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 is the source of the indicative timelines below. Iron & steel and textiles are early priorities (steel delegated act expected around Q4 2026, mandatory DPP from 2028 — indicative until the act is formally adopted), followed by furniture, tyres, aluminium, and others through 2028–2030. 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. 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; toys around 2030. Each date is fixed by that category's delegated act, 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 becoming mandatory from 2028. Steel also overlaps CBAM reporting, so the data substrate is partly already being collected. Treat the 2028 date as the current best estimate from the ESPR working plan until the delegated act is formally adopted.

Regulatory · delegated acts

ESPR delegated acts — per-category coverage

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

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.
Pending
Acknowledged category, not modelled yet — awaiting the delegated act before we add fields.

ESPR · iron-steel

Iron & Steel

Speculative

Fields modelled: 83
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. Dates (delegated act ~Q4 2026, mandatory DPP ~2028) are the current best estimate from the ESPR Working Plan COM(2025) 187 final (CELEX 52025DC0187, adopted 16 April 2025), a Commission Communication that sets no binding obligation. 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.

View category template

ESPR · tyres

Tyres

Draft-aligned

Fields modelled: 95
Effective from: 2028-01-01
Mandatory from: 2029-01-01

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.

View category template

ESPR · electronics

Electronics

Draft-aligned

Fields modelled: 166
Effective from: 2028-01-01
Mandatory from: 2029-01-01

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 — 166 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.

View category template

ESPR · chemicals

Chemicals

Draft-aligned

Fields modelled: 96
Effective from: 2029-09-01
Mandatory from: 2029-09-01

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 for chemical formulations
National variations on declaration thresholds where they diverge from REACH

Notes

Chemicals is the most regulation-mature category in this list — REACH and CLP supply almost the entire data structure. The ESPR delegated act is expected to layer durability and end-of-life metrics on top, not replace REACH.

View category template

ESPR · furniture

Furniture

Speculative

Fields modelled: 80
Effective from: 2029-01-01
Mandatory from: 2030-01-01

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.

View category template

ESPR · jewelry

Jewellery

Speculative

Fields modelled: 52
Effective from: 2030-01-01
Mandatory from: 2030-01-01

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

Jewellery is the furthest-out category in this list. No Commission draft published; the schema reflects RJC + OECD + Kimberley anchors as the most stable proxies. Schema bumps expected once the delegated act surfaces.

View category template

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 is the source of the indicative timelines below. Iron & steel and textiles are early priorities (steel delegated act expected around Q4 2026, mandatory DPP from 2028 — indicative until the act is formally adopted), followed by furniture, tyres, aluminium, and others through 2028–2030. 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. 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; toys around 2030. Each date is fixed by that category's delegated act, 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 becoming mandatory from 2028. Steel also overlaps CBAM reporting, so the data substrate is partly already being collected. Treat the 2028 date as the current best estimate from the ESPR working plan until the delegated act is formally adopted.

Where this fits: see the buyer's guide

/buyers-guide →

Reviewed by Malin Ivanov, Managing Director — on 2026-07-19