Table of Contents
The Digital Product Passport (DPP) is a unique digital record for each physical product placed on the market in the European Union.
It can be accessed via a QR code or NFC tag linked to the product, and centralises data on supply chain traceability, material composition, environmental impact and repair or recycling options at the end of its useful life.
It is not a set of rules with a single date of entry into force: it is a phased timetable which the European Commission is finalising sector by sector through delegated acts.
When does it come into force in your sector?
The roll-out is taking place in phases, prioritising first those sectors with the greatest environmental impact or the highest volume of products on the European market:
- First mandatory sector (2027): batteries for electric vehicles, light transport and industrial vehicles with a capacity of more than 2 kWh. This is the only DPP with a fixed deadline laid down by regulation: 18 February 2027. Its requirements have already been defined (composition, recycled content, carbon footprint, condition) and it serves as a technical model for the other sectors.
- Textiles and iron/steel (2027–2028): delegated acts are expected throughout 2026, with actual entry into force between mid-2027 and 2028, following the standard 18-month transition period. Furthermore, for the textiles sector, a separate milestone has already been reached: from 19 July 2026, large companies will no longer be permitted to destroy unsold stocks of textiles or footwear.
- Second phase (2028–2029): aluminium, tyres, furniture, mattresses and construction materials (cement, insulation), depending on when the delegated act for each category is published.
- Electronics and small household appliances (2028–2031): this is the sector with the longest timeframe within the horizontal measure on reparability. Caution should be exercised regarding sources that place this date as early as 2027: as things stand, there is no delegated act confirming this date.
- General roll-out (from 2030 onwards): the Commission’s aim is that, by this date, the majority of products placed on the market in the EU will have their DPP, although the actual pace will depend on the progress of the pending delegated acts.
Ahead of any sector-specific deadlines, there is a common infrastructure that is already in place: the European Commission’s Central Register, where the unique identifiers for all DPPs will be stored, must be operational by 19 July 2026 at the latest.
What information will the DPP contain?
The DPP is not a static PDF, but a dynamic technical data sheet that is updated throughout the product’s life cycle. It comprises four main sections:
- Identification and origin: Unique product identifier, traceability of raw materials and manufacturing sites, responsible economic operators.
- Composition and substances: Exact composition of materials, % recycled content, substances of concern/restricted substances (REACH).
- Environmental impact: Carbon footprint, EU Environmental Footprint (PEF), water footprint.
- Circularity and end of life: Instructions for repair, dismantling and recycling; expected lifespan; and, for batteries: state of health and remaining capacity.
The legal framework: ESPR
The DPP stems from the Ecodesign Regulation for Sustainable Products (ESPR, Regulation (EU) 2024/1781), which has been in force since July 2024. The ESPR sets out the general framework; it is the subsequent delegated acts – one for each product category – that determine what data is required and from when. Batteries are also governed by their own regulation (EU 2023/1542), which is separate from the ESPR.
Responsibility
What to do if your sector hasn’t yet set a date
There’s no need to wait for the delegated act to start preparing. Companies that get a head start avoid last-minute implementations: fully commissioning a DPP system usually takes between 18 and 36 months when the product catalogue is complex. Here are three areas where progress can be made right away:
- Digitise existing product data: raw materials, certificates, emissions, composition. If that information is currently scattered across spreadsheets or relies on several people, that is the first bottleneck.
- Define data governance: who is responsible for keeping the DPP up to date in the event of, for example, a recall, a change in formulation or a resale.
- Monitor the publication of delegated acts relating to one’s own sector, so as to scale the project with sufficient lead time and avoid working under deadline pressure.
Frequently Asked Questions
Will the DPP be compulsory by 2026?
Not across the board. The common infrastructure (central register, technical standards) will be rolled out in 2026, but no sector-specific DPP is yet mandatory. The first actual obligation comes into force in February 2027, relating to batteries.
Does this affect companies that are not based in the EU?
Yes. Any company that sells physical products on the European market must comply with the DPP requirements for its category, regardless of where its headquarters or manufacturing facilities are located, including sales via e-commerce platforms or distributors based in the EU.
Does the DPP replace other requirements, such as energy labelling?
Not automatically. For products already registered in EPREL (energy label), the ESPR provides for the possibility of exempting them from an additional DPP, but this exemption must be expressly stated in the delegated act for each category; it does not apply by default.
What happens if no delegated act has yet been published for my sector?
You can start organising your data and internal governance right away. When the delegated act for your category is published, that work will be integrated into the system without you having to build it from scratch under time pressure.
If your product is in the textiles sector, the timetable already affects you directly. If you work in cosmetics, biocides, plant protection products, fertilisers or medical devices, your sector is not yet included in the DPP timetable, but the data it will require when the time comes — carbon footprint, life cycle assessment, environmental labelling, and composition under REACH and CLP — are the same as those currently required by other sustainability regulations, and are precisely what we at KAELTIA address through our eco-design services. Starting to prepare this information now does not depend on whether your sector already has a fixed deadline.
If you’d like to assess how the DPP affects you and where to start, please get in touch with our team.
