TracePass
Regulatory · delegated acts

ESPR & EU DPP delegated acts — dated status tracker

ESPR itself sets no Digital Product Passport requirement — each product category's obligation arrives only through its own delegated act under Regulation (EU) 2024/1781, and most delegated acts are still in preparation. This page shows what TracePass models today, per category: anchored against companion regulations where they exist (REACH, CLP, Tyre Labelling, Ecodesign, EPREL), and explicitly speculative where no Commission draft is yet published.

Regulation (EU) 2024/1781 of the European Parliament and of the Council establishing a framework for the setting of ecodesign requirements for sustainable products (ESPR)

Status

  • Adopted

    Passport duty is adopted law — the obligation is in a published Regulation or Decision. Mandatory date may be in the future.

  • Draft-aligned

    Modelled against a published Commission draft or a mature companion regulation (REACH, CLP, Tyre Labelling, Ecodesign, EPREL).

  • Speculative

    Modelled from CIRPASS recommendations or our own analysis; no Commission draft yet visible. Schema versions will bump when the act lands.

EU DPP legislation — current status

One row per EU act that creates, or expressly does not create, a Digital Product Passport obligation. Adopted and in-force rows cite the Official Journal (EUR-Lex). Acts in preparation cite the Commission's Have Your Say portal. Groups with no scheduled initiative are sourced from the ESPR Working Plan, a Communication that binds nothing.

ActProduct groupStageDateSourceLast checked
Battery Regulation (EU) 2023/1542

Art. 77(1) mandates the battery passport from 18 February 2027 for LMT, industrial batteries >2 kWh, and EV batteries. This is a Battery Regulation obligation, not ESPR — ESPR's own Art. 77 amends a different directive and is unrelated. Scope is battery-category-specific (not every portable battery).

Batteries (LMT, industrial >2 kWh, EV)In forcepassport mandatory from2027-02-18EUR-Lex (OJ)2026-09-26
Detergents Regulation (EU) 2026/405

The Detergents Regulation (EU) 2026/405 is adopted law: it mandates a product passport with a QR data carrier and a central-registry entry from 23 September 2029. This is a standalone obligation under the Detergents Regulation, not conditional on an ESPR delegated act.

DetergentsAdoptedpassport mandatory from2029-09-23EUR-Lex (OJ)2026-09-26
Toy Safety Regulation (EU) 2025/2509

The Toy Safety Regulation replaces Directive 2009/48/EC; Art. 19 mandates the toy DPP from 1 August 2030 when the Regulation applies. Notified-body articles (28–44, 49–55) apply from 1 January 2026. The passport replaces the EU Declaration of Conformity under the Directive — this is a standalone obligation, not an ESPR delegated act.

ToysAdoptedpassport mandatory from2030-08-01EUR-Lex (OJ)2026-09-26
ESPR (EU) 2024/1781

ESPR is a framework regulation: it mandates no Digital Product Passport field itself. Every product-group obligation flows through a delegated act adopted under Art. 4 of ESPR. As of this check date, no such delegated act has been adopted for any product group under ESPR (iron & steel and textiles are in preparation — see those rows).

Framework — all product groupsIn forcein force since2024-07-18EUR-Lex (OJ)2026-09-26
Implementing Regulation (EU) 2026/1778

Establishes the technical and operational rules for the EU DPP registry under ESPR Art. 13(5). The registry is operational (opened July 2026) but registration is enrol-only: no battery or other passport can complete a verified central registration yet because the back-up-copy delegated act (Art. 10(4)) is not adopted.

EU DPP registry (cross-category)In forcein force since2026-08-06EUR-Lex (OJ)2026-09-26
Implementing Decision (EU) 2026/1736

Cites six harmonised EN standards in support of ESPR (unique identifier, interoperability, data carrier, API, data exchange, data storage). These are ESPR-only — zero harmonised standards are cited under the Battery Regulation (2023/1542) as of this date. Two further standards (EN 18239 access rights, EN 18246 integrity) were published on 30 September 2026 but are not yet cited in the Official Journal.

DPP harmonised standards (EN 18216, 18219, 18220, 18221, 18222, 18223)Adoptedadopted2026-07-14EUR-Lex (OJ)2026-10-02
ESPR delegated act — iron & steel

Have Your Say initiative 17672 — the public consultation ran 20 May–12 August 2026. Q4 2026 is the Commission's planned adoption quarter per initiative 17672 and the ESPR Working Plan COM(2025) 187 — indicative until the act is published in the OJ. The ~2028 DPP-obligation estimate is from the Commission's DPP roadmap (DG GROW, May 2026), consistent with ESPR Art. 4's ≥18-month transition; the delegated act will fix the mandatory date.

Iron & steelPlannedplanned adoptionQ4 2026 (planned)Have Your Say2026-09-26
ESPR delegated act — apparel textiles

Have Your Say initiative 16116 — still at the planning stage (announced 18 December 2025). Q1 2027 is the Commission's planned adoption quarter — indicative until adopted in the OJ. The ~2029 DPP-obligation estimate is from the Commission's DPP roadmap (DG GROW, May 2026), consistent with ESPR Art. 4's ≥18-month transition; the delegated act will fix the date.

Apparel & textilesPlannedplanned adoptionQ1 2027 (planned)Have Your Say2026-09-26
ESPR delegated act — aluminium

No ESPR delegated act initiative for aluminium on Have Your Say yet. Working plan (COM(2025) 187): indicative adoption 2027; no passport date set. Obligation estimate (~2029) from the Commission's DPP roadmap (DG GROW, May 2026), indicative per ESPR Art. 4; the delegated act will fix the date.

AluminiumWorking plan only—EUR-Lex (working plan)2026-09-26
ESPR delegated act — tyres

No ESPR delegated act initiative for tyres on Have Your Say yet. Working plan (COM(2025) 187): indicative adoption 2027; no passport date set. Obligation estimate (~2029) from the Commission's DPP roadmap (DG GROW, May 2026), indicative per ESPR Art. 4; the delegated act will fix the date.

TyresWorking plan only—EUR-Lex (working plan)2026-09-26
ESPR delegated act — furniture

No ESPR delegated act initiative for furniture on Have Your Say yet. Working plan (COM(2025) 187): indicative adoption 2028; no passport date set. Obligation estimate (~2030) from the Commission's DPP roadmap (DG GROW, May 2026), indicative per ESPR Art. 4; the delegated act will fix the date.

FurnitureWorking plan only—EUR-Lex (working plan)2026-09-26
ESPR delegated act — mattresses

No ESPR delegated act initiative for mattresses on Have Your Say yet. Working plan (COM(2025) 187): indicative adoption 2029; no passport date set. Obligation estimate (~2030–2031) from the Commission's DPP roadmap (DG GROW, May 2026), indicative per ESPR Art. 4; the delegated act will fix the date.

MattressesWorking plan only—EUR-Lex (working plan)2026-09-26
ESPR delegated act — electronics (ICT)

No specific ESPR delegated act initiative for ICT products on Have Your Say (a repairability initiative, 17873, is on the portal but is not the product-group DPP act). ICT products are not a discrete product-group row in the working plan; they are covered by the horizontal 'recycled content and recyclability of electrical and electronic equipment' measure (COM(2025) 187), indicative adoption ~2029. No product-group DPP act adopted; no passport date set.

Electronics / ICTWorking plan only—EUR-Lex (working plan)2026-09-26
Construction Products Regulation (EU) 2024/3110

CPR (EU) 2024/3110 is adopted and in force; Chapter X (Arts. 75–79) creates a DPP legal framework for construction products. However, the passport obligation on manufacturers (Art. 22(7)) does not take effect until 18 months after the Art. 75(1) delegated act specifying which products carry a DPP. That delegated act has not been adopted and has no initiative on Have Your Say. Stage here reflects the passport duty, not the regulation itself.

Construction productsWorking plan only—EUR-Lex (OJ)2026-09-26
Packaging Regulation (EU) 2025/40

PPWR mandates marking, labelling and a QR data carrier (Art. 12) for reusable packaging — the QR requirement is not universal; it applies only to reusable packaging, not all packaging. No Digital Product Passport obligation flows from PPWR itself; the word 'passport' appears in PPWR only as a cross-reference to the ESPR passport framework.

PackagingNo passport—EUR-Lex (OJ)2026-09-26
VOC Paints Directive 2004/42/EC

Paints & coatings fall under substance law (VOC Directive 2004/42/EC and REACH). No delegated act under ESPR has been adopted, drafted, or initiated for this product group. There is no passport duty.

Paints & coatingsNo passport—EUR-Lex (OJ)2026-09-26

What TracePass models today

ESPR · iron-steel

Iron & Steel

Speculative
Fields modelled
84
Effective from
~2026-Q4
Mandatory from
~2028

Companion regulations

CBAM Regulation (EU) 2023/956, EN 10204 (inspection certificates), ResponsibleSteel Standard

Field areas covered

  • CBAM embedded-emissions data (scope 1, scope 2, precursor, grid intensity)
  • Production route, facility type (EAF vs BOF), recycled (scrap) content
  • Grade, EN designation, chemical composition per element
  • Heat / batch traceability, inspection-certificate URI (EN 10204)
  • Mechanical properties (yield, tensile, elongation, hardness)

Pending or partial

  • Final data-field list — no ESPR delegated act for iron & steel has been adopted; all fields are indicative pending the act
  • Durability, repairability, and end-of-life routing requirements (ESPR-layer, not yet defined)

Notes

Indicative — no ESPR delegated act for iron & steel has been adopted as of this review. Delegated act ~Q4 2026 per Have Your Say initiative 17672 and the ESPR Working Plan COM(2025) 187 final (CELEX 52025DC0187, adopted 16 April 2025) — a Commission Communication that sets no binding obligation. DPP obligation ~2028 is from the Commission's DPP roadmap (DG GROW, May 2026), consistent with ESPR Art. 4's ≥18-month transition; the delegated act will fix the mandatory date. CBAM Regulation (EU) 2023/956 already requires embedded-emissions reporting for steel imports — that data substrate is the most mature companion instrument today. Schema will be updated when the delegated act is formally adopted.

ESPR · textile

Textiles

Speculative
Fields modelled
60
Effective from
~2028
Mandatory from
~2029

Companion regulations

ESPR (EU) 2024/1781, Textile Labelling Regulation (EU) No 1007/2011, REACH (EC) No 1907/2006, General Product Safety Regulation (EU) 2023/988

Field areas covered

  • General Information: product identifier, manufacturer and importer chain
  • Materials & Composition: fibre content and percentage breakdown
  • Care Instructions: wash, dry, iron and special-treatment labelling
  • Durability & Performance: pilling, tear strength, colorfastness indicators
  • Environmental Impact: carbon footprint, water use, chemical treatment disclosure
  • Circularity & End-of-Life: recycled content, recyclability, disassembly instructions
  • Supply Chain: country of origin, manufacturing facility

Pending or partial

  • Product-specific performance requirements and minimum thresholds — to be defined by the ESPR delegated act, not yet adopted
  • Mandatory recycled-content minimums and specific durability test protocols for each textile subcategory

Notes

No ESPR delegated act for textiles has been adopted. Have Your Say initiative 16116 plans its adoption for Q1 2027 — a planned quarter, not a date anything binds to until the act is published in the Official Journal. The working plan (COM(2025) 187) gives an indicative adoption year of 2027; obligation estimate (~2029) is from the Commission's DPP roadmap (DG GROW, May 2026), consistent with ESPR Art. 4's ≥18-month transition; the delegated act will fix the mandatory date. Fibre-composition labelling is already required under the Textile Labelling Regulation (EU) No 1007/2011, so that field carries statutory authority today; care labelling is voluntary in the EU. All remaining fields anticipate the ESPR delegated act.

ESPR · tyres

Tyres

Draft-aligned
Fields modelled
93
Effective from
~2028
Mandatory from
~2029

Companion regulations

EU Tyre Labelling Regulation (EU) 2020/740, ECE Regulation 117

Field areas covered

  • Identifier and manufacturer/importer chain (with EORI)
  • Tyre class, size designation, load and speed indices
  • EPREL registration + label class (rolling resistance, wet grip, noise)
  • Retreadability and end-of-life routing
  • Date and place of manufacture, casing/structural data

Pending or partial

  • Implementing-act-specific test methodology refinements

Notes

Tyre Labelling Regulation 2020/740 + ECE Regulation 117 supply most of the data structure; the ESPR delegated act is expected to align with these rather than introduce a parallel scheme.

ESPR · electronics

Electronics

Draft-aligned
Fields modelled
160
Effective from
~2028
Mandatory from
~2029

Companion regulations

Ecodesign Directive 2009/125/EC + delegated regulations, EPREL, RoHS, WEEE, RED, RFE

Field areas covered

  • Identifier, manufacturer, importer, authorised representative
  • CE marking, EU Declaration of Conformity, technical-documentation URL
  • Repairability score, parts availability and lead-time, software-update commitment
  • Energy efficiency class, EPREL registration, recycled content
  • End-of-life routing, hazardous-substance disclosure (RoHS / WEEE)

Pending or partial

  • Subcategory-specific delegated-act fields (the ESPR delegated act will be issued per electronics subcategory)
  • Detailed power-supply-and-charger interoperability (USB-C harmonisation)

Notes

Electronics is the broadest category — 160 fields cover the cross-cutting compliance surface. Each delegated act will narrow the scope per subcategory (smartphones, tablets, displays, etc.); we plan one schema bump per finalised subcategory act.

ESPR · detergents

Detergents

Adopted
Fields modelled
77
Effective from
2029-09-23
Mandatory from
2029-09-23

Companion regulations

REACH (EC) 1907/2006, CLP (EC) 1272/2008, BPR (EU) 528/2012, SDS Regulation (EU) 2020/878

Field areas covered

  • Identifier and manufacturer/importer chain, authorised representative
  • Hazardous-substance disclosure (REACH-aligned), SVHC declarations
  • CLP labelling: GHS pictograms, signal words, hazard and precautionary statements
  • Safety data sheet linkage and ingredient disclosure
  • Intended use, packaging, ingredient concentration ranges

Pending or partial

  • ESPR-specific durability and end-of-life metrics beyond the Detergents Regulation data set
  • National variations on declaration thresholds where they diverge from REACH

Notes

Detergents no longer waits on an ESPR delegated act for its passport: Regulation (EU) 2026/405 Art. 21 mandates a product passport from 23 September 2029 in its own right, with REACH and CLP supplying most of the data structure. Any ESPR act would layer durability and end-of-life metrics on top, not replace either.

ESPR · furniture

Furniture

Speculative
Fields modelled
79
Effective from
~2029
Mandatory from
~2030

Companion regulations

EN 1335 (office), EN 16139 (contract), EN 71-3 (children), FSC Chain of Custody

Field areas covered

  • Identifier, manufacturer/importer chain, country of manufacture
  • Bill of materials, total weight, recycled content (post + pre + total)
  • Formaldehyde emission class (E0/E1/CARB)
  • Durability and repairability indicators, spare-parts availability
  • FSC chain-of-custody markers, end-of-life routing

Pending or partial

  • Final ESPR delegated-act methodology for durability test cycles
  • Office vs contract vs domestic-use scope split — no published draft

Notes

No Commission draft for the furniture delegated act has been published as of this review. The schema is anchored on EN durability standards and existing emission-class conventions; expect schema bumps when the act lands.

ESPR · jewelry

Jewellery

Speculative
Fields modelled
54
Effective from
—
Mandatory from
—

Companion regulations

Responsible Jewellery Council (RJC) Code of Practices, OECD Due Diligence Guidance, Kimberley Process

Field areas covered

  • Identifier, manufacturer, retailer chain
  • Primary metal type, fineness, weight, hallmark authority and number
  • Gemstone attributes: type, weight, colour, clarity, cut, treatment
  • Origin and provenance markers, responsibly-sourced declarations

Pending or partial

  • Full RJC chain-of-custody (we model markers; deeper supply-chain provenance requires per-batch input we don't yet collect)
  • End-of-life recycling instructions specific to jewellery formats

Notes

No ESPR delegated act for jewellery is adopted or scheduled: jewellery is not in the ESPR working plan COM(2025) 187 (next review 2028), so a jewellery passport is voluntary. The schema anchors on RJC, OECD and the Kimberley Process as the most stable references; it will change only if the Commission schedules an act.

ESPR delegated acts — common questions

What is the timeline for the ESPR delegated acts?
The Ecodesign for Sustainable Products Regulation (ESPR — Regulation (EU) 2024/1781) entered into force in 2024, but it sets no Digital Product Passport requirements by itself. Each product category gets its own delegated act, adopted on the schedule in the Commission's ESPR working plan. The first working plan (2025–2030) prioritises textiles, iron & steel, furniture, tyres, and a set of others; most category delegated acts are still in preparation, so concrete DPP obligations arrive category by category rather than all at once.
What does the first ESPR working plan cover?
The Commission's first ESPR working plan — COM(2025) 187 final (CELEX 52025DC0187), adopted 16 April 2025 — is a Communication that sets the order in which product groups are tackled. It does not bind anything; it gives the indicative adoption years for each delegated act. Iron & steel and textiles are early priorities (steel delegated act expected around Q4 2026 per initiative 17672 and the working plan; DPP obligation ~2028 per the Commission's DPP roadmap (DG GROW, May 2026), consistent with ESPR Art. 4's ≥18-month transition — all indicative), followed by furniture, tyres, aluminium, and others. The working plan tells you when a category's delegated act is expected, not the final field list, which the delegated act itself will define.
When do ESPR delegated acts make a Digital Product Passport mandatory?
It depends entirely on the category. The battery passport is mandatory from 18 February 2027 under the EU Battery Regulation (2023/1542), not ESPR; the toy passport is mandatory from 1 August 2030 under the Toy Safety Regulation (EU) 2025/2509, also not ESPR. Under ESPR, iron & steel is expected to require a DPP from around 2028 (indicative — no delegated act adopted yet); textiles, aluminium and tyres follow through 2029. Each date is fixed by that category's own instrument, so the only safe answer is per-category — which is exactly what the matrix above tracks.
Is there a confirmed date for the steel DPP?
The iron & steel delegated act under ESPR is expected around Q4 2026, with the Digital Product Passport expected to become mandatory around 2028. Steel also overlaps CBAM reporting, so the data substrate is partly already being collected. Treat the 2028 date as indicative — it is from the Commission's DPP roadmap (DG GROW, May 2026), consistent with ESPR Art. 4's ≥18-month transition; the delegated act will fix the mandatory date.

Where this fits: see the buyer's guide

/buyers-guide →

Reviewed by Malin Ivanov, Managing Director — on