regulations

ESPR DPP implementation status 2026: Standards, Registry and Open Gaps

September 2026 ESPR DPP status: harmonised standards, the adopted DPP Registry framework, sector timelines and the main open gaps.

3/18/2026 · 10 min read · InfoDPP

DPP standards, July 2026: Decision (EU) 2026/1736 published the references to EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223 on 15 July. Applying them supports a presumption of conformity with the ESPR requirements they cover. The earlier extension of the standardisation request was adopted as Decision C(2025) 8024. FprEN 18239 and FprEN 18246 are outside this six-standard package. Full explanation →

Editorial update, 22 July 2026: Commission Implementing Regulation (EU) 2026/1778, adopted on 16 July and published on 17 July, sets the legal operating framework for the DPP Registry. On 20 July, the Commission announced that the Registry was operational and that registration was available through a secure interface or API. The Regulation covers identity verification, model, batch or item registration, technical checks, versioning, the semantic repository and the list of verified DPP service providers, and it entered into force on 6 August 2026. This does not create a blanket DPP obligation or itself define sector-specific schemas and access rights. See the Registry analysis.

Preparing for February 2027: use Registry user guide v1.03, dated 16 September 2026, to prepare organisation verification and product identifiers. Section 6.2.1 says battery-passport registration cannot yet complete because the battery semantic catalogue has not been defined; check the latest guide before testing that step. The Commission’s indicative timeline places the battery access-rights implementing act in Q4 2026, whereas Article 77(9) set 18 August 2026 as the deadline for its adoption. This planning update does not change the 18 February 2027 passport obligation for LMT batteries, industrial batteries above 2 kWh and EV batteries placed on the market or put into service. Prepare the Annex XIII data and access roles now, using the Commission’s battery data-point guidance as implementation support.

Beyond the Regulation Text: Where Does DPP Implementation Actually Stand?

The ESPR framework regulation has been in force since July 2024. The first Working Plan 2025–2030 identifies priority product groups. Battery passport obligations under Regulation (EU) 2023/1542 begin in February 2027. Together, these measures provide the starting point for implementation.

What is less clear, and harder to find in one place, is the status of the technical and administrative arrangements that support DPP implementation: harmonised standards, a central registry, the Ecodesign Portal, data-carrier specifications, and the underlying IT infrastructure.

This article maps the current state of each building block after the September 2026 updates and separates what is confirmed from what is still in progress.

Implementation milestones from spring and summer 2026: these announcements show how the standards and Registry work developed; the September update above gives the current planning context:

six JTC 24 DPP standards were published as EN standards in May 2026; FprEN 18239 on access rights, information-system security and business confidentiality, and FprEN 18246 on data authentication, reliability and integrity are not yet published EN standards

a dedicated CEN-CENELEC webinar on 25 June 2026 introduced the six published JTC 24 standards with guidance on becoming DPP-compliant

Commission Implementing Regulation (EU) 2026/1778 was adopted on 16 July and published on 17 July; it gives the registry an interface, API, verification, logging, versioning and semantic-repository framework

the production Registry, a separate testing environment and implementation resources became available on 20 July 2026; the Commission describes registration as available through a secure interface or API, while product-specific use still depends on the applicable semantic catalogue and sector rules

DG GROW’s 27 May 2026 webinar outlined planned secondary-legislation and Registry milestones for batteries in June/July 2026

the same webinar timeline places 2028/2029 implementation milestones for construction materials, packaging, mattresses, electronics and digital equipment, tyres, textiles, aluminium and furniture

the timeline also lists horizontal DPP milestones: DPP Registry implementing act and DPP standards implementing decision in June 2026, digital credentials / unique identifiers / repairability in Q2 2027, European Product Act and Circular Economy Act proposals in Q3 2026, and a horizontal recycled-content delegated act in 2029

detergents and toys also appear in the webinar slide, but those mandates had already been confirmed before the webinar by standalone regulations

1. Six DPP EN Standards Published; Two Still Pending

Original standardisation request: C(2024)5423

The Commission issued a formal standardisation request to CEN, CENELEC and ETSI in July 2024, via implementing decision C(2024)5423. The original scope was limited to batteries under Regulation (EU) 2023/1542.

All three European Standardisation Organisations (ESOs) accepted the request. By May 2026, CEN/CENELEC JTC 24 had published six DPP EN standards; their references were then published in the OJEU on 15 July by Implementing Decision (EU) 2026/1736. FprEN 18239 and FprEN 18246 remain in progress, and WI JT024009 should also be monitored.

Historical draft extension: adopted as Decision C(2025) 8024

In September 2025, the Commission circulated a draft implementing decision to extend the standardisation request to cover all ESPR products, not just batteries. The points below describe that historical draft; the amendment was subsequently adopted as Decision C(2025) 8024:

extending the legal basis to ESPR (EU) 2024/1781
moving the draft harmonised standards deadline to March 2026
setting a proposed target date of March 2028 for adoption

Legal basis for the extended request: Decision C(2025) 8024 was adopted on 28 November 2025. Use the adopted amendment and Decision (EU) 2026/1736 when planning standards work; the September 2025 draft records an earlier proposal.

What this means in practice:

The standardisation request has been extended through Decision C(2025) 8024
Six JTC 24 DPP standards were published as EN standards in May 2026 and their references entered the Official Journal on 15 July; the common specifications and DPP standards explainer explains what those standards cover
The two remaining standards are still in progress: FprEN 18239 on access-rights management, information-system security and business confidentiality, and FprEN 18246 on data authentication, reliability and integrity. A further JTC 24 work item, WI JT024009 on dictionary referencing, should also be monitored.
The references of the six standards are published in the Official Journal through Implementing Decision (EU) 2026/1736; remaining FprEN work and sector-specific measures still need monitoring
Product-specific obligations continue to depend on the relevant delegated or implementing act

Standards hierarchy

The adopted standardisation-request amendment confirms a clear hierarchy for standards development:

IEC, ISO, ISO/IEC and existing European standards, first priority
National standards, supplementary
Forum standards, last resort

Full cross-sectoral interoperability is a stated requirement.

OPC Foundation and CEN/CENELEC Liaison Agreement

In late February 2026, CEN/CENELEC signed a formal liaison agreement with the OPC Foundation, one of the key players in Industrial Internet of Things (IIoT) standardisation. The agreement aims to deliver open, scalable, and trusted standards for industrial data exchange, directly relevant to how DPP data will flow between manufacturing systems, supply-chain partners, and the central registry.

This partnership matters because DPP is not only a consumer-facing QR code. For industrial and intermediate products (steel, chemicals, components), DPP data needs to travel through factory automation systems, ERP platforms, and cross-border supply chains. OPC UA (Unified Architecture) is used to exchange data in industrial systems. Aligning it with European DPP standards reduces the risk of fragmented, vendor-specific implementations.

Source: OPC Foundation and CEN/CENELEC Strengthen Cooperation on Digital Product Passport Standardization and CEN/CENELEC announcement.

2. The DPP Registry

Article 13 of the ESPR requires the Commission to establish a DPP registry. Regulation 2026/1778 now implements that requirement as a central registration and verification layer; it is not a central warehouse for the full content of every passport.

What is confirmed

Legal framework adopted: Implementing Regulation (EU) 2026/1778 was adopted on 16 July, published on 17 July and entered into force on 6 August 2026.
Registration mechanics: DPPs are registered through a secure interface or API at the model, batch or item level required by the relevant product law. If more than one Union act applies, the most granular level applies.
Verification: economic operators and eligible value-chain actors must be verified through the eIDAS-based routes in the act. Verification expires at the credential expiry date and no later than three years; an unverified actor cannot create or change a registration.
Technical checks and evidence: the registry validates semantic conformity, relevant DPP/registry-data consistency, granularity and, where relevant, commodity codes; it issues a unique registration identifier, records versions and logs changes. These checks do not prove that a product meets every substantive product-law requirement.
Registry scope: the Commission describes it as holding unique identifiers, registration data and high-level metadata. Detailed passport data remains decentralized with the operator or service provider.
Initial operational availability: the production Registry, a separate testing environment and implementation resources became available on 20 July 2026. The Commission describes the Registry as operational and registration as available through a secure interface or API. Product-specific use, especially battery testing, still depends on the applicable semantic catalogue and sector rules. The operating regulation separately took effect on 6 August.
User guide v1.03 (16 September 2026): the guide explains organisation enrolment and verification. It specifies an https product-identifier URL of up to 2000 characters, a qualified seal or signature created on a qualified device or through a qualified remote service, and batch uploads of up to 100 records. Section 6.2.1 describes battery-passport registration as unavailable pending the semantic catalogue; organisation verification and completed product registration are separate steps.

Sector details to follow

The product-specific DPP fields, access rights and registration level for each sector
Provider-specific onboarding instructions and sector-specific API profiles beyond the horizontal Registry documentation
The final delegated act and any certification scheme for DPP service providers
The timetable and detailed workflow for onboarding each sector beyond the initial production and testing launch
Battery registration readiness: section 6.2.1 of the 16 September guide identifies the missing semantic catalogue as a registration blocker. Follow updates to the guide and catalogue when planning end-to-end tests.

Next steps: organise the required product data, assign responsibility for organisation verification and version history, and test the available workflows. Record which API operations you have actually tested and check them against the relevant sector rules before describing the implementation as compliant.

3. Ecodesign Portal and Green Forum

The Ecodesign Portal is the Commission’s primary public-facing platform for ESPR implementation updates. It connects to the Green Forum, where preparatory work, stakeholder consultation, and sector-specific studies are managed.

Green Forum: preparatory work confirmed

As of March 2026, the Green Forum confirms active preparatory work for several product categories, including:

Textiles: preparatory study underway, first-wave priority
Iron and steel: preparatory study underway, first-wave priority
Electronics, furniture, tyres: scoped in the working plan with indicative timelines

The Green Forum also provides updates on horizontal topics such as data-carrier specifications, DPP technical infrastructure, and label requirements.

What the portal does not yet provide

No product-level DPP creation or submission flow
The Ecodesign Portal itself does not provide a sandbox; the separate DPP Registry test environment is now available, but it requires a separate EU Login, valid organisation data and production-equivalent signature/seal verification, and its objects may be deleted rather than migrated to production
No self-service compliance-checking tool

The portal remains primarily an information source, not an operational platform.

4. Data Carriers: QR Codes, Identifiers, and the “Or Equivalent” Clause

The ESPR requires each DPP to be accessible through a data carrier. The exact placement can depend on the applicable act, but the rules can provide for placement on the product, packaging or accompanying documentation; QR codes are one common machine-readable option, not the whole passport.

Current practical reality

QR codes are the most widely expected data carrier for consumer-facing products
GTIN (Global Trade Item Number) is a practical, low-risk identifier that already fits current market practice and recognised standards frameworks
The regulation preserves an “or equivalent” approach: it does not mandate a single identifier system
The adopted standardisation-request amendment reinforces the standards hierarchy without naming a specific identifier scheme

What to do now

Companies do not need to wait for a final identifier standard to start. Choosing an identifier that is already in use, already interoperable, and already supported by supply-chain systems (such as GTIN) is a defensible and low-risk starting point.

5. Sector-Specific Status: Who Is Closest to a Live DPP?

Sector	Status	Key milestone
Batteries	Most advanced: standalone Battery Regulation + adopted standardisation request	DPP obligation starts 18 February 2027
Textiles	Preparatory study underway, first-wave working-plan priority	Delegated act adoption targeted Q3–Q4 2027; Commission timeline places DPP application in 2029 *
Iron and steel	Preparatory study underway, first-wave working-plan priority	Commission timeline places iron and steel DPP application in 2028; aluminium in 2029 *
Tyres	Included in first working plan	Delegated act expected Q3–Q4 2027; Commission timeline places DPP application in 2029 *
Electronics	Included in working plan, broader scope	Electronics and digital equipment: Commission timeline places DPP application in 2029; broader appliances scope to be confirmed *
Furniture	Included in working plan	Commission timeline places the furniture delegated act in 2028; use date to be confirmed *
Mattresses	Included in working plan + DG GROW webinar timeline	Commission timeline places the delegated act in 2029; application date to be confirmed *
Construction products	Separate CPR track, plus ESPR only where a product is independently covered	The Commission’s current indicative DPP timeline places the CPR delegated act in Q2 2027; it does not by itself fix a universal product-level application date *
Packaging	PPWR labelling and data-carrier requirements	The general application date is 12 August 2026. Digital-labelling measures must not be described as a universal DPP obligation from 2028; check the specific Article 12 requirement and its application conditions.
Detergents	Confirmed before the webinar: standalone Regulation (EU) 2026/405 (not ESPR)	DPP mandatory from 23 September 2029; the webinar repeats the already-known 2029 mandatory group
Toys	Confirmed before the webinar: standalone Toy Safety Regulation (not ESPR)	DPP mandatory from 1 August 2030; outside the 2028/2029 focus but also shown as mandatory in the slide

* Dates marked with * refer to indicative Working Plan targets (COM/2025/187) and official DG GROW webinar timeline entries, not adopted sectoral law. “Adoption” = when the delegated act is adopted; “application” = when DPP obligations become mandatory.

For a detailed timeline, see: ESPR Timeline 2026–2030

6. Remaining Implementation Questions

As of 20 September 2026, the following points require attention when planning an implementation.

Commission-cited DPP standards and the remaining package: the Official Journal references for six EN standards are published; as of 20 September 2026 no citation of EN 18239 and EN 18246 has appeared, the Commission’s timeline still indicates September 2026, and WI JT024009 also needs to be tracked
Complete onboarding material for each user group: the Commission provides the economic-operator guide, technical documentation, API access and a semantic repository, but provider-specific onboarding and product-group materials are still being expanded
Several secondary measures: the Registry regulation is now adopted; the service-provider delegated act, future identifier/data-carrier measures and product-specific acts remain separate tracks
Portal and Registry roles: an information portal is not a product-passport submission service. The Registry has a separate production and test workflow; an operational submission feature in the Ecodesign Portal is not itself an ESPR legal requirement.
Identifier choices: the law and cited standards set requirements without imposing GS1 or GTIN as a universal brand or scheme. The absence of a single mandatory commercial scheme is not an implementation gap.
Product-specific ESPR acts: preparation remains product-specific. This does not mean that non-battery passport laws are absent: toys, detergents, construction products and vehicles have separate legislative frameworks.

7. What Companies Should Do Now

Companies can take the following steps while implementation details are being completed:

Structure your product data: composition, carbon, traceability, recycled content, and supplier evidence. Keeping these records organised will help when applying the relevant technical requirements.
Choose an identifier early: GTIN or an equivalent established scheme. Switching later is expensive; starting with something interoperable is low-risk.
Pilot with a self-service platform: solutions like OriginPass.eu allow you to create Digital Product Passports now, without waiting for the full EU infrastructure to go live.
Monitor the Green Forum: it provides updates on preparatory studies and the development of delegated acts.
Be specific about compliance claims: identify the product, applicable legal act, application date and requirements actually demonstrated. Conformity to a cited standard is not a certificate of full product-law compliance, but neither does pending legislation prevent an operator from demonstrating compliance with requirements already applicable.

Official Sources

Ready to create your first digital product passport? Try OriginPass.eu and start with one product.

← Back to Blog