ESPR DPP in March 2026: Standards, Registry and Open Gaps
What is actually in place for ESPR DPP in March 2026: standards work, registry status, the Ecodesign Portal and the main open gaps.
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. These facts are well-known.
What is less clear — and harder to find in one place — is the status of all the implementation building blocks that must exist before a Digital Product Passport can actually work at scale: 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 as of March 2026 and separates what is confirmed from what is still in progress.
1. Harmonised Standards: CEN/CENELEC/ETSI Work in Progress
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, and technical standardisation work is underway.
Draft extension to full ESPR scope — not yet adopted
In September 2025, the Commission circulated a draft implementing decision that would extend the standardisation request to cover all ESPR products — not just batteries. The draft proposed:
- 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
Status as of March 2026: this draft has not been formally adopted. It still appears under “Possible future standardisation requests” on the DG GROW Notification System, with an expired feedback deadline. It has not moved to the adopted section.
What this means in practice:
- The original decision C(2024)5423 remains the only legally binding standardisation request
- Standardisation work for batteries continues as planned
- The full ESPR-scope extension is a strong signal of direction, but is not yet law
- Final harmonised standards for DPP across all ESPR product groups should not be expected before 2028 at the earliest
Standards hierarchy
The draft 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 already the dominant protocol in smart manufacturing. 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 — a central database where all product passports must be registered and discoverable.
What is confirmed
- The legal obligation to create the registry exists in the regulation text
- The registry will act as a central hub protecting trade secrets and managing access rights (market surveillance, customs, operators, citizens)
- Go-Live Date: Under Article 13 of the ESPR, the Commission is legally obligated to make the registry operational by 19 July 2026.
- Technical development and public consultations are ongoing to select the IT infrastructure provider
What is not yet public
- No public beta, demonstrator, or API documentation has been released as of March 2026
- The registry’s data model, authentication framework, and access-rights structure remain under development
- The technical specifications and exact architecture of the registry have not yet been fully published
Practical takeaway: companies should prepare data structures that can be registered later, rather than wait for registry-level integration. The registry interface will come — the data work cannot be deferred.
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
- No formal test environment or sandbox for companies
- 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 placed on the product or its packaging. The regulation mentions QR codes and other machine-readable formats.
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 draft standardisation request reinforces 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 ~2027 (Working Plan) * |
| Iron and steel | Preparatory study underway, first-wave working-plan priority | DPP application expected ~2028–2029 (adoption targeted 2026) * |
| Tyres | Included in first working plan | Indicative 2027 window |
| Electronics | Included in working plan, broader scope | Delegated acts expected 2028–2030 |
| Furniture | Included in working plan | Expected from approximately 2030 |
| Building materials | Dual track — ESPR watchlist + CPR Working Plan 2026–2029 | CPR delegated acts in progress, ESPR review ~2028 |
| Detergents | Confirmed — standalone Regulation (EU) 2026/405 (not ESPR) | DPP mandatory from 23 September 2029 |
| Toys | Confirmed — standalone Toy Safety Regulation (not ESPR) | DPP mandatory from 1 August 2030 |
For a detailed timeline, see: ESPR Timeline 2026–2030
6. What Is Still Missing: Honest Gaps
To avoid over-claiming: the following elements are not yet in place as of March 2026.
- Adopted harmonised standards for DPP under ESPR — the draft extension exists but has not been formally adopted; only the battery-scope request (C(2024)5423) is binding
- A public DPP registry — legally required, under development, but not operational
- A live Ecodesign Portal with submission capabilities — the portal exists as an information source, not as a compliance tool
- A single mandatory identifier standard — the regulation allows for equivalence; no single system has been mandated
- Final delegated acts for any non-battery product group — all first-wave sectors are still in the preparatory or indicative-timeline stage
7. What Companies Should Do Now
The implementation gaps above do not mean inaction is the right strategy. In fact, the opposite is true:
- Structure your product data — composition, carbon, traceability, recycled content, and supplier evidence. This work is the same regardless of which standard or registry emerges.
- 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 allow you to create Digital Product Passports now, without waiting for the full EU infrastructure to go live.
- Monitor the Green Forum — this is the best real-time signal for when preparatory work transitions into formal delegated acts.
- Do not over-claim compliance — no company can today claim “full ESPR DPP compliance” because the full compliance framework does not yet exist. What companies can do is demonstrate data readiness and intention.
Official Sources
- ESPR Regulation (EU) 2024/1781
- European Commission ESPR Working Plan 2025–2030
- Green Forum — Implementing Ecodesign for Sustainable Products Regulation
- Battery Regulation (EU) 2023/1542
- DG GROW Standardisation Notification System
- CPR — Regulation (EU) 2024/3110
- Toy Safety Regulation (EU) 2025/2509
- Detergents Regulation (EU) 2026/405
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