Does my product need a Digital Product Passport right now?

Almost certainly not yet. The nearest obligation is the battery passport: EV, light-means-of-transport and industrial batteries above 2 kWh placed on the EU market need one from 18 February 2027. Detergents follow on 23 September 2029, toys on 1 August 2030, and cars and vans on 1 September 2032, each under its own regulation. For every other product, a DPP only becomes mandatory once the European Commission adopts the ESPR delegated act for its group, and none has been adopted yet.

What is the first hard DPP deadline?

The battery passport under the EU Battery Regulation (EU) 2023/1542, mandatory from 18 February 2027 for EV, LMT, and industrial batteries with a capacity above 2 kWh. It is the first of four dates already fixed in law — detergents (23 September 2029), toys (1 August 2030) and cars and vans (1 September 2032) follow. All ESPR product-group dates still depend on delegated acts.

What is the EU DPP Registry, and is it live?

It is a directory set up under Article 13 of ESPR, operational since July 2026 but not yet accepting passports for any product group, that maps a product's unique identifier (via GS1 Digital Link) to the location of its passport. It does not store the passports themselves and does not by itself make any group's DPP mandatory; each group's obligation still comes from its own delegated act.

Should I prepare before my group has a fixed date?

Yes. The slow part of a DPP is collecting accurate, source-attributed data, much of it from upstream suppliers, which takes months regardless of the legal date. Tools like TracePass let you extract regulated fields from existing documents with confidence scores and source links, route missing data through a supplier portal, and publish GS1 Digital Link QR passports now.

When Does My Product Need a DPP? ESPR Timeline by Group

Q: When will textiles need a DPP?

Textiles and apparel are a priority group in the ESPR working plan, which schedules adoption of the textile delegated act for 2027. As a rule, the act applies at least 18 months after it enters into force (ESPR Art. 4(4) allows earlier only in duly justified cases), so a textile DPP obligation normally lands around 2029 at the earliest. Until the act is published in the Official Journal, any specific textile DPP date should be treated as an expectation.

Q: How do I find the DPP date for my specific product?

First check whether a law already sets a passport for your product — batteries, detergents, toys, and cars and vans each have one with a fixed date. Otherwise classify your product against the ESPR working plan and check whether a delegated act has been adopted for that group. If one exists, read its application date and transition period; if none exists yet, you have no obligation today, only a roadmap. Re-check periodically, since acts are adopted on a rolling basis through roughly 2026 to 2030.

Most products do not need a Digital Product Passport (DPP) yet. Four EU laws already fix a passport date in their own text: batteries from 18 February 2027 (Regulation (EU) 2023/1542), detergents from 23 September 2029 (Regulation (EU) 2026/405), toys from 1 August 2030 (Regulation (EU) 2025/2509), and cars and vans from 1 September 2032 (Regulation (EU) 2026/1738 on end-of-life vehicles). Everything else waits on the ESPR (Regulation (EU) 2024/1781), which switches the DPP on one product group at a time through delegated acts, and none has been adopted yet. To answer "does my product need a DPP, and by when", check those four laws first, then track your ESPR group's delegated act.

Most products do not need a Digital Product Passport (DPP) yet, and when yours will depends on which law reaches it. Four laws already fix a passport date in their own text: batteries (EV, LMT and industrial above 2 kWh) from 18 February 2027 under the Battery Regulation (EU) 2023/1542; detergents from 23 September 2029 under the Detergents Regulation (EU) 2026/405; toys from 1 August 2030 under the Toy Safety Regulation (EU) 2025/2509; and cars and vans from 1 September 2032 under the End-of-Life Vehicles Regulation (EU) 2026/1738. For everything else, the EU's Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) introduces the DPP product group by product group, each activated by its own delegated act, and no such act has been adopted yet. To know whether your product needs a DPP, check those four laws first, then identify your ESPR priority group and track its delegated act.

How ESPR decides which products need a DPP

ESPR is a framework regulation: it is already in force, but it does not impose DPP obligations on any product on its own. Instead, the European Commission selects priority product groups and then issues a separate delegated act for each one. That delegated act is what actually defines the ecodesign requirements, the exact data fields the passport must carry, the carrier (a QR or data-carrier linked via GS1 Digital Link), and the application date. So the practical question is never just "does ESPR apply to me" but "has a delegated act been adopted for my product group, and what date does it set".

Batteries: the first hard deadline (18 February 2027)

Batteries are governed not by ESPR but by the standalone EU Battery Regulation (EU) 2023/1542, and they are first in line. From 18 February 2027, every EV battery, light means of transport (LMT) battery, and industrial battery with a capacity above 2 kWh placed on the EU market must carry a digital battery passport accessible via a QR code. The passport must hold structured data on the manufacturer, material composition, performance and durability over the battery's life, and end-of-life and recycling information; carbon-footprint, recycled-content and due-diligence data join it as those requirements start to apply. If you place these batteries on the market, this is a fixed legal date, not a projection.

Detergents, toys, cars and vans: dates already fixed in their own laws

Three more product groups get a passport from a law that already sets the date, with no ESPR delegated act needed. Detergents and end-user surfactants need one from 23 September 2029 under the Detergents Regulation (EU) 2026/405; its content list is Annex VI Part A, and the full list of intentionally added substances does not apply to industrial and institutional detergents covered by a safety data sheet. Toys need one from 1 August 2030 under the Toy Safety Regulation (EU) 2025/2509, where the passport takes over the role of the declaration of conformity. Cars and vans (vehicle categories M1 and N1) need a digital vehicle passport from 1 September 2032 under the End-of-Life Vehicles Regulation (EU) 2026/1738, one per vehicle. These dates are in adopted law, so they are obligations to plan against, not projections.

The ESPR priority groups and what we know about their dates

The ESPR working plan (COM(2025) 187) names the product groups the Commission will regulate first, with an indicative year for adopting each delegated act: iron and steel in 2026; textiles and apparel, tyres and aluminium in 2027; furniture in 2028; mattresses in 2029. These are adoption years, not deadlines. As a rule, a delegated act applies at least 18 months after it enters into force (ESPR Art. 4(4) allows earlier only in duly justified cases), so obligations normally land around two years later at the earliest, and indicative years can slip. Electronics and ICT are not a product group of their own in this plan: they are covered by two horizontal measures, on repairability (2027) and on recycled content and recyclability of electrical and electronic equipment (2029). Detergents, paints and lubricants were listed as candidates in ESPR but left out of the plan; detergents get their passport from their own regulation instead. Treat any calendar date quoted for an ESPR group as an expectation until the act is published in the Official Journal.

Batteries (EV, LMT, industrial >2 kWh) — mandatory 18 February 2027 under Reg (EU) 2023/1542. Hard-dated.
Detergents and end-user surfactants — mandatory 23 September 2029 under Reg (EU) 2026/405. Hard-dated; not in the ESPR working plan.
Toys — mandatory 1 August 2030 under Reg (EU) 2025/2509. Hard-dated.
Cars and vans (M1, N1) — vehicle passport mandatory 1 September 2032 under Reg (EU) 2026/1738. Hard-dated.
Iron and steel — ESPR delegated act planned for 2026; as a rule, obligation at least 18 months after it enters into force (ESPR Art. 4(4) allows earlier only in duly justified cases).
Textiles and apparel, tyres, aluminium — ESPR delegated acts planned for 2027; obligations around 2029 at the earliest.
Furniture (2028) and mattresses (2029) — ESPR adoption years; obligations later still.
Electronics and ICT — no product-group act; covered by horizontal ESPR measures on repairability (2027) and on recycled content and recyclability (2029).

A four-step method to find your group and your date

You can answer "does my product need a DPP and by when" yourself with a repeatable check. First, check whether a law already gives your product a passport with a fixed date — batteries, detergents, toys, and cars and vans each have one — and otherwise classify it against the ESPR working plan. Second, find whether a delegated act has been adopted for that group; if none exists yet, you have no DPP obligation today, only a roadmap to watch. Third, read the application date and transition period in that act, since obligations typically apply to products placed on the market from a stated date. Fourth, re-check periodically, because delegated acts are adopted on a rolling basis through roughly 2026 to 2030.

The EU DPP Registry is live — but passports cannot be registered yet

The EU DPP Registry, set up under Article 13 of ESPR, has been operational since July 2026, with its rules in Implementing Regulation (EU) 2026/1778. The registry is a directory, not a data store: it records each passport's unique identifiers and, for products entering free circulation, the customs commodity code, while the passport itself stays hosted by the manufacturer or their platform. Operators can already enrol, but no product group can register passports yet — the Commission has published the battery data model that registration checks each passport against, but the registry's check against it is not yet switched on, and the Commission has said registration will be available to economic operators from February 2027. The registry being live does not by itself make any product group's DPP mandatory — that still depends on each group's delegated act — but it is the backbone every passport will plug into.

Why early preparation pays even without a fixed date

The hardest part of a DPP is rarely the QR code — it is assembling accurate, source-attributed product data, much of which sits with upstream suppliers. That work takes months regardless of the legal date, so the absence of a final deadline for your group is not a reason to wait. This is where TracePass helps: you upload the documents you already hold — datasheets, certificates, EPREL entries — and the AI extracts and fills the regulated fields, each with a confidence score and a link back to its source. A human reviews and approves before anything is published, and a supplier portal collects the missing upstream data you cannot fill yourself.

TracePass is EU-hosted, with plans that scale from a Free tier (3 passports) to Basic at €49/mo and Starter at €350/mo, with AI extraction metered on every tier — and there is no per-scan or per-SKU billing, so a passport that gets scanned a million times costs the same as one that is never scanned. Early adopters such as the jewellery brand Vantony use it to publish GS1 Digital Link QR passports today, building the data discipline now that any future delegated act will demand.