The ESPR and the DPP Rollout: Which Products, When

This page reflects the rules as of 10 July 2026. Regulatory dates are dated and may change, confirm against the current instruments or with qualified advisers.

The ESPR creates the DPP, delegated acts switch it on

Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR), entered into force on 18 July 2024. It replaces the old Ecodesign Directive and extends ecodesign rules beyond energy-related products to almost every physical good sold in the EU. Chapter III of the regulation establishes the Digital Product Passport: a structured, digitally accessible record of a product's composition, performance and circularity data, reachable through a data carrier, in practice a QR code, on the product itself.

The critical mechanism to understand is the delegated act. The ESPR is deliberately a framework: it defines what a DPP is and how it must work, but the obligation to actually carry one is switched on product group by product group, each through its own delegated act adopted by the European Commission. Each act specifies the data points, the granularity (model, batch or item level), who must see what, and, importantly, its own application date.

So "the DPP is coming" is true, but imprecise. What is coming is a sequence of product-specific acts over the second half of this decade. If you make textiles, your date is different from a steelmaker's, and an electronics maker's date is further out still.

The first working plan: six product groups (COM(2025) 187)

The Commission's first ESPR working plan, COM(2025) 187, adopted on 16 April 2025, names the priority product groups for the 2025–2030 period. Four final products: textiles (with apparel prioritised), furniture, tyres and mattresses. Two intermediate products: iron & steel, and aluminium. These were selected for environmental impact and improvement potential, textiles and steel between them account for a large share of the EU's material footprint.

The working plan attaches an indicative adoption date to each delegated act: iron & steel in 2026, textiles and tyres in 2027, furniture and aluminium in 2028, mattresses in 2029. Requirements then apply after a transition period set in each act, on the working plan's own indicative pattern, roughly 18–24 months after adoption, which puts the earliest real DPP obligations around 2028.

For textiles, preparatory work is well advanced: the Commission's Joint Research Centre published a draft data specification in May 2026 covering roughly 49 data points across four categories, with batch-level granularity as the working minimum. That document is a draft, not law, the numbers can and likely will move before the delegated act is adopted.

Electronics is not in the first wave

Consumer electronics and ICT products are not among the six priority product groups in COM(2025) 187. They are touched instead by two horizontal measures the working plan schedules for 2027–2029: a repairability requirement including an A-to-E repairability score (a scheme already applied to smartphones and tablets under separate rules), and requirements on recycled content and recyclability of electrical and electronic equipment. Product-specific DPP obligations for electronics are realistically a 2029–2031 question, tied to those horizontal measures or to a later working plan.

Energy-related products, dishwashers, fridges, electric motors, EV chargers, continue on their own staggered ecodesign timelines carried over from the previous regime, separate from the six DPP priority groups.

If you sell electronics, this is breathing room, not exemption. The DPP infrastructure being defined now, identifiers, data carriers, the registry, will apply to whichever act eventually covers your products, and the supplier-data problem is the same in every category.

What's adopted versus what's expected, as of July 2026

An honest status table, product group by product group:

The horizontal plumbing is further along than the product acts. CEN and CENELEC published the first harmonised European standards for the DPP's technical infrastructure in May 2026, EN 18219 (unique identifiers), EN 18220 (data carriers) and EN 18222 (data exchange and APIs). Under Article 13 of the ESPR, the Commission is required to establish the central DPP registry by 19 July 2026, and further Commission acts covering data carriers, service providers and registry operation are expected in late 2026.

The battery passport runs on its own track

Batteries are the one category with a hard, adopted date, and it does not come from the ESPR at all. Regulation (EU) 2023/1542, the EU Batteries Regulation, requires a battery passport from 18 February 2027 for EV batteries, light-means-of-transport (LMT) batteries, and industrial batteries with capacity above 2 kWh. The data structure is set out in Annex XIII of that regulation: identification, technical and performance data, carbon footprint and material composition, circularity and safety information, and compliance documentation. Carbon-footprint declaration obligations phase in earlier, starting with EV batteries.

A supporting delegated act on data content details and access rights is due from the Commission by 18 August 2026 under the same regulation, and was not adopted as of early July 2026. Battery makers are therefore in the unusual position of a fixed legal deadline arriving before every technical detail is final, which argues for building the passport record now on Annex XIII's structure and adjusting when the act lands, not waiting.

Because the battery passport predates any ESPR product act by at least a year, it is effectively the live pilot for the whole DPP system: the identifier conventions, QR-code data carriers and access-tier thinking being settled for batteries will shape how the ESPR acts are written.

Indicative dates are not deadlines, read them correctly

The working plan's dates are planning signals, not legal obligations. An "indicative adoption 2027" for textiles means the Commission intends to adopt the act around then; Commission timetables of this kind have historically slipped, and nothing is owed by anyone until an act is adopted, published, and its own application date arrives. Equally, the dates only move one way that matters commercially: an act can be late, but once adopted, its transition clock runs regardless of whether your supplier data is ready.

The practical reading for a manufacturer in a priority group, as of July 2026: no ESPR passport is legally required from you today, one is realistically required within roughly two to four years, and the slowest part of preparing, getting composition, origin and circularity data out of your supply chain, takes longest exactly when everyone in your sector starts asking the same suppliers at once. A passport you build for textiles or furniture today is a voluntary transparency record, not compliance, and should be described that way. What it buys you is the data pipeline, so that when the delegated act fixes the final field list, you are mapping to it rather than starting from a blank sheet.

This page reflects the rules as of July 2026. Adoption timings in the working plan are indicative and may change; we track adopted-versus-pending status per category and log changes as they happen.

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