Digital Product Passport: the roadmap to 2030
Ever since the EU Ecodesign Regulation (ESPR) came into effect, timelines for the Digital Product Passport have been circulating: 2027 batteries, 2028 textiles and furniture, 2029 electronics, 2030 practically every sector. These lists are useful for orientation — but they mix two things that must not be mixed: applicable law and planning intent.
- Framework
- ESPR — Regulation (EU) 2024/1781
- In force since
- 18 July 2024
- Made binding by
- a delegated act
- First hard deadline
- Battery passport 18.02.2027
Why no date from the work plan is a deadline
The ESPR is a framework, not a directly applicable product rule. It establishes that product passports will exist — but not which products need which passport when. Under Article 9(2) that is decided by the delegated act for the product group in question: which data has to be included, which data carrier is to be used, whether the passport is created at model, batch or item level, who has access and how long it has to remain available.
As long as that act does not exist for your product group, there is no obligation — and no solid data requirement to plan against either. The Commission’s work plan for 2025 to 2030 names the priority product groups it will work on first. It is an order of play, not a calendar of deadlines.
The most common error in circulating timelines
When a list says “2028: textiles and furniture”, it sounds like a deadline but is an expectation. For every year figure you come across, check which legal basis stands next to it. If all it says is “ESPR work plan”, the date is a planning assumption — it can shift, and it has shifted in the past.
What is actually settled today
Regulation (EU) 2024/1781 replaces the old Ecodesign Directive and creates the framework for the Digital Product Passport. From here the DPP legally exists — but is not directly mandatory for any product group.
The Commission sets out the order in which it will develop delegated acts — including textiles and clothing, furniture, tyres, iron and steel, aluminium. An order of play, not deadlines.
The first hard DPP deadline comes not from the ESPR but from the Batteries Regulation (EU) 2023/1542. It covers industrial and traction batteries as well as LV batteries above 2 kWh. If you supply here, you have a genuine cut-off date.
For all other groups the obligation only arises with the respective act, together with a transition period. Only then is it settled which data fields you have to supply.
Binding or expected — telling them apart day to day
Legally binding
- Battery passport from 18.02.2027 — Regulation (EU) 2023/1542
- Electronic labels for wine and aromatised wine — Regulation (EU) 2021/2117, since December 2023
- ESPR framework obligations (data carrier, back-up copy, access rights) as soon as a delegated act applies
Expected per the work plan
- Textiles and clothing
- Furniture and mattresses
- Tyres
- Iron, steel and aluminium
- Paints and varnishes as well as detergents and cleaning products
On the central EU registry
Article 13 ESPR obliges the Commission to set up a registry for product passports. Different figures circulate online for when it goes live. We deliberately name none here, because none can be derived from the text of the regulation — for your planning rely on the delegated act for your product group, not on the registry.
What you can do now regardless of the date
The good news within the uncertainty: the preparatory work is almost identical across all product groups. No delegated act will demand data you would not have to know about your products anyway — material composition, origin, recycled content, substances of concern, supplier evidence. If you hold that information in structured and evidenced form, all that remains at the cut-off date is to export it.
- Determine your product group — via the customs tariff (HS code), not by gut feeling. It decides which act applies to you.
- Make the data gaps visible today: which fields are missing, and which supplier are they stuck with?
- File supplier evidence as records, not as email attachments — every value will later need a source.
- Use the PPWR work twice: recycled content, material details and recyclability are the same data for packaging and the product passport.
- Think about the QR code and hosting last — that is the smallest part of the work.
The digital product passport shall be stored by the economic operator responsible for its creation or by digital product passport service providers.
That is the second place where effort can be saved: there is no obligation to operate the passport yourself. For the back-up copy, Article 10(4) even expressly requires an independent third-party service provider. Anyone investing in their own infrastructure today is solving a problem the regulation does not pose.
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Which deadline applies to your products?
We classify your product groups and show which data you only have to collect once for both the PPWR and the product passport.
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