Digital Product Passport (DPP): Obligations, Deadlines, and What the ESPR Roadmap Means

As of July 2026

The Digital Product Passport (DPP) is becoming mandatory for an increasing number of product groups—but not all at once, rather in phases through individual legislative acts. The EU Ecodesign Regulation (ESPR) sets the framework; the first mandatory product passport—the battery passport—will take effect on February 18, 2027. This article explains who will be affected and when, what data the DPP must contain, and what the roadmap looks like through 2030.

Key Points at a Glance

• The Digital Product Passport is a framework instrument under the Ecodesign Regulation (ESPR) (EU) 2024/1781, which entered into force on July 18, 2024.
• The DPP does not apply across the board, but is implemented for each product group through a separate delegated act—each with its own deadline.
• The first mandatory product passport is the battery passport under the Battery Regulation (EU) 2023/1542: It will be mandatory starting February 18, 2027, for LMT, industrial (> 2 kWh), and EV batteries.
• The ESPR Work Plan (COM(2025) 187, adopted in April 2025) identifies textiles, iron and steel, aluminum, furniture, and tires, among others, as priority product groups.
• For iron and steel, the legislative act is tentatively scheduled to be adopted in 2026; for textiles, around 2027—the requirement will then typically take effect about 18 months later.
• 2026 is the year of infrastructure: EU registries, data carrier standards (GS1), and CEN/CENELEC standards are being developed.

What is the Digital Product Passport?

The Digital Product Passport (DPP) is a machine-readable data record that describes a product throughout its life cycle and makes this information accessible via a data carrier (e.g., a QR code). It consolidates information on materials, repairability, recyclability, environmental impact, and disposal. The legal basis is the Ecodesign Regulation ESPR (EU) 2024/1781.

Digital Product Passport (DPP): A structured, digitally accessible dataset for a product, mandated by the ESPR (EU) 2024/1781. The goal is to provide greater transparency regarding materials, recyclability, and environmental impact—for public authorities, economic operators, and consumers. The specific data requirements are set forth in a delegated act for each product group.

What’s important is the logic behind it: The ESPR provides the framework, but it does not, on its own, make any individual product subject to the DPP. The Pass only becomes mandatory once a delegated act for a product group enters into force. Therefore, the key question for companies is not “whether the DPP applies,” but “when it will apply to my product.”

Who is affected by the DPP, and when does it take effect?

Batteries will be the first to be affected: The battery passport will be mandatory starting February 18, 2027—regulated not by the ESPR, but by the separate Battery Regulation (EU) 2023/1542. The ESPR product groups will follow in phases. For iron and steel, the adoption of the legislation is tentatively scheduled for 2026; textiles are expected to follow in 2027, with the regulation taking effect approximately 18 months later.

Product GroupLegal BasisIndicative TimelineBatteries (LMT, Industrial > 2 kWh, EV)Battery Regulation (EU) 2023/1542Effective February 18, 2027Iron & SteelESPR ActAdoption indicated for 2026Textiles & ApparelESPR ActAdoption ~2027, Effective ~2028/2029Furniture, Tires, Aluminum, etc.ESPR Legislation2027–2030 (phased)

The dates listed are indicative (as of the ESPR Work Plan COM(2025) 187)—the binding date will be specified in the published delegated act. Anyone supplying within these supply chains should actively monitor the delegated act relevant to their own product group.

What information must a Digital Product Passport contain?

Each delegated act specifies the specific data fields for its product group—there is no uniform list of required data fields for all products. However, certain recurring data categories emerge across product groups:

1. Product and Manufacturer Identification (unique identifiers, data carriers).
2. Material composition, including substances of concern.
3. Recycling rate and recyclability (repairability, replacement parts, disassembly).
4. Environmental impact, including the product's carbon footprint.
5. End-of-life information and proof of compliance.

The data source is crucial for environmental data: A robust Product Carbon Footprint (PCF) and a methodologically sound life cycle assessment (LCA) provide exactly the values that the DPP requests on a product-by-product basis.

What does the DPP mean for businesses?

For companies, the DPP shifts the focus from communication to data management: What matters is not the presentation, but whether accurate, reliable product-specific data is available across the supply chain. This applies equally to procurement, product management, and sustainability—and overlaps with data requirements for CSRD reporting.

In practice, the real hurdle lies in the supply chain: material composition, recycling content, and product CO₂ figures must be provided by upstream suppliers and consistently maintained. Those who establish these data flows early on will not have to reconstruct them later under time pressure.

Our Assessment

From a consulting perspective: The phased rollout is slightly underestimated. Because “the DPP” won’t take effect for many product groups until 2028 or later, the issue seems non-binding. However, building the database takes longer than the actual implementation of the pass—especially if product CO₂ values and material data first have to be collected from suppliers.

Our recommendation: Identify the regulatory act relevant to your product group now, derive the required data fields from existing PCF/LCA projects, and close the gaps in the supply chain. The 2027 Battery Passport serves as the best blueprint for this—it clearly illustrates the level of data detail that a regulatory agency expects.

Conclusion: The schedule is set—it all comes down to the data

The DPP will be implemented in phases but reliably: batteries in 2027, iron & steel and textiles in the years that follow. For companies, the sensible next step is not pass technology, but a product-specific database—material data, recycling content, and CO₂ values from the supply chain. Those who are familiar with the relevant legislation and close data gaps early on will be able to navigate the process without the pressure of deadlines.

Digital Product Passport: Prepare the data set from PCF and LCA. A brief initial consultation will clarify what product data your DPP will need in the future and how you can fill the gaps in the supply chain. Schedule an initial consultation.

Sources

1. European Union: Regulation (EU) 2024/1781 (Ecodesign Regulation, ESPR), in effect since July 18, 2024.
2. European Commission: Ecodesign for Sustainable Products Regulation – Overview & Work Plan (COM(2025) 187) (as of July 2026).
3. European Union: Regulation (EU) 2023/1542 (Battery Regulation), Article 77 (Battery Passport effective February 18, 2027).

‍

Dr. Florian Niedermeier, Five Glaciers Consulting GmbH. Advises industrial companies on product CO₂ accounting, life cycle assessment, and product-related data requirements such as the Digital Product Passport.