01The framework is set; the dates arrive in waves
The ESPR - the European Ecodesign for Sustainable Products Regulation (EU 2024/1781) - has been in force since July 2024. But being in force does not mean every product needs a passport tomorrow.
The regulation sets the framework. The concrete requirements - which data, which products, by when - arrive afterwards, category by category, through delegated acts. So the honest answer to "when is it mandatory?" is always: it depends on your category.
Framework: live since 2024. Batteries: 18 February 2027. Textiles and other priority groups: requirements expected from 2027, with category dates landing across 2027–2030.
02Batteries: the first hard deadline
Batteries do not wait for the ESPR delegated acts - they have their own law. The EU Battery Regulation (2023/1542) makes the battery passport mandatory from 18 February 2027 for industrial and electric-vehicle batteries above 2 kWh.
This is the first firm, dated obligation of the whole DPP movement - which is why the battery sector is the bellwether everyone else is watching.
03Textiles and the first ESPR groups
Under the ESPR itself, textiles and apparel are on the front line - one of the first priority groups, with requirements expected from 2027.
The exact obligations and the precise date come with the textile delegated act, but the direction is settled: fashion is among the earliest sectors to carry a digital passport.
04Categories on the 2027–2030 horizon
In its 2025–2030 working plan, the European Commission named the priority groups. Expect their passports to land across this window:
The trajectory is unmistakable: over 2027–2030 the digital passport extends to the generality of products placed on the European market.
05How each date actually gets set
For each category, a delegated act fixes the specifics: which data points are required, the access layers, and the date from which the passport becomes obligatory.
- The ESPR sets the framework and the menu of possible requirements.
- A delegated act per category selects the requirements and the date.
- Most category dates fall between 2027 and 2030.
- Once adopted, the date is firm - and preparation lead times are long.
Because a category has no obligation until its delegated act is adopted. Waiting for your exact date to start preparing is the trap - the hard part (clean, organised data) takes longer than the legislation.
06What to do before your date arrives
Whatever your category's exact date, the preparation is the same - and it is mostly about data, not paperwork:
- Map the data you already hold - composition, suppliers, certificates - and where it lives.
- Serialise identity at the item level, not just the model.
- Choose physical carriers (QR, NFC, RFID) fit for the product.
- Secure permanent, interoperable hosting aligned with GS1 Digital Link and EN ISO/IEC.
Start with What is the digital product passport, or jump to the frequently asked questions.
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