ESPR applies to virtually all physical products placed on the EU market. The first product groups and the adjacent sectors already worth monitoring:
Apparel: act adoption planned Q4 2027; DPP application date not fixed
Source: working plan COM(2025) 187 and current Commission DPP portal
Textiles, particularly apparel. Footwear has a separate preparatory track.
Commission timeline places the delegated act in 2028; use date to be confirmed *
Source: working plan COM(2025) 187 and current Commission DPP portal
Wooden and upholstered furniture. Wood certification, durability scores, and recyclability data.
Commission timeline places the delegated act in 2029; use date to be confirmed *
Source: working plan COM(2025) 187 and current Commission DPP portal
Mattresses are listed separately in the first ESPR Working Plan. Prepare material, durability and end-of-life data early.
Battery passport obligations start 18 February 2027
Source: Regulation (EU) 2023/1542
Battery passport obligations start from February 2027 for categories covered by the Battery Regulation.
Planned adoption: steel Q4 2026, aluminium Q3–Q4 2027; DPP application not fixed
Source: working plan COM(2025) 187 and current Commission DPP portal
Primary metals and metal products. Carbon footprint tracking, recycled content, and supply chain traceability for carbon-intensive materials.
ICT: measures planned for adoption in 2029; no common electronics/appliance DPP deadline
Source: working plan COM(2025) 187 and current Commission DPP portal
Consumer electronics and appliances. Right to repair, spare parts availability, and energy efficiency.
CPR: DPP act planned Q2 2027; duty dates depend on applicable provisions
Source: CPR 2024/3110 and current Commission DPP portal
Construction products and materials. CPR GWP reporting obligations are already in force since January 2026; DPP delegated acts are planned under the CPR Working Plan 2026–2029.
PPWR duties; no confirmed full packaging DPP date
Source: PPWR data-carrier rules; DG GROW timeline, 27 May 2026
PPWR already creates packaging-law duties for labelling, selected digital data carriers and the one-data-carrier principle. The DG GROW timeline also places a packaging DPP milestone in 2028, but a future act is still needed before this becomes a confirmed DPP obligation.
Act adoption planned Q3–Q4 2027; DPP application date not fixed
Source: working plan COM(2025) 187 and current Commission DPP portal
Tyres are included in the first ESPR working plan with an indicative 2027 window, but exact duties still depend on the delegated act.
DPP mandatory from 1 August 2030 (Toy Safety Regulation)
Source: Regulation (EU) 2025/2509
The Toy Safety Regulation mandates a Digital Product Passport for toys from 1 August 2030. Composition, safety documents, and traceability data are required.
DPP mandatory from 23 September 2029 (Regulation (EU) 2026/405)
Source: Regulation (EU) 2026/405
Regulation (EU) 2026/405 applies from 23 September 2029 to detergents and end-user surfactants. Model-level DPP, UFI, ingredient disclosure, refill logic and poison-centre data.
No confirmed cosmetics DPP date; prepare formula, CPNP, label and surveillance data
Source: EU cosmetics portal, CPNP, CosIng and Safety Gate
Cosmetic products do not have a confirmed DPP obligation yet, but EU rules already require product documentation, safety, CPNP, labelling and market-surveillance records that need to stay consistent.
Circularity Vehicle Passport mandatory from 1 September 2032; Regulation (EU) 2026/1738 published 24 July 2026
Source: Regulation (EU) 2026/1738, published 24 July 2026
Regulation (EU) 2026/1738, published on 24 July 2026, requires a Circularity Vehicle Passport for covered vehicles from 1 September 2032. It is separate from ESPR but designed to interoperate with other EU passports.
The Ecodesign for Sustainable Products Regulation (ESPR) is the EU's framework for making products placed on the European market more sustainable, durable, and recyclable. It replaces the previous Ecodesign Directive and significantly expands its scope to cover virtually all physical products.
A key element of ESPR is the Digital Product Passport (DPP) — a standardised digital record that accompanies every product and is accessible through a data carrier, for example a QR code where the relevant rules allow or require it. The DPP will contain information about the product's origin, composition, repairability, and end-of-life handling.
Different product categories will be phased in on different timelines. Batteries are the first product group with passport obligations already set in sector-specific EU law (February 2027), followed by expected rollouts for textiles, mattresses, furniture, and other sectors.
