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Who Needs a Digital Product Passport?

ESPR applies to virtually all physical products placed on the EU market. The first product groups and the adjacent sectors already worth monitoring:

Textiles & Apparel

Delegated act targeted for Q3-Q4 2027; Commission timeline shows DPP use in 2029 *

Commission plan

Source: COM/2025/187 and DG GROW webinar, 27 May 2026

Clothing, footwear, and textile products. Material composition, care instructions, and carbon footprint tracking.

Key DPP Requirements

  • Material composition and fibre content
  • Carbon footprint per product lifecycle
  • Care instructions and durability information
  • Recyclability and circular economy data
  • Supply chain traceability
Learn more

Furniture

Commission timeline places the delegated act in 2028; use date to be confirmed *

Commission plan

Source: COM/2025/187 and DG GROW webinar, 27 May 2026

Wooden and upholstered furniture. Wood certification, durability scores, and recyclability data.

Key DPP Requirements

  • Wood origin and certification (FSC/PEFC)
  • Durability and repairability scores
  • Material composition breakdown
  • Recyclability and disassembly instructions
  • Chemical substance declarations
Learn more

Mattresses

Commission timeline places the delegated act in 2029; use date to be confirmed *

Commission plan

Source: COM/2025/187 and DG GROW webinar, 27 May 2026

Mattresses are listed separately in the first ESPR Working Plan. Prepare material, durability and end-of-life data early.

Key DPP Requirements

  • Foam, textile, spring and coating composition
  • Durability and service-life evidence
  • Substance and supplier declarations
  • Repair, refurbishment and reuse routes
  • End-of-life and recyclability data
Learn more

Batteries

Battery passport obligations start 18 February 2027

Confirmed law

Source: Regulation (EU) 2023/1542

Battery passport obligations start from February 2027 for categories covered by the Battery Regulation.

Key DPP Requirements

  • Battery chemistry and composition
  • Carbon footprint declaration
  • Recycled content percentage
  • State of health and expected lifetime
  • Supply chain due diligence data
Learn more

Iron, Steel & Aluminium

Commission timeline shows iron and steel DPP use in 2028; aluminium in 2029 *

Commission plan

Source: COM/2025/187 and DG GROW webinar, 27 May 2026

Primary metals and metal products. Carbon footprint tracking, recycled content, and supply chain traceability for carbon-intensive materials.

Key DPP Requirements

  • CO2 emissions per tonne (Scope 1, 2, 3)
  • Recycled content (scrap vs. primary)
  • Alloy grades and material composition
  • Energy source and production route
  • Supply chain traceability and due diligence
Learn more

Electronics

Electronics and digital equipment: Commission timeline shows DPP use in 2029; appliance scope to be confirmed *

Commission plan

Source: COM/2025/187 and DG GROW webinar, 27 May 2026

Consumer electronics and appliances. Right to repair, spare parts availability, and energy efficiency.

Key DPP Requirements

  • Energy efficiency class and consumption
  • Repairability score and spare parts
  • Software update guarantee period
  • Critical raw materials declaration
  • WEEE classification and recyclability
Learn more

Building Materials

CPR GWP live; Commission timeline shows construction-materials DPP use in 2028 *

Mixed basis

Source: CPR acquis, CPR planning and DG GROW timeline, 27 May 2026

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.

Key DPP Requirements

  • Material composition and declared substances
  • Carbon and EPD-related evidence
  • Batch and supplier traceability
  • Recycled content and end-of-life data
  • Product identification and variant mapping
  • Installation, durability and performance records
Learn more

Packaging

PPWR data-carrier rules; Commission timeline shows packaging DPP in 2028, future act needed *

PPWR + Commission timeline

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.

Key DPP Requirements

  • Packaging material composition
  • PPWR labelling and digital-labelling data
  • Reusable-packaging system information
  • Recyclability and recycled-content evidence
  • Packaging EPR and role mapping
  • Data carrier and identifier strategy
Learn more

Tyres

Delegated act expected Q3-Q4 2027; Commission timeline shows DPP use in 2029 *

Commission plan

Source: COM/2025/187 and DG GROW webinar, 27 May 2026

Tyres are included in the first ESPR working plan with an indicative 2027 window, but exact duties still depend on the delegated act.

Key DPP Requirements

  • Tyre model and dimensional data
  • Recycled content and recyclability evidence
  • Performance and lifetime records
  • Supply-chain and end-of-life documentation
  • Alignment with existing tyre workflows
Learn more

Toys

DPP mandatory from 1 August 2030 (Toy Safety Regulation)

Confirmed law

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.

Key DPP Requirements

  • Composition and restricted-substance data
  • Safety-document linkage
  • Supplier and batch traceability
  • Durability and packaging inputs
  • Structured product data for future rules
Learn more

Detergents & Surfactants

DPP mandatory from 23 September 2029 (Regulation (EU) 2026/405)

Confirmed law

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.

Key DPP Requirements

  • Model-level identity, UFI and traceability
  • Intentional ingredient, preservative and allergen disclosure
  • Dual-layer label and dosage logic
  • Refill and distance-sales workflow
  • Micro-organism and biodegradability evidence
  • Registry, customs and DPP back-up
Learn more

Cosmetics

No confirmed cosmetics DPP date; prepare formula, CPNP, label and surveillance data

Readiness watchlist

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.

Key DPP Requirements

  • Product identity and responsible-person data
  • Formula, INCI and ingredient restrictions
  • CPSR and product information file evidence
  • CPNP, nanomaterial and SUE workflows
  • Label, claim substantiation and e-commerce consistency
  • Packaging and sustainability evidence
Learn more

Vehicles

Circularity Vehicle Passport phased from around 2032; ELV Regulation adopted by Parliament 18 June 2026, OJ publication pending *

Readiness watchlist

Source: End-of-Life Vehicles / Circularity Requirements Regulation, procedure 2023/0284(COD)

The End-of-Life Vehicles / Circularity Requirements Regulation introduces a Circularity Vehicle Passport, phased in around 2032. It is separate from ESPR and not yet published in the Official Journal.

Key DPP Requirements

  • Vehicle and component identity data
  • Recycled-content evidence (plastics, steel, critical raw materials)
  • Dismantling and circularity information
  • Extended producer responsibility and supply-chain traceability
  • Material declarations for recyclability
Learn more
Cards marked as Commission plan, editorial estimate or PPWR + Commission timeline do not yet indicate confirmed DPP obligations. Use the detailed sector page to distinguish confirmed law, Commission timeline points and editorial interpretation.

What is ESPR?

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.

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