DPP deadlines and status by product category
Find which product groups have adopted duties, which ones are still work-plan signals, and what practical data work should start now.
Adopted law
1
Work-plan categories
6
Horizontal measures
2
Market guidance
1
Act now
Start with these product and buying decisions.
These are not all the same kind of obligation. They are the rows where an operator should already have a data owner, source owner, or vendor question ready.
| Product category | Status | Timing | Market signal | Source | Affected operators | Action | Priority |
|---|---|---|---|---|---|---|---|
| ESPR digital product passport framework Article 9 links mandatory passports to product-specific delegated acts; Articles 10-11 set core passport requirements. | Framework | In force since 18 Jul 2024; duties depend on delegated acts | No estimate published | ESPR legal text Regulation (EU) 2024/1781, Articles 9-11 | Operators selling physical products into the EU market | Separate framework requirements from product-category obligations before writing any compliance claim. | Act now |
| Batteries Article 77 sets the electronic record date and scope; Article 13 links the passport to the QR code. | Adopted law | Passport required from 18 Feb 2027 for scoped batteries | No estimate published | Battery Regulation Regulation (EU) 2023/1542, Article 77 | LMT batteries, industrial batteries over 2 kWh, and electric vehicle batteries | Map battery models, individual-battery data, QR access, unique identifiers, and update responsibility. | Act now |
| Iron and steel Listed as the first ranked intermediate product in the working plan. | Work plan | Indicative adoption: 2026 | EUR 152bn EU market size (2023) | ESPR working plan 2025-2030 COM(2025) 187 final, ESPR working plan | Iron, steel, importers, processors, and downstream products using major steel inputs | Track the delegated act and start source mapping for material grade, supplier evidence, carbon data, and recycled-content claims. | Act now |
| Textiles and apparel Ranked first among final products, with high support and high improvement potential. | Work plan | Indicative adoption: 2027 | EUR 78bn textiles/apparel; EUR 142bn including footwear (2019) | ESPR working plan 2025-2030 COM(2025) 187 final, ESPR working plan | Fashion, apparel, textile, ecommerce, and brand operators | Inventory SKU hierarchy, material composition, supplier evidence, care data, and public sustainability claims. | Act now |
| Tyres Ranked third among final products; the working plan notes existing tyre labelling legislation and end-of-life tyre risks. | Work plan | Indicative adoption: 2027 | EUR 45bn EU market size (2021) | ESPR working plan 2025-2030 COM(2025) 187 final, ESPR working plan | Tyre manufacturers, importers, fleets, and mobility suppliers | Track recycled-content, recyclability, and end-of-life tyre evidence before turning pilots into compliance claims. | Act now |
| Aluminium Listed as an intermediate product with improvement potential across climate, energy, air, water, biodiversity, soil, and raw materials. | Work plan | Indicative adoption: 2027 | EUR 40bn EU market size (2019) | ESPR working plan 2025-2030 COM(2025) 187 final, ESPR working plan | Aluminium producers, importers, component makers, and high-material-use products | Prepare supplier evidence for recycled content, emissions, origin, and downstream data handoff. | Watch closely |
| Furniture Ranked second among final products in the working plan. | Work plan | Indicative adoption: 2028 | EUR 140bn EU market size (2021) | ESPR working plan 2025-2030 COM(2025) 187 final, ESPR working plan | Furniture, home goods, contract furniture, and importers | Map materials, repairability, durability, product lifetime evidence, and supplier documentation. | Watch closely |
| Repairability horizontal requirement The working plan lists repairability, including scoring, as a horizontal requirement; exact scope is still to be refined. | Horizontal | Indicative adoption: 2027 | No estimate published | ESPR working plan 2025-2030 COM(2025) 187 final, ESPR working plan | Potentially consumer electronics, small household appliances, and similar product groups | Collect repair documentation, spare-part logic, durability evidence, and scoring assumptions. | Watch closely |
| Mattresses Ranked fourth among final products, with high support and potential for waste, lifetime, and material-efficiency improvements. | Work plan | Indicative adoption: 2029 | EUR 10bn EU market size (2022) | ESPR working plan 2025-2030 COM(2025) 187 final, ESPR working plan | Mattress, bedding, home goods, hospitality, and importers | Map material layers, supplier evidence, product lifetime claims, and end-of-life data. | Watch closely |
| Electrical and electronic equipment The working plan lists recycled content and recyclability of electrical and electronic equipment as a horizontal requirement. | Horizontal | Indicative adoption: 2029 | No estimate published | ESPR working plan 2025-2030 COM(2025) 187 final, ESPR working plan | Electrical and electronic equipment operators | Prepare recycled-content, recyclability, component, repair, and supplier data models. | Watch closely |
| DPP software and service providers ESPR refers to service providers and backup copies, but a vendor demo is not the same as product-category compliance. | Market | Market forming; service-provider rules still depend on delegated acts | No estimate published | ESPR framework ESPR Articles 10-11 and future product delegated acts | Brands, manufacturers, importers, and consultants buying DPP tooling | Ask vendors to map each compliance claim to a source, export path, access-right model, and update workflow. | Act now |
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