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

Most products do not need a Digital Product Passport (DPP) yet. 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. The one firmly dated obligation today is the battery passport: mandatory from 18 February 2027 under the EU Battery Regulation (EU) 2023/1542. For every other priority group (textiles and apparel, electronics and ICT, furniture, iron and steel, tyres, detergents), DPP requirements are expected under the ESPR working plan but most exact dates are not yet final and await delegated acts. To know whether your product needs a DPP, identify your ESPR product group, then track the delegated act that sets its rules and timeline.

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 one 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 origin, material composition, carbon footprint, performance over the battery's life, and end-of-life and recycling information. If you place these batteries on the market, this is a fixed legal date, not a projection.

The ESPR priority groups and what we know about their dates

The ESPR working plan names the product groups the Commission intends to address first. Textiles and apparel are explicitly a priority group, and first textile DPP requirements are commonly cited for roughly 2027 to 2028 — but they are not yet hard-dated, because the delegated act has not been finalised. The same caution applies across the board: these groups are on the roadmap, but their precise application dates depend on delegated acts that are still in preparation. Treat any single calendar date you see quoted for non-battery groups as an expectation, not a settled obligation, until the relevant act is published in the Official Journal.

• Batteries (EV, LMT, industrial >2 kWh) — mandatory 18 February 2027 under Reg (EU) 2023/1542. Hard-dated.
• Textiles and apparel — priority ESPR group; first requirements expected ~2027-2028 under the working plan, exact date awaits the delegated act.
• Electronics and ICT — named priority group; timeline expected under the ESPR working plan, not yet hard-dated.
• Furniture — named priority group; timeline expected under the ESPR working plan, not yet hard-dated.
• Iron and steel — named priority group; timeline expected under the ESPR working plan, not yet hard-dated.
• Tyres and detergents — named priority groups; timelines expected under the ESPR working plan, not yet hard-dated.

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, classify your product against the ESPR working plan and the Battery Regulation scope — batteries are governed separately. 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 2027 to 2030.

The EU Central DPP Registry goes live 19 July 2026

One date that is fixed for everyone is the launch of the EU Central DPP Registry, scheduled to be operational from 19 July 2026 under Article 13 of ESPR. The registry is a directory, not a data store: given a product's unique identifier via GS1 Digital Link, it returns the location of that product's passport, which remains hosted by the manufacturer or their platform. It will also hold unique identifiers and customs commodity codes for products entering free circulation. The registry going 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, which adds AI extraction — 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.