Basics & regulation

Digital Product Passport Timeline by Product Group

DPP timeline as of November 2026: fixed dates for batteries, detergents and toys, and the Commission's indicative schedule for steel, textiles and more.

Published
Reading time
7 min read

This overview separates the fixed dates from the expected ones and shows how to read them.

How to read DPP dates: three status levels

Most confusion about the passport timeline comes from mixing three different kinds of dates.

Status What it means Example
In force and applicable The rule is law and already applies. The ESPR framework, the DPP registry
Adopted, not yet applicable The rule is law and published, with a future start date. Battery passport from 18 February 2027
Expected A plan or proposal. Dates may move. Delegated act for textiles, indicated for late 2027

A date in the third group is a planning assumption. Only publication in the Official Journal of the EU turns it into a deadline.

Dates fixed in law

These dates are written into adopted regulations.

Date What applies Legal basis
18 July 2024 ESPR enters into force Regulation (EU) 2024/1781
19 July 2026 Destruction of unsold apparel, clothing accessories and footwear is prohibited for large companies ESPR Article 25
20 July 2026 DPP registry operational (legal deadline: 19 July 2026) ESPR Article 13
18 February 2027 Battery passport for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries; QR code on batteries Regulation (EU) 2023/1542, Articles 13 and 77
18 February 2027 Member States appoint national administrators for the registry Implementing Regulation (EU) 2026/1778
23 September 2029 Passport for detergents and end-user surfactants Regulation (EU) 2026/405
19 July 2030 Destruction ban and disclosure duty extend to medium-sized companies ESPR Articles 24 and 25
1 August 2030 Passport for toys Regulation (EU) 2025/2509

Two notes on this table. First, the destruction ban is an ESPR obligation but not a passport obligation; it is listed because it is often confused with the DPP start. Micro and small enterprises are exempt from it. Second, the battery passport date has not been moved. The 2025 amendment to the Batteries Regulation postponed the due diligence obligations to 18 August 2027, not the passport. Details are in our battery passport guide.

The Commission's indicative schedule

The European Commission publishes an indicative timeline on its Digital Product Passport page. On 11 November 2026 it listed the following steps. All of them are subject to change.

Indicative timing Planned step
November 2026 Implementing decision on the two remaining harmonised DPP standards
Q4 2026 ESPR delegated act for iron and steel; implementing act on access rights for the battery passport
Q2 2027 Delegated act for construction products under the Construction Products Regulation
Q2 to Q3 2027 Delegated act on DPP service providers
Q3 to Q4 2027 ESPR delegated acts for textiles, aluminium and tyres
2028 ESPR delegated act for furniture
2029 ESPR delegated acts for mattresses and for recycled content

The schedule follows the first ESPR working plan for 2025 to 2030, which the Commission adopted in April 2025. The working plan also carries forward a list of energy-related products, such as displays, household washing machines and dishwashers, with adoption dates between 2026 and 2030. A mid-term review of the plan is foreseen for 2028.

From adoption to obligation: the 18-month rule

For ESPR product groups, adoption of the delegated act is not the day the passport becomes mandatory. Article 4 of the ESPR says that the date of application may not be earlier than 18 months after the delegated act enters into force, except in duly justified cases. The Commission's DPP page repeats this: after adoption, economic operators have a transition period of at least 18 months.

A worked reading, clearly hypothetical: if a delegated act entered into force in January 2028, its requirements would normally apply from July 2029 at the earliest. The act itself can set a later date or stagger requirements.

The 18-month rule belongs to the ESPR. The other regulations set their own dates directly, which is why batteries, detergents and toys have fixed days.

Status by product group

Batteries. Adopted. From 18 February 2027 every LMT battery, every industrial battery with a capacity above 2 kWh and every electric vehicle battery placed on the market or put into service needs a battery passport. The implementing act that defines access for persons with a legitimate interest was due by 18 August 2026 and had not been published when this article was written; the Commission lists it for the fourth quarter of 2026.

Iron and steel. Expected. This is planned to be the first ESPR delegated act. The initiative is listed on the Commission's "Have your say" portal. Until the act is adopted, neither the exact product scope nor the data fields are final.

Textiles (apparel). Expected. The Commission's textile page names the fourth quarter of 2027 for the planned adoption. Footwear is not part of the first working plan; a study is to assess it by the end of 2027. See DPP for textiles.

Aluminium and tyres. Expected, indicated for 2027.

Furniture and mattresses. Expected, indicated for 2028 and 2029.

Electronics and ICT. No stand-alone passport act is scheduled. The working plan addresses them through horizontal requirements on repairability (indicated for 2027) and on recycled content and recyclability of electrical and electronic equipment (2029), and through the energy-related product list.

Construction products. The revised Construction Products Regulation provides for a passport system, to be set up by delegated act. The Commission indicates the second quarter of 2027.

Detergents and toys. Adopted, with the fixed dates shown above.

Not on the first working plan. Detergents, paints and lubricants were not prioritised under the ESPR. Chemicals and footwear are being studied.

What could still change

Three things can move dates.

  • Delays in adoption. Indicative quarters slip. The battery access rights act is an example of an act that missed its legal deadline.
  • Simplification packages. EU "omnibus" proposals have already postponed other obligations, such as battery due diligence. Proposals under negotiation in 2026 may change details. Until a change is published in the Official Journal, the dates in the adopted texts stand.
  • Scope decisions in delegated acts. A delegated act can exclude sub-groups, set different dates for different requirements or choose model, batch or item level.

How to track the dates yourself

  • The Commission's DPP page carries the current indicative timeline and news.
  • EUR-Lex shows the consolidated text of each regulation, including amendments.
  • The "Have your say" portal lists draft delegated acts during their feedback period, which is the earliest reliable view of scope and data fields.
  • Our DPP scope and timeline checker shows the status for a product group and role, with the date each entry was last verified.

If you are new to the topic, start with what the Digital Product Passport is.

Checklist for your planning calendar

  • Mark fixed dates and indicative dates in different colours.
  • For each product group you sell, note the legal act and its current status.
  • For ESPR groups, plan with "adoption plus at least 18 months", not with the adoption quarter.
  • Set a reminder to re-check the Commission's timeline every quarter.
  • Record the date and source for every deadline you put into an internal plan.
  • Review your plan when a draft delegated act for your product group is published.

Sources

This article is general information, not legal advice. Status checked on 11 November 2026.

FAQ

When does the Digital Product Passport become mandatory?

It depends on the product group. The first fixed date is 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. Detergents follow on 23 September 2029 and toys on 1 August 2030. ESPR product groups have no fixed date until their delegated act is adopted.

What happened on 19 July 2026?

That was the legal deadline for the Commission to set up the DPP registry. The registry went live on 20 July 2026. No product became subject to a passport on that date. Separately, the ban on destroying unsold apparel and footwear started to apply to large companies on 19 July 2026.

How long after a delegated act do companies have to comply?

Under Article 4 of the ESPR, a delegated act may not apply earlier than 18 months after its entry into force, unless there are duly justified reasons for an earlier date.

Are the Commission's dates for textiles and steel binding?

No. They are indicative and the Commission says so itself. Only an adopted act published in the Official Journal sets binding dates.