The Digital Product Passport does not arrive on one date, for everything, all at once. It arrives product group by product group, through delegated acts adopted under the Ecodesign for Sustainable Products Regulation — the ESPR, Regulation (EU) 2024/1781. Batteries are already ahead of the curve, with their own passport duty from February 2027. For everything else, the question is not whether your product will need a passport, but when its turn comes — and the Commission’s first working plan already names the order.
A framework, not a single deadline
The ESPR entered into force on 18 July 2024. It replaces the old Ecodesign Directive (2009/125/EC) and widens the approach from energy-related products to almost all physical goods placed on the EU market — including components and intermediate products. The Regulation itself sets the framework: durability, repairability, recycled content, environmental footprint — and the Digital Product Passport as the information layer. The binding requirements for each product group are then set in delegated acts adopted under Article 4, which also fix the passport’s data, granularity (model, batch or item) and application dates, normally with a transition period before obligations bite.
The working plan: who is first
In April 2025 the Commission adopted the first ESPR and Energy Labelling Working Plan 2025–2030. Its priorities, with the indicative timing the Commission published for adopting each delegated act:
| Product group | Type | Indicative adoption of the delegated act |
|---|---|---|
| Iron & steel | Intermediate product | 2026 |
| Textiles & apparel | Final product | 2027 |
| Tyres | Final product | 2027 |
| Aluminium | Intermediate product | 2027 |
| Furniture | Final product | 2028 |
| Mattresses | Final product | 2029 |
Alongside the product groups, the plan covers horizontal measures — repairability and recycled-content requirements that cut across categories, including electrical and electronic equipment — and continues the review of energy-related products under the previous framework. A mid-term review in 2028 can add further groups. Treat the years as what they are: the Commission’s indicative adoption calendar. The legal deadline for your company is the application date in the delegated act for your product group — adoption plus transition — but data collection has to start well before either.
What a passport is, under the ESPR
Articles 9 to 11 set the essential requirements every ESPR passport must meet, whichever product group it serves:
- A data carrier on the product — physically present on the product, its packaging or accompanying documentation, connected to a persistent unique product identifier (Article 10);
- Open standards, no lock-in — passport data must be machine-readable, structured and transferable through an open interoperable network without vendor lock-in;
- Tiered access — customers, repairers, recyclers, market surveillance and customs authorities each access the data their role requires, free of charge (Article 11);
- Built to outlive companies — the passport must remain available for the period set in the delegated act, including after an insolvency, liquidation or cessation of activity of the operator who created it, and a back-up copy must be held through a Digital Product Passport service provider (Articles 10–11);
- Integrity by design — “data authentication, reliability and integrity shall be ensured”, and passports must be designed so that “a high level of security and privacy is ensured and fraud is avoided”.
The registry, the portal and customs
Article 13 required the Commission to set up the Digital Product Passport registry by 19 July 2026. Operators upload at least the unique identifiers of their products; the registry issues back a unique registration identifier. Article 14 adds a public web portal to search and compare passport data. And Article 15 connects the system to the border: anyone releasing a covered product for free circulation must provide its registration identifier, and customs verify it against the registry before release. A passport is therefore not a marketing page — it becomes part of the machinery of market access, for EU-made and imported products alike.
Already law: batteries
One sector does not have to wait for the ESPR sequence. Under Regulation (EU) 2023/1542, electric-vehicle, light-transport and larger industrial batteries need a battery passport from 18 February 2027 — and those battery identifiers are stored in the same ESPR registry. Our dedicated guide covers the duty, the data and the QR access model: Battery Passport from February 2027.
What companies should do now
- Find your group: locate your products in the working plan and track the delegated-act process for your group — that file is your real calendar.
- Start with data, not software: composition, origin, recycled content and repair information sit with suppliers; contracts and data requests take longer than any IT project.
- Adopt identifiers early: align product, operator and facility identifiers with the standards the ESPR points to, so labelling and packaging do not need a second redesign.
- Choose infrastructure that survives: the passport must outlive product cycles — and possibly the company unit that created it. Governed, standards-based infrastructure with predictable costs beats a quick proprietary fix.
Ledger Consortium builds passports on exactly those principles: we aggregate your product data, anchor it on a governed blockchain as tamper-evident evidence, and manage the regulatory updates as delegated acts land. In Italy, the Ledger DPP is distributed by Il Sole 24 Ore (Valore24), whose channel onboards dozens of companies per month. See the product working, live, in the demo — and read why the same identity that satisfies regulators also defeats counterfeiters here.