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DPP Resource

The Digital Product Passport timeline, cross-referenced.

One synthesised schedule for every EU DPP deadline from the Battery Regulation in 2023 through the textile, furniture and toy passports of 2030 — built from primary EUR-Lex texts, the Commission's Working Plan, GS1, CEN-CENELEC, CIRPASS-2 and the leading independent trackers. Where they disagree, we say so.

15
Confirmed-in-law dates
11
Working-plan estimates
2
Contested between sources
15
Sources cross-referenced
RegulationProduct DPPInfrastructureHorizontalMilestone

The schedule

Year by year, milestone by milestone

Each event is tagged by type and by how solid the date is — written into a published regulation, expected per the Working Plan, or contested between sources. Treat the last group as planning parameters, not predictions.

2023
  1. 12 July 2023RegulationConfirmed in law

    Battery Regulation adopted

    Regulation (EU) 2023/1542 becomes the first EU law to mandate a Digital Product Passport for a specific product category. Battery passport obligations are written into Article 77 with a hard application date.

    Source: EUR-Lex 32023R1542

2024
  1. May 2024MilestoneConfirmed in law

    CIRPASS-2 begins

    The €12.6M Horizon Europe project (coordinated by CEA, 49 partners) starts a three-year programme of 13 lighthouse pilots across textiles, electronics, tyres and construction. Its outputs feed CEN-CENELEC and the delegated acts.

    Source: cirpass2.eu

  2. 18 July 2024RegulationConfirmed in law

    ESPR enters into force

    Regulation (EU) 2024/1781 — the Ecodesign for Sustainable Products Regulation — comes into force. The framework is set; the product-specific rules now flow through delegated acts.

    Source: EUR-Lex 32024R1781

2025
  1. April 2025MilestoneConfirmed in law

    ESPR Working Plan 2025-2030 published

    The Commission names the priority categories that will get the first wave of delegated acts: iron and steel, textiles, tyres, furniture, mattresses, dishwashers, EV chargers, fridges and freezers, electric motors, aluminium, plus mobile phones and tablets later in the plan.

    Source: European Commission, 16 Apr 2025

  2. May 2025InfrastructureConfirmed in law

    CEN-CENELEC CWA 18186 published

    First public technical guidance from CEN-CENELEC JTC 24 on how to create a DPP. Not the full harmonised standards, but the first stake in the ground.

    Source: CEN-CENELEC CWA 18186:2025

2026
  1. 1 January 2026RegulationConfirmed in law

    Toy Safety Regulation enters into force

    Regulation (EU) 2025/2509 takes effect. The DPP is written directly into the regulation rather than left to a future delegated act — applies from 1 August 2030.

    Source: EUR-Lex 32025R2509

  2. 9 February 2026HorizontalConfirmed in law

    Destruction-ban delegated regulation adopted

    Commission Delegated Regulation C(2026) 659 final sets out the narrow derogations from the ESPR ban on destroying unsold textiles and footwear, plus the disclosure rules.

    Source: European Commission, 9 Feb 2026

  3. Mid-2026InfrastructureExpected

    Eight harmonised DPP standards (delayed)

    The CEN-CENELEC JTC 24 package — data carriers, APIs, interoperability, security, access rights — was targeted for March 2026 and has slipped. Drafts are circulating; final publication is now expected later in 2026.

    Source: CEN-CENELEC JTC 24

  4. 19 July 2026HorizontalConfirmed in law

    Destruction ban applies (large enterprises)

    Large fashion and footwear businesses can no longer destroy unsold stock. Medium-sized companies get an extra four years; micro and small are exempt.

    Source: ESPR Art. 24

  5. Mid-2026InfrastructureExpected

    EU central DPP registry expected to go live

    The single point through which competent authorities and customs verify a product before market placement. Operational target is mid-2026; the Commission has not yet confirmed a firm launch date.

    Source: Commission planning

  6. 31 July 2026RegulationConfirmed in law

    Right to Repair Directive transposition deadline

    Member states must implement Directive (EU) 2024/1799 in national law. Repair data hooks into the same product records the DPP relies on.

    Source: EUR-Lex 32024L1799

  7. 27 September 2026HorizontalConfirmed in law

    Empowering Consumers Directive applies

    Directive (EU) 2024/825 bans unsubstantiated green claims and offset-based 'climate neutral' labels. The substantiation those claims need lives naturally inside a DPP.

    Source: EUR-Lex 32024L0825

  8. 30 December 2026RegulationConfirmed in law

    EUDR applies to large operators

    EU Deforestation Regulation due-diligence obligations bite for leather, rubber, wood, palm oil, soy, cocoa, coffee and cattle. The same chain-of-custody data feeds the DPP.

    Source: EUR-Lex 32023R1115

2027
  1. 18 February 2027Product DPPConfirmed in law

    Battery passport mandatory

    Every EV battery, LMT battery, and industrial battery above 2 kWh placed on the EU market needs a QR code linked to a compliant passport. The first live DPP enforcement event.

    Source: Reg 2023/1542 Art. 77

  2. Early 2027Product DPPSources disagree

    Textile delegated act expected

    Sources disagree on timing — see the contested-dates section below. Once it publishes, the compliance window opens (typically ~18 months).

    Source: Multiple — see below

  3. April 2027MilestoneExpected

    CIRPASS-2 closes

    Lighthouse pilots wrap up. Cross-pilot interoperability and large-scale issuance results feed into the standards and act revisions that follow.

    Source: cirpass2.eu

  4. May 2027RegulationExpected

    CRMA permanent-magnet disclosure

    Critical Raw Materials Act (Reg 2024/1252) disclosure rules for products containing permanent magnets — composition, recycled content, recovery pathway — begin to apply.

    Source: EUR-Lex 32024R1252

  5. 2027InfrastructureConfirmed in law

    GS1 Sunrise 2027

    Global retail point-of-sale infrastructure switches on 2D barcodes (QR / GS1 Digital Link) alongside the traditional EAN. One QR can now serve checkout, DPP access, and consumer engagement.

    Source: GS1 Global

  6. 2027Product DPPExpected

    Iron, steel, dishwashers, tyres acts adopted

    The Working Plan's first ESPR-wave delegated acts are expected through 2027. Compliance follows ~18 months later.

    Source: ESPR Working Plan 2025-2030

2028
  1. 2028HorizontalExpected

    Textile EPR schemes operational

    Under the revised Waste Framework Directive (EU 2025/1892), member states stand up Extended Producer Responsibility schemes for textiles. Eco-modulated fees lean on the same data feeding the DPP.

    Source: EUR-Lex 32025L1892

  2. 2028MilestoneExpected

    Working Plan mid-term review

    Commission re-opens the Working Plan. Scope and timing of remaining categories can be adjusted; new categories can enter the queue.

    Source: ESPR Art. 18

  3. 2028Product DPPExpected

    Furniture, aluminium, EV chargers, fridges, motors acts

    Second-wave ESPR delegated acts expected through 2028. Mattresses may join furniture or follow in 2029.

    Source: ESPR Working Plan

  4. Late 2028Product DPPSources disagree

    Textile DPP requirements apply (expected)

    Roughly 18 months after the textile delegated act publishes. Every textile product on the EU market must carry a compliant DPP. Exact date is fixed only when the act itself publishes.

    Source: Multiple — see below

2029
  1. 2029-2030Product DPPExpected

    Tyres and second-wave compliance

    Tyres and the first batch of 2028-act categories enter their compliance windows. Furniture and aluminium DPPs follow into 2030.

    Source: ESPR Working Plan

2030
  1. 19 July 2030HorizontalConfirmed in law

    Destruction ban extends to medium enterprises

    Fashion businesses with 50-249 employees can no longer destroy unsold stock.

    Source: ESPR Art. 24

  2. 1 August 2030Product DPPConfirmed in law

    Toy DPP mandatory

    Every toy placed on the EU market needs a Digital Product Passport. The first regulation outside ESPR/Batteries to mandate a DPP directly.

    Source: Reg 2025/2509

  3. 2030Product DPPExpected

    Mobile phones & tablets delegated act

    Last category in the current Working Plan. Compliance follows ~18 months later.

    Source: ESPR Working Plan

2031
  1. ~2031-2032Product DPPExpected

    Mobile, late-wave compliance

    Mobile, mattresses, late categories close out the current plan. A second Working Plan is likely.

    Source: Commission planning

Where sources disagree

Five contested dates worth knowing

Most online DPP timelines pick one position and present it as fact. The reality is messier — the Commission's own communications, the standards bodies and the independent trackers diverge on five questions in particular. Here's the honest read on each.

1

When does the textile delegated act actually publish?

  • European Commission Working Plan"2027" — no quarter specified.
  • eudigitalproductpassport.org (April 2026 update)Expected early 2027; DPP obligations phase in from 2028.
  • PassportCraft / industry trackersQ2 2027, with compliance late 2028 to early 2029.
  • Regen Studio (Feb 2026 analysis)Adoption pushed back from 2026 expectations; full timing still moving.

Our read

Plan against "first half of 2027" and start data collection now. Whichever quarter wins, the ~18-month compliance clock is unlikely to be extended once the act publishes.

2

Battery carbon footprint declaration — already live or still pending?

  • Foundation tracker (Reg 2023/1542)Carbon-footprint declaration for EV batteries applies from 18 February 2026.
  • Industry trackers (May 2026)Calculation methodology delegated act not yet adopted, so the obligation is effectively un-enforceable.

Our read

The obligation is in force; the methodology is not. Manufacturers should publish a best-effort CFP using ISO 14067 today and update once the methodology lands — late adopters will be caught short.

3

When does the EU central DPP Registry go live?

  • ESPR Art. 12Required before any product-category DPP can be enforced.
  • Industry trackersExpected July 2026, in time for early Working Plan acts.
  • Commission communicationsNo firm launch date announced as of mid-2026.

Our read

Treat "second half of 2026" as the working assumption. If the registry slips, product compliance dates can slip with it — but supplier data collection cannot wait either way.

4

Textile DPP compliance: 2028 or 2029?

  • Foundation trackerObligations phase in from 2028.
  • PassportCraft / WetrackLate 2028 to early 2029, depending on act publication.
  • Intertek (JRC study, May 2026)Structured phase-in across data categories rather than a single big-bang date.

Our read

There is no single "textile DPP day". Some data fields will apply earlier, others phase in. Programme planning should target end-2028 readiness for the core fields and end-2029 for the full set.

5

CEN-CENELEC harmonised standards — are they late?

  • Original Commission targetEight harmonised standards from JTC 24 by March 2026.
  • CEN-CENELEC CWA 18186 (May 2025)Workshop Agreement already published as interim technical guidance.
  • Industry observersFinal harmonised standards have slipped to mid-2026 or later.

Our read

Standards are late, but CWA 18186 plus the GS1 Digital Link standard are stable enough to design against today. Brands waiting for harmonised standards before starting are building in a delay they cannot afford.

Category lookup

When does your product need a DPP?

Adoption is when the delegated act (or primary regulation) is expected to publish. Compliance is when DPPs must actually be on products entering the EU market. Where dates are still moving, the confidence column reflects it.

CategoryAct adoptedDPP appliesConfidence
Batteries (EV / industrial > 2 kWh)Adopted18 Feb 2027Confirmed in law
ToysAdopted1 Aug 2030Confirmed in law
Construction productsAdoptedPhased 2026-2032Confirmed in law
Permanent-magnet productsAdoptedLabelling 2025 / disclosure 2027Expected
Iron & steel2026-27~2027-28Expected
Dishwashers2026-27~2027-28Expected
Textiles & apparelEarly-mid 2027~Late 2028Sources disagree
Tyres2027~2028-29Expected
Furniture2028~2029-30Expected
Aluminium2028~2029-30Expected
EV chargers2028~2029-30Expected
Fridges & freezers2028~2029-30Expected
Electric motors2028~2029-30Expected
Mattresses2028-29~2030-31Expected
Mobile phones & tablets2030~2031-32Expected
FootwearFeasibility by end-2027Not scheduledExpected
DetergentsUnder studyNot scheduledExpected
Chemicals, paints, lubricantsUnder studyNot scheduledExpected

What changes if you start now

The cost of being early is zero. The cost of being late is market access.

Whichever category you sell into, the work pattern is the same. Suppliers, IDs, resolvers and packaging cycles all take more than a year. Brands that start when the delegated act publishes are already late — the runway is built by tracking infrastructure milestones, not category deadlines.

  1. 1

    Audit product and supplier data; allocate GS1 GTINs across the catalogue.

  2. 2

    Pilot connected packaging on one SKU line and stand up a GS1 Digital Link resolver.

  3. 3

    Wire ERP, PIM and PLM into a DPP platform; agree data contracts with tier-1 suppliers.

  4. 4

    On delegated act publication, map mandatory fields to your data model and run the supplier-data drive.

  5. 5

    Twelve months before compliance, move from pilot to programme: artwork, print runs, retailer onboarding.

  6. 6

    Three months out, dry-run the EU registry and live QA every scan in the first 90 days.

Talk to SmartLinks about your categoryHow SmartLinks meets ESPR

Methodology

Sources we cross-referenced

We start from primary EU sources — the regulations themselves, the Commission's Working Plan, and the standards bodies — then triangulate against the independent trackers and legal analyses that read those texts for a living. Every date on this page is traceable back to one of the sources below.

Last reviewed June 2026. We update this page as dates move. Nothing here is legal advice — consult counsel for your category and market.