Digital Product Passport deadlines

Dates that are already law, dates the Commission has committed to, and dates that are still indicative. The distinction matters — plan against the first category, watch the second, and do not build a project schedule on the third.

How to read this. Entries marked in force come from published legislation with a binding date. Entries marked indicative come from the ESPR working plan or Commission communications — the direction is firm, the exact date is not, and delegated acts have slipped before.

  1. 17 August 2023 Batteries Regulation (EU) 2023/1542 enters into force. The battery passport is created here, ahead of and separately from ESPR — which is why batteries are the first product group most merchants meet.
  2. 18 July 2024 ESPR — Regulation (EU) 2024/1781 — enters into force. The framework that creates the Digital Product Passport. It repeals the old Ecodesign Directive from the same date, though parts of the Directive survive for 19 named product groups until 31 December 2026.
  3. 18 August 2024 Battery Regulation Chapter VI — economic operator obligations — starts to apply. If you sell batteries, duties have already been live for nearly two years.
  4. 16 April 2025 First ESPR working plan adopted (COM(2025) 187), covering 2025–2030 with a mid-term review in 2028. It names the priority product groups — and drops several that the ESPR framework had listed as candidates.
  5. 20 June 2025 Ecodesign and energy-labelling rules for smartphones and tablets apply. Notable as the closest working precursor to a DPP: a regulator-run database (EPREL), populated before market, exposed through an on-product QR code, with a mandatory repairability class.
  6. 18 August 2025 The old Batteries Directive 2006/66/EC is repealed. Separate-collection and Cd/Pb labelling symbols become mandatory.
  7. 9 February 2026 Secondary legislation on unsold consumer goods adopted — a delegated regulation setting out the ten grounds for derogation, and an implementing regulation fixing the disclosure format.
  8. 27 May 2026 The first six European standards for the Digital Product Passport are published by CEN/CLC/JTC 24 — covering data exchange, unique identifiers, data carriers, storage and persistence, lifecycle APIs and system interoperability. EN 18219 and EN 18220 are the ones that decide what your QR code and identifier scheme have to look like.
  9. 16 July 2026 Commission Implementing Regulation (EU) 2026/1778 adopted, setting the operating rules for the DPP registry — who may register, identity verification, automated checks and retention.
  10. 19 July 2026 The ESPR ban on destroying unsold apparel, clothing accessories and footwear takes effect for large enterprises, together with the annual public disclosure duty for discarded unsold goods. Micro and small enterprises are out of scope; medium-sized enterprises follow on 19 July 2030. This is currently the most immediately enforceable ESPR obligation for a clothing retailer — and it is not a passport obligation at all.
  11. 20 July 2026 The EU Digital Product Passport Registry goes live, with a testing environment, a free semantic repository of machine-readable data models, API and UI registration, and a helpdesk. Note carefully: this was the Commission's deadline to build the registry, not a date by which anyone must register a product.
  12. 12 August 2026 The Packaging and Packaging Waste Regulation (EU) 2025/40 starts to apply. Relevant here because reusable packaging must carry reusability information through a QR or digital code — a second data carrier on the same parcel, governed by a different regime.
  13. 18 August 2026 Three battery acts fall due: the implementing act defining who has a “legitimate interest” in restricted passport data, the recycled-content calculation methodology, and the labelling implementing act. None had been adopted as of 21 July 2026, and the legitimate-interest act is expected to slip to Q4 2026.
  14. 27 September 2026 Directive (EU) 2024/825 on empowering consumers for the green transition applies — banning generic environmental claims and offsetting-based carbon-neutrality claims. This, not the stalled Green Claims Directive, is the operative anti-greenwashing regime, and it governs the sustainability copy on your product pages.
  15. 30 December 2026 EU Deforestation Regulation applies to large and medium operators and traders, after a second delay. Micro and small enterprises follow on 30 June 2027.
  16. 31 December 2026 The Ecodesign Directive carve-out ends for the 19 product groups still running under the old regime.
  17. During 2026 Iron and steel delegated act — indicative. With under six months of the year left and no draft published, treat this as at risk of slipping.
  18. 18 February 2027 The battery passport becomes mandatory. Every LMT battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the market must carry an electronic record reachable via a QR code. Battery removability rules and the QR requirement on all batteries start the same day. This is the first hard DPP deadline for most merchants.
  19. 2 March 2027 The standardised disclosure template for unsold consumer goods applies — 50+ product categories, commodity codes, and statements from waste treatment operators.
  20. During 2027 Textiles and apparel, tyres, aluminium and the horizontal repairability requirements are all indicatively scheduled for their delegated acts. Adoption of the act is not the compliance date — obligations typically follow around 18 months later.
  21. 18 August 2027 Battery due diligence obligations apply, after being pushed back two years by Regulation (EU) 2025/1561. Operators below EUR 40 million net turnover are exempt.
  22. During 2028 Furniture delegated act indicatively scheduled, alongside EV chargers, electric motors and several refrigeration categories. The ESPR working plan itself gets a mid-term review this year.
  23. During 2029 Mattresses, and the horizontal requirements on recycled content and recyclability of electrical and electronic equipment.
  24. 19 July 2030 The unsold-goods destruction ban and disclosure duty extend to medium-sized enterprises.
  25. 18 August 2031 First mandatory recycled-content thresholds for batteries: 16% cobalt, 85% lead, 6% lithium, 6% nickel. Unlike the carbon footprint rules, these are hard dates that a late methodology act does not automatically postpone.

What to do with these dates

The temptation is to work backwards from the deadline and start when the delegated act is published. That fails, because the long pole is not building the passport — it is getting the data out of your suppliers.

Recycled content percentages, substance declarations and carbon footprint figures generally do not exist in the format you need. Somebody upstream has to produce them, often from their own upstream. A request that takes an afternoon to send takes six to eighteen months to come back across a full supplier base, and the suppliers who are slowest to answer are usually the ones whose data you most need to check.

Start the supplier conversation a year before you think you need to. The schema work can wait; the data collection cannot.

The readiness checklist