The Digital Product Passport Timeline: Every Deadline from 2026 to 2030, and Which Ones Are Actually Fixed
"When is the Digital Product Passport mandatory?" is the most common question a compliance lead gets asked, and it has no single answer. DPP obligations do not come from one law. They come from at least five, only one of which is the Ecodesign for Sustainable Products Regulation itself.
That matters because the dates circulating in industry decks come from two very different places. Some are statutory: written into a regulation that is already in the Official Journal, binding on a named class of products, and enforceable. Others are indicative: planning assumptions published by the Commission in a working plan, carrying no legal force, and explicitly labelled as subject to change. Teams that mix the two columns end up either building for a deadline that does not exist, or missing one that does.
Here is the full calendar to 2030, sorted properly.
Column A: the dates that are fixed in law
These are in force. They do not depend on any further act being adopted, and no Commission slippage moves them.
| Date | What happens | Instrument |
|---|---|---|
| 18 July 2024 | ESPR enters into force; Ecodesign Directive 2009/125/EC repealed | Regulation (EU) 2024/1781 |
| 19 July 2026 | Ban on destroying unsold textiles, clothing accessories and footwear applies to large companies | ESPR Article 25 and Annex VII |
| 20 July 2026 | EU central DPP Registry operational | Commission DPP hub |
| 31 July 2026 | Right to Repair Directive applies in Member States | Directive (EU) 2024/1799 |
| 18 February 2027 | Battery passport mandatory for every EV battery, LMT battery and industrial battery above 2 kWh | Regulation (EU) 2023/1542, Article 77 |
| 23 September 2029 | DPP mandatory for every detergent and end-user surfactant placed on the EU market | Regulation (EU) 2026/405 |
Two more sit in this column with a caveat. The toy Digital Product Passport under Regulation (EU) 2025/2509 is fixed in substance - the regulation is adopted and the DPP is written into it as the replacement for the paper EU declaration of conformity - and runs on the transition period set out in that regulation rather than on anything ESPR does. Construction products are similar but looser: the recast Construction Products Regulation (EU) 2024/3110 entered into force on 7 January 2025 and merges the declaration of performance and declaration of conformity into a single DoPC, but the construction DPP itself arrives per product family through delegated acts, with manufacturers given 18 months from the entry into force of the act establishing the construction DPP system.
Note what is not in this column: any ESPR ecodesign delegated act. As of September 2026, none has been adopted.
Column B: the indicative dates
The ESPR and Energy Labelling Working Plan 2025-2030, COM(2025) 187, was adopted on 16 April 2025. It names six priority product groups and gives each an indicative year for adoption of its delegated act:
- Iron and steel - indicatively 2026
- Textiles and apparel - indicatively 2027
- Aluminium - indicatively 2027
- Tyres - indicatively 2027
- Furniture - indicatively 2028
- Mattresses - indicatively 2029
Every one of these is a planning assumption. And there is a second layer of distance between the indicative year and your compliance date: ESPR provides that ecodesign requirements generally apply no earlier than 18 months after the relevant delegated act enters into force. The delegated-act year is not the compliance year. A textiles act adopted in 2027 does not bite in 2027.
The furthest advanced of these is textiles, where the Commission's impact assessment is supported by a Joint Research Centre technical study with stakeholder consultation running through 2026, and a proposal expected late 2026 or early 2027. That is the pattern to watch for every other group: preparatory study, then consultation, then draft act, then an 18-month runway.
The proof that indicative means indicative
The most useful data point of 2026 is not an industry deadline. It is one the Commission set for itself and missed.
Article 77(9) of the Batteries Regulation requires the Commission to adopt an implementing act specifying who has a legitimate interest in accessing the non-public parts of the battery passport, and what they may do with the data once they have it - download it, share it, republish it. The statutory deadline for that act was 18 August 2026. It came and went with nothing published in the Official Journal, and the Commission's own timetable now places the act in the fourth quarter of 2026.
The 18 February 2027 obligation did not move by a single day.
So a manufacturer is currently building a battery passport with three access tiers - public data under point 1 of Annex XIII, authority-only data, and legitimate-interest data - while the rules defining who qualifies for the third tier do not yet exist. That is the asymmetry in one sentence: regulator-side deadlines slip, operator-side deadlines do not. Nothing in the record so far suggests the Commission will move a statutory application date to compensate for its own delay in producing the instruments that make compliance easier.
What this means for a plan you have to defend
Work backwards from Column A only. If your board asks why a programme is funded, the answer has to point at a date in a regulation, not a date in a working plan. Batteries, detergents, toys, and the unsold-goods ban are all defensible on that basis. "Textiles 2027" is not.
Treat Column B as a consultation calendar, not a compliance calendar. The indicative year tells you roughly when the preparatory study and stakeholder consultation for your product group opens - which is the only window in which the data fields are still negotiable. After the delegated act is drafted, you are implementing someone else's data model. Before it, you can argue about which fields are technically feasible for your supply chain to populate.
Stage supplier data collection ahead of the act, not after it. The binding constraint in almost every DPP programme is not the software. It is getting a tier-two or tier-three supplier to provide substance, recycled-content or carbon data in a structured form, under contract, with something behind it. That work takes longer than the 18-month runway, and it is the same work regardless of which column your date sits in.
Do not wait for missing implementing acts. Build for the access tiers the primary regulation already describes, and design the permission layer so it can be reconfigured when the act finally lands. A system that assumes the access rules are known is a system you will rebuild in 2027.
The three dates to hold, whatever you make
20 July 2026 - the Registry is live. The routing infrastructure every EU passport will eventually pass through exists now, and registration is the step most teams discover late.
18 February 2027 - the battery passport. Even if you never touch a battery, this is the first hard DPP deadline in EU law and the live test of whether the Registry, the identifiers and the data carriers work at volume. What breaks here gets fixed before your act lands.
18 months after your own delegated act enters into force - whenever that turns out to be. It is the only deadline on this page you cannot yet write in a calendar, and the only one that is genuinely about your product.
Everything else is a date someone else has to meet first.
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