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Digital Product Passport Timeline: What Applies When?

Understand the EU Digital Product Passport timeline by category. Separate fixed application dates from planned delegated acts, studies, Registry milestones and standards.

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1 September 2026
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There is no single EU Digital Product Passport deadline. Different laws and product groups move on different tracks. A date may mean that a law was adopted, entered into force, starts to apply, that a Digital Product Passport becomes mandatory, or simply that the European Commission currently plans to adopt a future measure. Those dates are not interchangeable. The safest way to read the DPP timeline is therefore:

What happens on this date, what legal weight does it have, and does it actually change what a business must do?

For the broad category landscape, see Digital Product Passport Requirements by Product Category.

The date types that matter

Date typeWhat it meansWhat it does not automatically mean
Law adoptedThe EU legislature or Commission has formally adopted an instrument.That every obligation applies immediately.
Entry into forceThe instrument has become legally part of EU law.That its substantive requirements already apply.
Application dateThe relevant provisions start to apply.That every implementation detail was necessarily fixed years earlier.
DPP requirement appliesThe passport obligation applies to the products in scope from that date.That every other product category follows the same date.
Delegated act plannedThe Commission currently expects to adopt a product-specific measure in that period.A compliance deadline.
Implementing act plannedThe Commission expects to adopt detailed implementation rules.A new product obligation unless the parent law says so.
Study / preparatory milestoneEvidence is being developed to support future policy or law.An adopted requirement.
Registry / system milestoneA horizontal part of DPP infrastructure becomes available or operational.That every product suddenly needs a DPP.
Standards milestoneTechnical standards are published or referenced.That one standard becomes the product-specific legal field list.
Indicative dateAn official planning date that may change.A legally fixed date.

This distinction matters most for developing categories such as textiles, tyres, iron and steel and aluminium. A planned delegated-act date tells you when a regulatory decision may be made. It does not by itself tell you when businesses must comply.

The cross-category DPP timeline

Date / windowCategory or systemEventDate typeWhat it means
17 August 2023BatteriesRegulation (EU) 2023/1542 entered into forceEntry into forceBattery Passport rules were adopted in the Regulation, with the passport obligation applying later.
18 July 2024ESPRRegulation (EU) 2024/1781 entered into forceEntry into forceThe horizontal DPP architecture became law. Product-specific measures still determine the detailed passport for ESPR product groups.
8 January 2026Construction productsRegulation (EU) 2024/3110 generally began to applyApplicationThe Construction Products Regulation contains an adopted DPP-system framework, but a delegated act is still needed to operationalise the system.
22 March 2026Detergents & surfactantsRegulation (EU) 2026/405 entered into forceEntry into forceThe model-level DPP regime is adopted, but the Regulation generally applies later.
13 May 2026Textiles & apparelJRC supporting study on textile DPP publishedPreparatory workStrong evidence of possible design directions, not final textile DPP law.
15 July 2026DPP systemCommission Implementing Decision (EU) 2026/1736 referenced six harmonised DPP standardsStandards milestoneSix standards supporting DPP interoperability are formally referenced.
20 July 2026DPP systemEU DPP Registry became operationalRegistry milestoneEconomic operators can use the Registry infrastructure. It does not create one universal product deadline.
18 August 2026BatteriesStatutory date in Article 77(9) for detailed legitimate-interest access rulesLegal implementation deadlineThe parent Battery Regulation set this deadline. As at 1 September 2026, the detailed implementing act had not been identified as adopted; the Commission roadmap still shows Q4 2026.
September 2026DPP systemCommission roadmap indicates decision on the remaining two DPP standardsIndicative implementation milestoneCurrent official plan. As at 1 September 2026, no new decision had been identified in the verification pass.
Q4 2026Iron & steelCommission plans ESPR delegated actIndicative delegated-act dateExpected product-specific regulatory decision, not an application deadline.
Q4 2026BatteriesCommission roadmap indicates Battery access-rights implementing actIndicative implementing-act dateDetailed legitimate-interest access implementation remains a live update trigger.
18 February 2027BatteriesBattery Passport becomes mandatory for covered LMT, EV and industrial batteries above 2 kWhDPP application dateA legally fixed passport date for the covered battery categories.
Q2 2027Construction productsCommission roadmap indicates construction DPP delegated actIndicative delegated-act dateOperational DPP-system rules are expected. Application depends on the adopted act and the Regulation's transition mechanism.
Q2–Q3 2027DPP systemCommission roadmap indicates service-provider delegated actionIndicative horizontal implementationRules for DPP service providers remain an implementation dependency.
Q3–Q4 2027TyresCommission roadmap / Working Plan trackIndicative delegated-act dateFinal tyre DPP content is not yet established.
Q3–Q4 2027AluminiumCommission roadmap / Working Plan trackIndicative delegated-act dateFinal aluminium DPP content is not yet established.
Q4 2027Textiles & apparelCommission plans textile ESPR delegated actIndicative delegated-act dateThis is not a textile compliance deadline. Final fields, access, granularity and application timing remain to be set.
End 2027FootwearWorking Plan indicates study milestoneStudy milestoneA study is not a delegated act and does not establish a passport obligation.
2028FurnitureWorking Plan trackIndicative delegated-act yearProduct-specific requirements remain in development.
2029MattressesWorking Plan trackIndicative delegated-act yearProduct-specific requirements remain in development.
23 September 2029Detergents & surfactantsRegulation (EU) 2026/405 generally appliesApplication dateThe adopted model-level detergent/surfactant DPP regime generally applies.
1 August 2030ToysRegulation (EU) 2025/2509 appliesApplication dateThe adopted model-level Toy DPP regime applies.

Is there one DPP deadline?

No.

The phrase “the DPP deadline” is usually too imprecise to be useful.

The first major adopted product deadline in the current cross-category landscape is 18 February 2027 for the covered battery categories. That does not make February 2027 the deadline for textiles, toys, detergents, construction products or every product regulated under ESPR.

A category can also have an adopted passport regime years before its application date. Detergents and toys are already useful examples: their legal passport architectures are adopted, but their general application dates are 23 September 2029 and 1 August 2030 respectively.34

When do Battery Passports apply?

For the batteries covered by Article 77 of Regulation (EU) 2023/1542, the Battery Passport applies from 18 February 2027.2

The covered groups are:

  • light means of transport batteries
  • industrial batteries with a capacity greater than 2 kWh
  • electric-vehicle batteries.

This is a legally fixed product-passport application date, not an indicative planning date.

The Battery regime still has implementation work around it. In particular, Article 77(9) required detailed rules for people with a legitimate interest. The statutory date for that implementing act was 18 August 2026. The Commission's current implementation roadmap instead places the access-rights implementing act in Q4 2026. That implementation delay should be shown, not hidden by rewriting one date into the other.26

See Who Can See What in a Digital Product Passport? for the access architecture.

What does the textile Q4 2027 date mean?

It means the Commission currently plans to adopt the textile ESPR delegated act in Q4 2027.7

It does not mean:

  • every textile business must have a DPP by 1 January 2028
  • the final textile DPP fields are already known
  • factory data is already a mandatory textile DPP field
  • carbon or recycled content are already legally fixed DPP fields
  • textile passports are already known to be item-level.

The May 2026 JRC study is important preparatory evidence because it explores possible information and architecture. It is not the final delegated act.8

A future adopted textile act will need to be read for its own entry-into-force and application provisions before a legal compliance date can be stated.

When do detergent DPP rules apply?

Regulation (EU) 2026/405 creates an adopted DPP for detergents and end-user surfactants. The Regulation generally applies from 23 September 2029.3

The passport is model-level by default. Important technical details, including detailed access allocation and carrier rules, remain subject to implementing action.

That combination is useful: the core obligation can be adopted while implementation detail is still pending.

When do Toy DPP rules apply?

The Toy Safety Regulation creates an adopted model-level DPP applying from 1 August 2030.4

The law already establishes the minimum DPP information architecture. Detailed technical and access rules can still be supplemented before application.

Again, adoption and application are separate dates.

What is happening with iron and steel?

Iron and steel is the nearest major ESPR product-specific act on the current Commission roadmap.

The Commission currently indicates Q4 2026 for adoption of the delegated act and expressly describes the timetable as indicative.9

Official material discusses possible territories such as product identity and classification, technical and material information, circularity and recycled content, sustainability and compliance/traceability. The exact information requirements remain for the delegated act to decide.

The correct public wording is therefore:

The Commission currently plans the iron and steel delegated act for Q4 2026. The exact DPP requirements and application timing are not final until the act is adopted.

What dates matter for tyres and aluminium?

Both are on the 2027 ESPR product-measure track.56

For tyres, existing EU tyre-label and product-database rules already structure substantial product information. That is adjacent law. It should not be converted into a final tyre DPP dataset before the product-specific act is adopted.

For aluminium, the same timing discipline applies: 2027 is the current regulatory-development track, not a single fixed compliance date.

When did the EU DPP Registry become operational?

The Registry became operational on 20 July 2026.10

This is an important horizontal infrastructure milestone. It means the EU registration layer exists before the first major Battery Passport application date.

It does not mean the Registry stores the full content of every passport. The Commission describes the wider architecture as decentralised, while the Registry stores identifiers and the mandatory registration data required for regulatory functions.1011

See EU DPP Registry: Where Passport Data Actually Lives.

What is happening with DPP standards?

Commission Implementing Decision (EU) 2026/1736 referenced six harmonised DPP standards in July 2026. They cover:

  • data exchange protocols
  • unique identifiers
  • data carriers
  • data storage, archiving and persistence
  • APIs for passport lifecycle management and searchability
  • system interoperability.12

The Commission's current roadmap indicates an implementing decision on the remaining two standards in September 2026.6

As at the last verification on 1 September 2026, this remained an upcoming current-month event rather than an adopted additional decision identified in the evidence pass.

Which future events should businesses monitor?

The highest-value triggers are not every consultation date. They are events capable of changing a real implementation decision.

Near-term

  • remaining DPP standards decision, currently indicated for September 2026
  • Battery access-rights implementing act, currently indicated for Q4 2026
  • iron and steel delegated act, currently indicated for Q4 2026.

2027

  • Battery Passport application on 18 February 2027
  • construction DPP-system delegated act
  • DPP service-provider delegated rules
  • textile, tyre and aluminium delegated acts
  • footwear study outcome.

Later adopted dates

  • detergent/surfactant Regulation generally applying 23 September 2029
  • Toy Safety Regulation applying 1 August 2030.

For what to organise before those events, see What Product Data Should Businesses Prepare Now for Digital Product Passports?.

Direct answers

Is 2027 the universal DPP deadline?

No. It includes the Battery Passport application date and several planned regulatory milestones, but different categories follow different laws and dates.

Is Q4 2027 the textile DPP deadline?

No. It is the Commission's current indicative timing for adoption of the textile delegated act.

Does a delegated act apply on the day it is planned or adopted?

Not necessarily. The adopted act must be read for its entry into force, transition and application provisions.

What is the first major fixed DPP application date?

In the current cross-category set, 18 February 2027 for the covered battery categories.

What does “indicative” mean?

It means an official planning date that can move as legislative or technical work progresses.

Keep exploring

The questions this page usually raises next.

Does this reach your products?

Give ActivateDigital one product and it works out which obligations apply from the product's own character, and says which it cannot decide.

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Primary sources

This resource explains regulatory status and timing. It is not personalised legal advice.