In depth

Digital Product Passport

The European regulatory framework: in depth

Where it all comes from

In 2020 Europe adopted a plan to move to a circular economy: the Circular Economy Action Plan (CEAP).

The Circular Economy Action Plan led to the ESPR, the framework for product design. The Digital Product Passport is one of its tools: it makes the required data available for the products covered, in accordance with applicable delegated acts and sector-specific legislation.

ESPR: the root of the passport

The Ecodesign for Sustainable Products Regulation is the framework law, in force since July 2024. On its own it does not set obligations product by product: it lays down the general rules and refers, for each sector, to a delegated act stating which data is needed and from when. For a company this means it will have to collect and publish in the passport information such as material composition, recycled content, repairability and end-of-life instructions. The first sectors in focus are iron and steel, textiles, aluminium and tyres.

Circular Economy Act: an initiative in preparation

The Commission is preparing the Circular Economy Act and plans to propose it by the end of 2026 to support the market for secondary raw materials and the circular economy. This is a legislative initiative timetable, not the date when new business obligations apply.

Two families of rules, one direction

Ecodesign for Sustainable Products Regulation

The ESPR provides the framework: delegated acts will define the products covered, passport data and application dates. Adopting an act does not immediately trigger an obligation: adoption, entry into force and application are distinct stages.

Specific rules for certain sectors

Other legislation provides for passports for specific categories, such as batteries and detergents, with its own scope and timelines. For packaging, the PPWR governs labels and digital data carriers: these obligations do not all amount to a DPP.

Both sets of rules require reliable data throughout the supply chain. Suppliers may be asked for information for a customer’s passport: this does not automatically require a separate DPP for every component or material.

Batteries
From 18 February 2027, Article 77 of Regulation (EU) 2023/1542 requires a passport for light means of transport batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries placed on the market or put into service. This date is set by the Regulation and does not apply indiscriminately to all batteries.
New rules, new obligations and set timelines for each sector
Discover the dates
Packaging (PPWR)
Regulation (EU) 2025/40 generally applies from 12 August 2026, with later, specific obligations for labels and digital data carriers. The dates in Article 12 also depend on implementing acts. The PPWR does not impose a universal DPP for all packaging; information to be coordinated with any product passport depends on the applicable requirements.
New rules, new obligations and set timelines for each sector
Discover the dates
Detergents
Regulation (EU) 2026/405 provides for a digital passport for each detergent model and each surfactant model intended for the end user. It generally applies from 23 September 2029, with transitional provisions. Digital labelling is distinct from the passport and does not replace all physical information in every case; implementing acts specify the DPP’s technical requirements.
New rules, new obligations and set timelines for each sector
Discover the dates

Extended producer responsibility (EPR)

Whoever places a product on the market is also responsible for when that product becomes waste: they must contribute to its collection, recycling and reporting.
EPR does not in itself create a general digital passport obligation. Some required data, such as materials and end-of-life destination, may also be useful for the DPP, depending on the rules for each sector.
It already applies today to many categories, from packaging to electronic equipment.

Environmental claims
(Empowering Consumers)

Since 27 September 2026, the new rules under Directive (EU) 2024/825 have applied. They prohibit, among other practices, generic environmental claims without recognised excellent environmental performance relevant to the claim, and claims about an entire product that concern only one aspect of it.
Traceable data can help substantiate specific, verifiable claims. Having a DPP or a chain of custody does not automatically make a claim lawful and does not replace legal requirements.

The dates,
in brief

Sectors regulated by the ESPR

The Commission’s timetable indicates when it plans to adopt acts for different products. Plans may change: these are not the dates when passports automatically become mandatory. Scope, required data and application will be specified in each act.

The delegated act is not the deadline

Article 4(4) of the ESPR generally provides for at least 18 months between a delegated act’s entry into force and its application, with justified exceptions. Adoption, publication and entry into force are distinct stages: the actual date must be checked in the act.

To identify the applicable deadline:
check the product, the adopted act and its application date.

Regulatory timelines and sectors involved

Sector	Legal basis	Adoption / preparation (planned)	Application of the DPP obligation
LMT, EV and industrial batteries > 2 kWh	Reg. (EU) 2023/1542, Art. 77	Regulation adopted	18 February 2027
Textiles and clothing	ESPR	Q4 2027 (indicative)	To be set in the delegated act
Iron and steel	ESPR	Q4 2026 (indicative)	To be set in the delegated act
Aluminium	ESPR	2027 (indicative)	To be set in the delegated act
Footwear	ESPR Working Plan 2025–2030	Study expected by the end of 2027	Timeline to be determined
Consumer electronics (ICT)	ESPR	2029 (indicative)	To be set in the delegated act
Furniture	ESPR	2028 (indicative)	To be set in the delegated act
Tyres	ESPR	2027 (indicative)	To be set in the delegated act
Construction products	Reg. (EU) 2024/3110	DPP system act planned for 2027	Depends on the acts and products covered

Sources checked: 4 November 2026. Indicative dates concern the adoption or preparation of acts, not a deadline already fixed for businesses.

Official sources

The common thread

Verifiable claims

Different names and acronyms, one direction: what a company claims about its product must be provable with verifiable data. The digital passport is the tool that makes this data available, and The Nest Company specialises in making it certain from the source.

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