“Which of my products need a Digital Product Passport, and when?” is the first question every product team asks, and the honest answer is that it depends on the product group. The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, covers almost all physical products in principle, but it applies to a group only once the Commission adopts a delegated act for it. This guide explains how that process works, lists the product groups by status and expected timing, shows which products are excluded, and gives a practical way to stay current. It was last checked against the sources on 26 September 2026, and every date marked “expected” comes from the Commission’s working plan and can change. The free DPP Product Category Lookup keeps the same information searchable, with sources.
How a product gets a passport requirement
A product group is bound by passport rules only after four things happen in order.
- The ESPR is in force. It entered into force on 18 July 2024 and provides the framework, including the Digital Product Passport.
- The product group is named in a working plan. The Commission’s first ESPR working plan, adopted on 16 April 2025, names the priority groups and the indicative timing of their delegated acts. It also renews a number of energy-related product categories from the earlier ecodesign plan.
- A delegated act is adopted for the group. The act sets the ecodesign requirements and says whether and how the passport applies, what it contains and which data carrier and identifier rules are used.
- The act’s application date arrives. Rules usually apply after a transition period, so there is time between adoption and enforcement.
That is why “expected around 2027” is not a deadline. It is the plan’s target for when the delegated act arrives, and the passport obligation would follow after that. Only batteries, which fall under a separate law, have a fixed passport date today.
The status of each product group
| Product group | Governing rule | Status and timing | Data likely to matter |
|---|---|---|---|
| Batteries: electric vehicle, industrial over 2 kWh, light means of transport | Battery Regulation (EU) 2023/1542 | Fixed: battery passport from 18 February 2027 | Chemistry, composition, carbon footprint, recycled content, due diligence, performance |
| Iron and steel | ESPR delegated act | Expected around 2026 (working plan) | Carbon footprint, recycled content, grade and material data |
| Aluminium | ESPR delegated act | Expected around 2027 (working plan) | Alloy, recycled content, carbon footprint |
| Textiles and apparel | ESPR delegated act | Expected around 2027 (working plan) | Fibre composition, durability, repair, recycled content, substances |
| Tyres | ESPR delegated act | Expected around 2027 (working plan) | Tyre label data, performance, materials |
| Furniture | ESPR delegated act | Planned around 2028 (working plan) | Materials, durability, repairability, end-of-life |
| Mattresses | ESPR delegated act | Timing to be confirmed | Material layers, recyclability |
| Electronics and ICT | Existing ecodesign rules; ESPR measures later | No ESPR passport date set | Repairability, spare parts, software updates, energy data |
| Construction products | Construction Products Regulation (EU) 2024/3110 | Phased in through later acts; check the schedule | Declaration of performance and environmental data |
| Food, feed and medicines | Excluded from the ESPR | Not applicable | Follow food labelling and pharmaceutical serialisation rules |
| Vehicles under type-approval law | Excluded from the ESPR | Not applicable; vehicle batteries fall under the Battery Regulation | Type-approval documentation |
To our knowledge at the time of review, the first fixed date for a passport is 18 February 2027 for batteries. Anything else marked as expected can move, so verify it on the Commission’s ESPR pages before you plan spend around it. If your group has moved since this review, the category lookup shows the date it was last reviewed and links to the source for each entry.
What is already in force for products in the ESPR’s scope
Waiting for the delegated act does not mean nothing applies. Some parts of the ESPR and neighbouring rules already do.
- The ban on destroying unsold apparel, clothing accessories and footwear applies to large companies from 19 July 2026. Medium-sized companies follow in 2030, and micro and small enterprises are exempt.
- The Digital Product Passport registry. The ESPR requires the Commission to set it up by 19 July 2026. Check the Commission’s ESPR pages for its operational status.
- Environmental claims. The Empowering Consumers for the Green Transition Directive (EU) 2024/825 applies from 27 September 2026 and restricts generic environmental claims and unverified sustainability labels.
- Repair rules. The Right to Repair Directive (EU) 2024/1799 applies in Member States from 31 July 2026.
- Existing ecodesign and energy labelling rules for appliances, lighting, displays and phones and tablets already require product data.
The map of how ESPR, the Digital Product Passport and the Battery Regulation fit together explains these in more detail.
What is excluded from the ESPR
The ESPR excludes food, feed, medicinal products for human and veterinary use, living plants, animals and micro-organisms, products of human origin, and motor vehicles governed by type-approval law. Products in these groups follow their own sector rules. Note that the battery in a vehicle, or a battery sold on its own, falls under the Battery Regulation and may need its own passport.
Sector by sector: what to do now
Apparel, textiles and footwear
Textiles are the top priority in the working plan, with a delegated act expected around 2027, and the passport is likely to carry fibre composition, durability, repair, recycled content and substance information. Start with structured fibre composition at style and colour level, plan how the code links to the care label, and review how unsold stock is handled given the destruction ban. See the Digital Product Passport for fashion brands .
Furniture and home goods
Furniture is planned around 2028. Record materials and finishes per component, and spare part information for best sellers. See the Digital Product Passport for furniture and home goods . Mattresses are named as a priority group, with timing still to be confirmed.
Electronics
Electronics already have ecodesign, energy label and repair data requirements in several product lines, so this data is often the most mature. Keep repairability, spare parts and software update information structured. See the Digital Product Passport for electronics brands .
Iron, steel and aluminium
These come first in the working plan. Assemble product carbon footprint with a stated method, recycled content and grade data per product or batch, and check how your identifiers work with customers’ systems.
Batteries
Confirm which batteries fall into the passport categories, gather chemistry, composition and carbon footprint data from cell and material suppliers, and plan the QR code and hosting for the battery’s life.
How to find out whether your product is covered
- Classify your products. Group them by the categories above and by material, since delegated acts are written by product group.
- Look up each group. Use the DPP Product Category Lookup for the status, timing, what to do now and the source.
- Read the source. For binding detail, use the text of the regulation on EUR-Lex and the Commission’s ESPR page. Third-party summaries, including this one, can lag behind.
- Check the data you would need. Use the DPP Data Field Mapper to see how far your current attributes go.
- Set a review date. Put a quarterly reminder in your plan, and note which date changes would alter your priorities.
A sensible way to plan under uncertainty
- Spend first where the date is fixed or close. Batteries and fashion have the nearest obligations, and iron and steel come first among the ESPR groups.
- Build the shared foundation for everything. Identifiers, structured data, supplier evidence and governance serve nearly every group. The 30-step ESPR compliance roadmap sets out the sequence.
- Do not build group-specific detail early. Field lists will change when the delegated acts are adopted.
- Understand the data. The Annex I product parameters show what the requirements can cover.
- Decide on the carrier late but plan for it early. The carrier comparison shows what materials and sizes need.
For terms used here, such as delegated act, economic operator and data carrier, see the DPP Terminology Glossary , and for the whole programme, the Digital Product Passport guide . This article is general guidance, not legal advice.
Frequently asked questions
Which products need a Digital Product Passport?
Under the ESPR, products need a passport only once a delegated act for their product group is adopted and applies. The first fixed date is 18 February 2027 for electric vehicle, industrial (over 2 kWh) and light means of transport batteries under the Battery Regulation. Other groups follow through delegated acts.
When will textiles need a Digital Product Passport?
Textiles are a priority group in the Commission’s ESPR working plan, with a delegated act expected around 2027. The passport obligation would follow after adoption and any transition period. The timing is not final.
Which products are excluded from the ESPR?
Food, feed, medicinal products for humans and animals, living plants, animals and micro-organisms, products of human origin and motor vehicles governed by type-approval law are excluded.
Is there a Digital Product Passport requirement for electronics yet?
No ESPR passport date has been set for electronics and ICT. They already face ecodesign, energy label and repair rules in some product lines, and ESPR measures may follow.
What is the ESPR working plan?
It is the Commission’s plan naming the product groups that will get ESPR requirements first and the indicative timing of the delegated acts. The first plan was adopted on 16 April 2025, covering 2025 to 2030.
Where can I check the current status?
Use the Commission’s ESPR pages and the text on EUR-Lex for binding detail. The free DPP Product Category Lookup lists each group’s status, timing and source with a last-reviewed date.
