One of the most common misconceptions is that the ESPR has a single date on which the Digital Product Passport "switches on." It doesn't. The DPP becomes mandatory on a product-category basis, through separate delegated acts, typically between 2028 and 2031 — while batteries are covered by an entirely separate regulation, already from 18 February 2027. This article walks through, category by category, what becomes mandatory and when, and how to start preparing today.
What is the ESPR, and why is there no single "DPP switch"?
The ESPR — the Ecodesign for Sustainable Products Regulation, (EU) 2024/1781 — entered into force on 18 July 2024. It is, however, a framework regulation: on its own it imposes no concrete requirements on any product, and it does not contain the passport's data fields. The actual obligations — including whether a given product needs a DPP at all, and if so with what data — will be set out in product-group delegated acts. That is why there is no single, EU-wide "DPP go-live": the obligations arrive category by category. If it's still unclear what the product passport actually is, start with our introductory guide.
The ESPR working plan 2025–2030: the six priorities
The Commission adopted the first ESPR working plan 2025–2030 on 16 April 2025 — its official reference is Communication COM(2025) 187 final. This is a planning document (not the binding legislation itself) that identifies which product groups the Commission will tackle first. It sets out six priorities:
- Iron and steel — intermediate product
- Aluminium — intermediate product
- Textilees and clothing — finished product (the focus is on apparel)
- Furniture — finished product
- Tyres — finished product
- Mattresses — finished product
Work also continues on some 14 "legacy" energy-related product groups, and horizontal (cross-cutting) measures appear as well: a repairability score spanning several product groups, plus recyclability / recycled-content requirements for electrical and electronic equipment (indicatively 2027–2029). Footwear was considered but has been postponed for now. The working plan foresees a mid-term review in 2028, which may add new product groups or re-prioritise existing ones.
Timeline by category: when does the DPP become mandatory?
The start of a DPP obligation has two components: (1) when the delegated act for the given category is adopted, and (2) how much transition time that act allows before the requirements actually apply. The table below captures both. Important: every year shown is an indicative, non-binding Commission planning figure. Legally fixed dates only materialise once the individual delegated acts are adopted — as of early July 2026 (at the time of writing), not a single product-specific ESPR delegated act has been adopted, and there are visible slippages compared with earlier estimates. This is the timeline the answer to "when is the DPP mandatory" is built on.
| Product group | Delegated act – indicative adoption | DPP expected mandatory start | Type |
|---|---|---|---|
| Iron and steel | ~2026 | ~2028 | intermediate product |
| Textilees / clothing | ~2027 (some sources say end of 2026) | ~2028–2029 | finished product |
| Tyres | ~2027 | ~2029 | finished product |
| Aluminium | ~2027–2028 (sources conflict) | ~2029–2030 | intermediate product |
| Furniture | ~2028 | ~2030 | finished product |
| Mattresses | ~2029 | ~2030–2031 | finished product |
| Mid-term review | 2028 | — | new groups may be added |
The "DPP expected mandatory start" column is a derived estimate (adoption year + transition period), not an official date. Given the slippage observed so far, the real dates are more likely to move later than earlier.
What is a delegated act and the ~18-month transition?
A delegated act is the legal instrument in which the Commission — empowered by the framework regulation — lays down, category by category, the specific ecodesign requirements and the content of the Digital Product Passport: which data fields are mandatory, at what access level, on which data carrier. In other words, your industry's real "DPP rulebook" won't be found in the ESPR itself, but in the delegated act that applies to you.
The ESPR requires every delegated act to allow at least 18 months of transition between entry into force and actual application — in practice this is often 18–24, and sometimes as much as 36 months. This is the "grace period" within which manufacturers and importers have to reach compliance. Hence the rule of thumb: the delegated act's adoption year + roughly 18–24 months gives the earliest realistic mandatory DPP date. That is why the iron/steel DPP lands around 2028, while mattresses fall closer to 2030–2031. If someone promises a "Digital Product Passport 2027" date for ESPR products, they almost certainly mean batteries — more on that below.
What exactly does "mandatory" mean?
"Mandatory" here means, in legal terms, that compliance — including holding a valid DPP where the delegated act requires it — is a condition for placing the product on the EU market. "Placing on the market" means making the product available on the EU market for the first time in the course of a commercial activity (whether for payment or free of charge). After the application date, a product without a DPP (or with a defective one) cannot be lawfully placed on the market anywhere in the EU. A few practical consequences:
- The obligation falls on the responsible economic operator: the manufacturer, importer or authorised representative.
- Enforcement is carried out by market surveillance authorities and customs — customs can check at the point of import whether an adequate passport is in place.
- Products already lawfully placed on the market before the date generally do not need to be retrofitted with a passport — but always check the precise "grandfathering" wording in the relevant delegated act.
Batteries fall under a separate regulation — and sooner
Batteries are not part of the ESPR working plan: they are covered by the standalone EU Batteries Regulation, (EU) 2023/1542, which brings its own, earlier timeline. The mandatory start date for the digital battery passport is 18 February 2027 — directly applicable in all 27 Member States, with no national transposition.
Because the scope is often misunderstood, it's worth being precise: the passport is mandatory for every EV battery (regardless of capacity), every LMT (light means of transport) battery, and every industrial battery above 2 kWh. The 2 kWh threshold applies only to industrial batteries — many sources wrongly write "EV > 2 kWh," which is misleading. The key battery dates:
| Date | Obligation |
|---|---|
| 2027-02-18 | Battery passport mandatory (EV, LMT, >2 kWh industrial batteries) |
| 2027-08-18 | Supply-chain due diligence obligations begin — postponed from 18 August 2025 by Regulation (EU) 2025/1561 |
| 2028-08-18 | Recycled-content declaration (Co, Pb, Li, Ni) for EV / SLI / >2 kWh industrial batteries |
| 2031-08-18 | Minimum recycled-content thresholds: cobalt 16%, lead 85%, lithium 6%, nickel 6% |
The carbon-footprint declaration is staggered by battery type (EV batteries were meant to go first), but because the delegated act fixing the calculation methodology is delayed, the actual start is slipping. We set out the full list of battery data fields, access levels and the threshold schedule in our battery passport article and at our battery solution.
Where does the process stand in mid-2026?
At the time of writing (9 July 2026), the situation is as follows:
- Not a single product-specific ESPR delegated act has been adopted yet. Iron/steel and textiles are in the preparatory/consultation phase — the Joint Research Centre (JRC) DPP-content studies were produced in spring 2026 (steel in March, textiles in May), with a steel DPP-content consultation around April.
- The first act (steel) has slipped from earlier end-of-2025 estimates to 2026 — so the slippage is already visible, and is equally plausible for the other categories.
- Some industry watchers cite 19 July 2026 as a target date for setting up the EU central DPP registry (Article 13 of the ESPR) — but this specific day comes from secondary, industry sources, is not officially confirmed by the Commission (EUR-Lex), and should therefore be treated with caution. Moreover, this date too refers to standing up the system rather than to full live operation; the exact timing of operability is uncertain. Note: this registry is an index/directory, not a data store — the passport's content remains with the manufacturer.
How to start preparing right now
Even though most of the mandatory dates feel "distant," gathering the data and getting your supply chain in order takes months or even years. Concrete steps:
- Identify your category and the earliest realistic date. Use the table above to see which priority you fall into, and apply the "adoption + 18–24 months" rule.
- Take a data inventory. What do you know today about your product in terms of material composition, origin, repairability, recyclability and carbon footprint — and where are the gaps? The exact field list will come from the delegated act, but the core master data will be needed in every version.
- Get your supplier data in order. A large share of DPP fields (material, origin, certificates) comes from suppliers — it's worth collecting these now and writing their provision into contracts.
- Choose your data carrier and identifier. For consumer access, the QR code / Data Matrix is currently the only approved carrier, with a GS1 Digital Link URI; that's the subject of our QR and GS1 Digital Link article.
- Go deeper by industry. If you're in textiles, start with our textile-industry DPP guide and our textile solution.
- Work through a checklist. To progress step by step, use our preparation checklist.
The Veridyn platform is built to accelerate exactly this preparation: structured, machine-readable passports, QR-based consumer access and version tracking. Take a look at our plans, start an account, or book a consultation if you're not sure which category affects you and when.
Summary
ESPR deadlines are not a single date but a timeline that rolls out category by category: the framework regulation has applied since 2024, the delegated acts for the six priorities are indicatively due between 2026 (iron/steel) and 2029 (mattresses), and the actual mandatory DPP — thanks to the minimum 18-month transition — typically takes effect between 2028 and 2031. The one date that is solid and near today is the battery passport obligation of 18 February 2027, which rests on a separate regulation. The safe strategy: don't wait for the final date — get your data and your supply chain in order in good time.