Do Lamps Need a Digital Product Passport?

If you manufacture or import lamps for the EU market, you may have seen references to a "2029 DPP deadline" for electronics or lamps. That date is not a confirmed obligation — 2029 is the ESPR working plan's indicative adoption year for the horizontal measure on electrical and electronic equipment, not a date any obligation applies from, and the underlying delegated act that would make a lamp DPP legally mandatory has not been adopted. Here is what the law actually says today, and what to watch.

Do lamps legally need a DPP right now?

No. Lamps are electrical and electronic equipment (EEE), and EEE falls under the Ecodesign for Sustainable Products Regulation (ESPR — Regulation (EU) 2024/1781). However, ESPR does not set DPP requirements by itself. The regulation provides the legal framework and Article 4 delegated acts are the mechanism through which specific product obligations — including a Digital Product Passport — become mandatory. No delegated act has been adopted for lamps or for EEE generally, so no lamp DPP is legally required today.

When might a lamp DPP become mandatory?

ICT products are not a discrete product-group act in the ESPR working plan (2025–2030); they are covered by the horizontal 'recycled content and recyclability of electrical and electronic equipment' measure, with an indicative adoption year of around 2029 per the working plan (COM(2025) 187). That figure — 2029 — is an estimate in a planning document, not a legal deadline. The delegated act itself sets the date, and it has not been adopted. Until the Commission formally adopts an EEE delegated act, the 2029 figure remains a planning estimate only.

What about the battery in a rechargeable lamp?

This is a separate matter governed by a separate regulation. If a lamp contains a battery that falls in scope of the EU Battery Regulation (Regulation (EU) 2023/1542), that battery requires its own digital passport under Article 77 from 18 February 2027. The key scoping questions are battery type and capacity: LMT batteries above 25 V or 250 W, industrial batteries above 2 kWh, and EV batteries are in scope. Most consumer lamp batteries are small lithium cells well below the industrial threshold, so they are outside the February 2027 battery-passport obligation — but verify the category and capacity for your specific product. The lamp itself has no DPP obligation today regardless of the battery.

What can you do now?

There is no legal requirement to act on a lamp DPP today. What you can reasonably do is prepare: understand the electronics category template — TracePass models 160 fields for the EEE/electronics category against the ESPR framework and EPREL — so you know what data will eventually be needed and where it sits in your supply chain. Monitor the Commission's ESPR working plan updates for any advancement of the EEE delegated act. And, if your lamp contains an in-scope battery, address the Battery Regulation passport obligation now, as that date — 18 February 2027 — is fixed.

Frequently asked questions

Do lamps need a Digital Product Passport under EU law?

Not today. Lamps are EEE under ESPR (Regulation (EU) 2024/1781), but ESPR itself sets no DPP requirements — obligations are created only by product-specific delegated acts under Article 4. No such delegated act has been adopted for lamps or electronics, so no lamp DPP is legally mandatory at this time.

When will the lamp / electronics DPP become mandatory? Is there a date yet?

No date exists yet — nothing to comply with and nothing to miss. The word "lamp" does not appear anywhere in the text of ESPR (Regulation (EU) 2024/1781), and lighting is not named in the first working plan's priority list, which covers iron and steel, aluminium, textiles, furniture, tyres, detergents, paints, lubricants, chemicals, and ICT/electronics. ICT products are covered in the working plan via the horizontal EEE recycled-content/recyclability measure, with an indicative adoption year of about 2029 — but that is an indicative estimate in a planning document, not a legal deadline. The mandatory date is set by the delegated act itself, which has not yet been formally proposed or adopted. Any source quoting a firm lamp DPP deadline is citing a planning estimate as if it were law.

Does the battery in a rechargeable lamp need a DPP?

It depends on the battery's category and capacity. The EU Battery Regulation (2023/1542) requires a digital battery passport from 18 February 2027 for EV batteries, industrial batteries above 2 kWh, and LMT batteries above 25 V or 250 W. Most consumer lamp batteries are small lithium cells below the industrial threshold, so typically outside this obligation — but verify for your specific product.

Should I start preparing a lamp DPP now?

There is no legal requirement to act today. Practical preparation means understanding the electronics category template and the data it will require from your supply chain, monitoring the ESPR working plan for the EEE delegated act, and — if applicable — addressing the Battery Regulation passport requirement for any in-scope battery, which does have a firm deadline of 18 February 2027.