are already defined for batteries, while other product categories are still in the standardization phase.

The complete EU Battery Regulation timeline shows: from 18 February 2027, EV batteries, industrial batteries above 2 kWh, and LMT batteries may no longer be placed on the EU market without a valid digital battery passport.

What All Digital Product Passports Share

Although the specific data requirements vary by product category, ESPR defines overarching principles that apply to all DPPs:

• QR code access: Each product receives a machine-readable data carrier, typically a QR code, through which the DPP can be accessed. Consumers, retailers, and authorities can scan the product data with a smartphone.
• Machine-readable data: Information in the DPP must be provided in a standardized, machine-readable format. For batteries, this is based on JSON schemas according to DIN SPEC 99100.
• Unique identifiers: Each product must be identifiable via a globally unique identifier. ESPR names no preferred identifier system: Annex III requires the data carrier and the unique product identifier to comply with the ISO/IEC 15459 series, and GS1 standards such as GTIN and serial number are one way of meeting that requirement.
• Lifecycle data: The DPP accompanies the product throughout its entire lifecycle, from manufacturing through use to disposal or recycling. Certain data can be updated (e.g., repair history, ownership changes).
• Access rights: Different actors (consumers, market surveillance authorities, recyclers) receive different levels of access to DPP data.
• EU Registry: ESPR provides for a central EU registry in which digital product passports are registered. The registry has been live since 20 July 2026, together with a testing environment.

One point of the Ecodesign Regulation is regularly overlooked: under Article 10(4) the economic operator provides a backup copy of the digital product passport through an independent third-party service provider when placing the product on the market. The passport is meant to stay reachable even if the company behind it disappears. For the battery passport that explicit duty is not in the Battery Regulation; it still has to remain available under Article 78(e).

Preparing Regardless of Product Category

Even if the delegated act for your product category has not yet been published, you can start preparing today. Experience from the battery sector shows: those who build structured data early have a significant head start when the obligation takes effect.

1. Structure your product data: Capture your product data in a structured format. The DPP requires machine-readable data. Spreadsheets and PDF datasheets are not sufficient. Assess which information on material composition, origin, energy consumption, repairability, and recyclability already exists in your systems.

2. Implement unique identifiers: If you are not yet using GS1 GTINs or comparable unique identifiers for your products, start now. Transitioning identification systems is an organizational process that requires lead time.

3. Build supply chain transparency: ESPR requires supply chain due diligence evidence for many product categories. Begin systematically requesting relevant data from your suppliers, particularly regarding raw material origin and environmental impact.

4. Adapt internal processes: The DPP is not a one-time project. Integrate data collection into your product development and quality assurance processes so that every new product comes with a complete dataset from the start.

5. Monitor regulatory developments: Subscribe to relevant information channels from the European Commission and your industry associations. Delegated acts go through public consultation phases where you can provide input.

DPP Hero: From Battery Passport to DPP Platform

DPP Hero is a creation and management tool for digital product passports, built on the DIN SPEC 99100 standard. The software was developed for the battery passport, the first and so far only product category with a binding DPP start date.

However, DPP Hero's architecture is deliberately modular: the data model, export functions, and user interface can be extended for additional product categories once the respective delegated acts and technical standards are published.

For manufacturers in the battery sector, DPP Hero already provides the complete DIN SPEC 99100 data structure, GS1 identifier validation, and machine-readable JSON exports. Those preparing for the battery passport obligation from February 2027 can begin data entry immediately.

The six standards, and what a breach costs

Since Implementing Decision (EU) 2026/1736 of 14 July 2026, six standards for the digital product passport are harmonised. Anyone checking whether a solution fits needs the numbers, not the series:

• EN 18216:2026 Data exchange protocols
• EN 18219:2026 Unique identifiers
• EN 18220:2026 Data carriers
• EN 18221:2026 Data storage, archiving and data persistence
• EN 18222:2026 APIs for lifecycle management and searchability
• EN 18223:2026 System interoperability

The gap is telling: EN 18217 and EN 18218 are not on the list. The series is therefore not recognized in full. Cite a standard by its number, not by the series.

What a breach costs is set out in Article 74 of the Ecodesign Regulation. Paragraph 3 requires member states to provide for two things explicitly: fines and temporary exclusion from public procurement. Under paragraph 2 the assessment takes in the nature, gravity and duration of the infringement, whether it was intentional or negligent, the financial situation of the party held responsible and the economic benefit derived. Article 76 adds liability towards consumers: where a product does not conform, the manufacturer is liable for damages, failing that the importer or authorised representative, failing that the fulfilment service provider. The Regulation names no amounts; member states set those.

FAQ

Does ESPR apply to products manufactured outside the EU?

Yes. ESPR applies to all products placed on the EU market, regardless of where they are manufactured. A manufacturer in China exporting textiles to the EU must meet the DPP requirements just like a European manufacturer. Responsibility lies with the economic operator placing the product on the EU market. This can be the manufacturer themselves, an importer, or an authorized representative.

Will all product categories introduce the DPP simultaneously?

No. ESPR introduces the DPP progressively, starting with product categories for which preparatory studies and standardization work are already complete. Batteries go first (February 2027), followed by iron & steel, textiles, and tyres. Other categories like electronics or mattresses are not expected until 2029. A separate delegated act is adopted for each category.

Is the battery passport part of ESPR?

No, the battery passport is based on the EU Battery Regulation (EU) 2023/1542, which is a standalone law. The Battery Regulation was adopted one year before ESPR and serves as a pioneer and blueprint for the DPP concept. ESPR adopts many of the principles proven in the Battery Regulation and extends them to additional product categories.

What happens if the delegated act for my product category is delayed?

As long as the delegated act for your product category has not been published, there is no DPP obligation. Historically, delegated acts from the European Commission have frequently been delayed by 6 to 12 months. However, this does not mean you should wait to prepare: data structuring and supply chain transparency are valuable regardless of the specific date and give you a competitive advantage.

Can small and medium enterprises (SMEs) receive exemptions?

ESPR does not provide a general exemption for SMEs. However, delegated acts may include simplified requirements or extended transition periods for SMEs for specific product categories. Details are defined in the respective delegated acts. For the battery passport: no exemptions based on company size.