A brand that designs its digital product passport around one regulation often finds, a year later, that the regulation moved and the system didn't. That's the risk of building for compliance alone. The stronger reason to build a passport now is the same one that applies whether or not a regulator ever gets involved: a persistent, scannable identity per product is what lets a brand capture ownership data, verify authenticity, and manage what happens after the first sale — resale, service history, recalls, repeat purchase. We've made that commercial case in detail for fashion brands specifically; this piece is the category-by-category detail underneath it. Getting the regulatory picture right matters mainly so that system is built on the correct foundations, rather than over-built for a category that isn't affected yet or under-built for the one deadline that already applies.
The short version: what's confirmed, what's still a plan
Only one category has confirmed, binding digital product passport-style obligations with live dates: batteries. Under the EU Batteries Regulation (Regulation (EU) 2023/1542), a Battery Passport is required for light means of transport (LMT, e-bikes and e-scooters), electric vehicle, and industrial batteries above 2 kWh — not for every battery placed on the market. Separately, all batteries (regardless of the passport requirement) must carry a QR code from 18 February 2027, a fixed date with no delay mechanism attached to it. General battery labelling — capacity, chemistry, non-rechargeable status — is due from 18 August 2026 or 18 months after a related implementing act is adopted, whichever is later; that implementing act was itself due by August 2025 and, as of this writing, still hadn't been adopted, only put out for consultation. Everything else commonly discussed under "digital product passport" — textiles, furniture, tyres, mattresses, iron and steel, and other categories named in the EU's Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) — has no binding passport requirement yet. The Commission's first ESPR working plan, published 16 April 2025, sets indicative delegated-act adoption timelines of 2027 for textiles and apparel and tyres, and 2028 for furniture, with mattresses following in 2029. Those are Commission planning dates for adopting the rules that would create the requirement, not the requirement itself, and not the date the requirement would apply from — treat them as directional until a delegated act is actually adopted and published.
What a passport is legally required to carry, and what a brand adds on top
Where a passport is mandated, ESPR Article 10 sets baseline structural rules that apply across categories: the passport must be linked to a persistent unique product identifier via a data carrier physically present on the product, its packaging, or accompanying documentation; that identifier and carrier must comply with a recognised standard — Annex III of the ESPR points to standards including the GTIN under ISO/IEC 15459-6 — until harmonised standards are formally published; and all data in the passport must be open-standard, machine-readable, and accessible through an interoperable network rather than locked into one vendor's system. What specific data fields go into any one category's passport — material composition, repairability score, carbon footprint, and so on — is left to the delegated act for that category, which is exactly why textiles and furniture brands don't yet have a fixed content list to build against. On top of whatever a delegated act eventually requires, nothing stops a brand adding commercial data now: ownership registration, care and repair instructions, proof of authenticity, resale history. Most of what makes a passport useful day to day is this voluntary layer, not the regulatory minimum.
Who's affected first: the battery passport as the working precedent
Because the Battery Passport is the only category with confirmed detail today, it's the closest thing to a template for what other categories' passports will eventually look like. Its access model, set out in Annex XIII of the Batteries Regulation, uses four tiers running from fully public data through to data restricted to the operator, an authorised third party, or a regulator — and, critically, includes a tier of per-unit dynamic data such as state of health and use-phase status that only makes sense if the passport is tracking an individual battery, not a product line. That per-unit structure is worth noting for any brand outside batteries too: a passport built at SKU level now will need re-architecting the moment a delegated act requires unit-level data, so it's worth building for individual items from the start even in categories where it isn't yet mandatory. The Commission has also said it plans to bring the central DPP registry online, with a testing environment due around 20 July 2026 — a planned date, not yet a live system as this is written, and one to watch rather than build against directly.
What to put in place before any delegated act lands
None of the categories still waiting on a delegated act need to sit still until the text is finalised. Three things are safe to build regardless of which category a brand sits in and what the eventual data fields turn out to be. First, a persistent identifier per item — a serial number, not just a SKU — because every version of the passport rules discussed so far assumes unit-level identification is possible even where it isn't yet mandatory. Second, a resolvable web page that identifier points to, built on an open, standards-based data carrier rather than a proprietary app, so it can be extended rather than replaced when specific requirements land. Third, a way to update that page after the sale — adding a repair record, a resale event, an ownership transfer — because static, print-and-forget QR codes can't do this and most future delegated acts will assume some data changes over the product's life.
Build once, for more than one regulation
A brand that builds this infrastructure now for commercial reasons — item-level customer data, resale participation, counterfeit protection — isn't starting from zero the day a delegated act for its category is adopted. The identifier structure, the resolvable page, and the update mechanism already exist; what's added later is a smaller job of populating specific required fields, not building the system underneath them. That's also why a passport shouldn't be treated as single-use compliance infrastructure built for one regulation and retired if that regulation changes shape — the same identity per product supports authentication, warranty, and repeat purchase whether or not any particular delegated act ends up applying to that product at all. SmartLinks Hub builds this the same way regardless of category: a persistent page per item, GS1 Digital Link-ready, extendable as specific rules land. It's free until you go live, so there's no reason to wait for a finalised delegated act before setting up the first product.
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Sources: Regulation (EU) 2024/1781 (ESPR), Article 10 and Annex III — https://eur-lex.europa.eu/eli/reg/2024/1781/oj
Regulation (EU) 2023/1542 (EU Batteries Regulation) — https://eur-lex.europa.eu/eli/reg/2023/1542/oj