Understanding when the Digital Product Passport becomes mandatory for your sector is critical for planning your compliance roadmap. Here is the full timeline as currently known, along with immediate action items for each phase.
2024–2025: Regulation Published, Prepare Now
- July 2024: ESPR enters into force. Commission begins drafting delegated acts for priority sectors.
- Now: Map your product portfolio against ESPR working plan categories. Identify which product lines will need a DPP first.
- Now: Audit your supply chain data — most companies discover they lack the material composition and carbon footprint data that DPPs will require.
- Now: Choose a DPP platform (like D-Pass) and start a pilot with one product line.
2027: Batteries Go Live
- 18 February 2027: Industrial batteries ≥2 kWh, LMT batteries, and EV batteries require a full DPP under Regulation (EU) 2023/1542. Portable batteries follow in 2028.
- By end 2026: All battery manufacturers/importers must have DPP infrastructure ready, carbon footprint declared, recycled content documented.
2026–2028: Textiles and ICT
- Textile DPP delegated act expected Q2 2026, with 18-month transition — mandatory ~late 2027/early 2028.
- ICT (smartphones, tablets, laptops) DPP expected 2027, mandatory 2028–2029.
- These sectors require fiber composition, country of origin, repairability score, and care instructions in the DPP.
2028–2030: Steel, Aluminium, Furniture, Chemicals
- Regulated materials (steel, aluminium) face DPP requirements for embedded carbon footprint and recycled content.
- Furniture: durability, repairability, hazardous substance data.
- Chemicals: Safety Data Sheets integration into DPP format.
Your 12-Month Action Plan (Starting Today)
- Month 1–2: Identify which of your products are in scope. Assign a DPP project owner.
- Month 3–4: Conduct a data gap analysis. What material composition, carbon, and supply chain data do you have vs. need?
- Month 5–6: Select and onboard a DPP platform. Run a pilot for your highest-risk product line.
- Month 7–9: Engage your supply chain — request the data you need from tier-1 and tier-2 suppliers.
- Month 10–12: Complete first DPPs. Commission third-party verification if your sector requires it.