If you have looked up when your product category needs a Digital Product Passport, you have probably seen two different years — and both came from official EU sources. Textiles is a good example: some say 2027, others 2029. Neither is wrong. They are measuring two different events, separated by a transition period written into the regulation itself. Planning against the wrong one costs you two years in either direction, and the mistake is easy to make because nothing on either page tells you which event it is describing.
The two events
ESPR — the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 — is a framework. It creates no product data requirements by itself. Every actual DPP obligation arrives through a separate product-specific delegated act, and that two-step structure is what produces the two years.
- Adoption year — when the Commission plans to adopt the delegated act for your product group. This is what the Commission's DPP overview page publishes, taken from the first ESPR Working Plan (COM(2025) 187, adopted 16 April 2025).
- Obligation year — when the requirement actually binds you as a manufacturer or importer. This is what the DG GROW roadmap publishes, and it is the only one that is a deadline.
The bridge: an 18-month floor in Article 4
ESPR Article 4 says a delegated act's date of application "shall not be earlier than 18 months from its entry into force" (entry into force is roughly 20 days after publication in the Official Journal). So obligation is approximately adoption plus 18 months — and in practice acts have set 18 to 36 months, which is why the gap usually reads as about two years rather than one and a half. Eighteen months is a floor, not a fixed offset: each delegated act sets its own date of application.
Same category, two published years
| Category | Adoption year (overview page) | Obligation year (roadmap) |
|---|---|---|
| Iron & steel | 2026 | 2028 |
| Textiles | 2027 | 2029 |
| Tyres | 2027 | 2029 |
| Aluminium | 2027 | 2029 |
| Furniture | 2028 | ~2030 |
| Mattresses | 2028–2029 | ~2030–2031 |
| ICT / electronics | ~2029 | ~2029–2030 |
Iron and steel is the cleanest illustration: adoption 2026, obligation 2028 — exactly one transition period. ICT and electronics is the muddiest, because parts of it transition from the older Ecodesign Directive rather than starting fresh under ESPR.
Batteries are the exception — and the only hard date
How to read any date you are given
When a source quotes an ESPR category year, ask which event it measures. If it does not say, assume it is the adoption year — that is the number the Commission's overview page shows, and it is the one most commonly repeated by vendors and trade press. Then add roughly two years to get the year you should actually plan against, and treat both as indicative: working-plan targets slip, and textiles has already drifted.
The practical consequence is not that you can relax. Whichever year binds you, the work that takes longest is assembling the data — and a large share of it sits with your suppliers, not in your own systems. That part does not get faster because the delegated act slipped a year.
Frequently asked questions
Is the textile DPP deadline 2027 or 2029?
2029 is the year the obligation is expected to bind. 2027 is the year the Commission plans to adopt the textile delegated act. ESPR Article 4 requires at least 18 months between a delegated act entering into force and applying, and acts have in practice set 18 to 36 months. Both years appear in official EU material because they measure different events.
Which EU source gives the obligation year rather than the adoption year?
The DG GROW roadmap publishes obligation years — when the requirement binds economic operators. The Commission's DPP overview page publishes adoption years from the first ESPR Working Plan (COM(2025) 187). If a source does not say which it means, it is most often the adoption year.
Does the adoption-versus-obligation gap apply to the battery passport?
No. The battery passport deadline of 18 February 2027 is set directly by Article 77 of Regulation (EU) 2023/1542, a standalone regulation rather than an ESPR delegated act. There is no transition period to add and no working plan that can move it.
Can these dates still change?
The ESPR category years can, and have — textile timing has already drifted. They are indicative working-plan targets, not statutory dates, and each delegated act sets its own date of application when adopted. The battery date is different: it is fixed in the text of Regulation (EU) 2023/1542.
Ready to publish your Digital Product Passports?
TracePass is live. Create an account, upload a product, and ship a compliant passport with a GS1 QR code today.
Get started