Digital Product Passport: Which Product Groups Are Affected?

For companies, this distinction matters. “Textiles 2027” does not mean, for example, that every garment must have a Digital Product Passport from 1 January 2027. The year initially refers to the planned date for the product-specific legal act. Only that act will define exactly which products are covered, which data is required and when the obligations actually apply.

This page therefore groups the affected product categories by their actual legal status.

Important Note

Which Products Will Need a Digital Product Passport?

The following overview covers the most important product groups currently in scope. It deliberately distinguishes between obligations that have already been adopted and product groups that, for now, appear only in the European Commission’s working plan.^[1]

For iron and steel, textiles, tyres, aluminium, furniture and mattresses, the years shown are only the planned years for adopting the respective legal acts. There is not yet a binding application date for these product groups.

Product Groups with an Already Adopted Passport Requirement

Batteries: the First Fixed DPP Date

The battery passport is the first major, fixed-date application of a sector-specific Digital Product Passport.

From 18 February 2027, the following batteries will require a battery passport:^[2]

• Batteries for light means of transport, such as e-bikes and e-scooters
• Electric vehicle batteries
• Industrial batteries with a capacity greater than 2 kWh

Small portable batteries are not automatically covered by this specific battery passport obligation. The date is nevertheless especially relevant for companies in the automotive, battery, engineering and logistics sectors because the required information must be brought together across several tiers of the supply chain. This may include the origin of raw materials, the carbon footprint, recycled content and the battery’s condition.

Volvo introduced a battery passport for the EX90 ahead of the statutory deadline. According to the company, this required much more detailed traceability of components and raw materials than had previously been standard in vehicle manufacturing.^[3]

Construction Products: Legal Framework in Place, Start Date Still Open

The new EU Construction Products Regulation contains a dedicated Digital Product Passport system for construction products. The technical and organisational foundation has therefore already been adopted.

There is not yet a fixed calendar date for the obligation. The European Commission must first adopt a delegated act establishing the system. The system is intended to become operational six months after that act enters into force, while the obligations for manufacturers begin 18 months after its entry into force.^[4]

For manufacturers of construction materials and products, this means the obligation does not begin automatically with the general application of the Construction Products Regulation. Even so, it is worth structuring existing declarations of performance, technical documentation, environmental information and product identifiers now.

The construction product passport is intended to be compatible with the general DPP system under the Ecodesign Regulation while accounting for the specific needs of the construction sector and Building Information Modelling.

Detergents and Surfactants

A Digital Product Passport has also been adopted in law for detergents and surfactants supplied directly to end users.

The new EU regulation on detergents and surfactants will largely apply from 23 September 2029. Before placing a product on the market, manufacturers must create a Digital Product Passport for the relevant product model. Among other things, the passport must document product conformity and be accessible through a data carrier on the packaging or label, or at the refill station for refill systems.^[5]

For the sector, this is more than another QR code. Formulations, labelling, conformity data and information for authorities will need to be connected technically and kept up to date over long periods.

Toys

A dedicated Digital Product Passport has also been adopted for toys. Before placing a toy on the market, manufacturers will need to create a passport that primarily supports evidence of product safety and conformity.

The relevant provisions apply from 1 August 2030. Earlier dates sometimes mentioned in connection with the new Toy Safety Regulation concern individual procedural rules, not the general DPP obligation for toys.^[6]

The long lead time should not obscure the fact that toys often consist of numerous materials, components and supplier parts. For imported goods and private-label products in particular, companies should clarify early who will provide the required evidence and who will be responsible for the passport.

Vehicles

A Digital Circularity Vehicle Passport is planned for vehicles. It is not part of the general ESPR priorities but is governed through a separate vehicle regulation.

The exact calendar date has not yet been set. Under the final legal text, the obligation is intended to begin on the first day of the month following a period of 72 months after the regulation enters into force. Technical implementing rules are to be developed beforehand.^[7]

A blanket claim such as “vehicle passport from 2028” or “from 2030” is therefore not reliable at present. An electric vehicle may also be covered by both a vehicle passport and a battery passport. The systems are intended to connect information wherever possible rather than request the same data several times.

The First ESPR Wave: Product Groups in the Working Plan

Alongside the sector-specific passports already adopted, the ESPR Working Plan 2025–2030 identifies the product groups for which the European Commission intends to develop concrete ecodesign requirements first.

The Digital Product Passport is a possible or expected component of each measure. The relevant delegated act will determine which data actually belongs in the passport and whether it is maintained at model, batch or individual-product level.

Iron and steel

A delegated act for iron and steel is scheduled for adoption in 2026, placing the sector in the first group under the ESPR Working Plan.

This does not mean that steel products will need a passport in 2026 or automatically in 2027. Only once the legal act is published will it be clear which steel products and intermediate products are covered and how long the transition period will be.

For steelmakers and processing companies, connecting material origin, production methods, carbon data, recycled content and batch information is likely to be especially relevant.

Textiles and apparel

The product-specific legal act for textiles and apparel is planned for 2027. The binding start of the requirements is therefore expected to come later. No fixed compliance date has yet been adopted.

Fashion brands are not the only businesses that may be affected. Manufacturers and retailers of home textiles, bedding, curtains, towels and other textile products should also monitor developments. The legal act will determine exactly which subgroups are covered and which exemptions apply.

In the textile industry, the real challenge is less the visible QR code than the data behind it. Material composition, origin, processing, substances of concern, care, repair and recycling information must be brought together from often lengthy international supply chains.

The statement comes from an interview about DPP preparation in the fashion industry.^[8]

Tyres

A delegated act for tyres is also planned for 2027. As with textiles, this is not the start date of the obligation.

Tyres are already subject to various labelling, safety and energy-efficiency requirements. The future legal act could add information on durability, material composition, abrasion, recyclability and recycled content. The final scope has not yet been defined.

Aluminium

Aluminium is also scheduled to be addressed by a product-specific legal act in 2027.

As with steel, information from upstream supply chains is expected to play an important role. This may include the production route, energy use, origin, alloy, recycled content and environmental indicators. Which data will become mandatory remains open.

Furniture

A legal act for furniture is scheduled for adoption in 2028.

The product group is broad: a piece of furniture may contain wood, metal, plastics, textiles, foams, adhesives, coatings and electrical components. A structured bill of materials is therefore likely to become particularly important. Information on spare parts, repair, disassembly and recycling may also play a role.

There is currently no binding date for a furniture passport.

Mattresses

Mattresses are treated as a separate product group in the ESPR Working Plan. The legal act is scheduled for 2029.

This matters because mattresses are not simply included under furniture or home textiles. Their construction from foams, springs, textiles, adhesives and other materials creates distinct challenges for recyclers.

A Digital Product Passport could later show how a mattress is constructed, which materials can be separated and how it should be processed at end of life. The specific requirements and compliance date have not yet been set.

Electronics and Other Energy-related Products

The situation is more complex for electrical and electronic products. The working plan includes both horizontal requirements and measures for individual product groups.

A horizontal measure on repairability is planned for 2027 and may cover consumer electronics and small household appliances, among other products. A further horizontal measure on recycled content and the recyclability of electrical and electronic equipment is planned for 2029.

In parallel, the working plan continues numerous energy-related product groups.

Not every one of these products will necessarily receive a conventional Digital Product Passport. For energy-labelled products, the existing European Product Registry for Energy Labelling (EPREL) may be used as an equivalent digital system or connected to the DPP. The decision will be made in each product-specific legal act.

Product Groups Being Assessed but without a Timetable

Several additional product groups are often mentioned in connection with the Ecodesign Regulation but are not yet included in the binding working programme for a product-specific DPP.

Footwear

Footwear is assessed separately from apparel because its construction, materials, function and supply chains differ significantly. A dedicated study is due to be completed by the end of 2027. There is no DPP date.

Chemicals, Polymers and Plastics

An initial fundamental assessment is planned for chemicals. Among other questions, it will examine whether and how basic chemicals, speciality chemicals, polymers and plastics could be covered.

There is currently neither a completed product-specific legal act nor a binding DPP date.

Paints and Lubricants

Paints and lubricants were also considered in the broader prioritisation process but were not included in the first working plan.

Companies should therefore not rely on publications that already claim a fixed DPP compliance year for footwear, chemicals, plastics, paints or lubricants.

What Does This Mean for Manufacturers, Importers and Distributors?

Not every company needs to introduce a complete DPP platform immediately. Waiting until every detailed rule has been published would also be risky. The greatest effort usually lies not in the technical presentation of the passport but in sourcing and maintaining the product data.

This usually reveals gaps that should be closed regardless of the final DPP data schema.

The data structure should remain flexible. Each product group will have its own rules on which fields are mandatory and whether a passport must be created for a model, batch or individual product.

Conclusion: The DPP Obligation Does Not Begin on One Single Date

The Digital Product Passport is being introduced gradually by product group.

Fixed dates already exist for batteries, detergents and surfactants, and toys. For construction products and vehicles, the obligation has been adopted, but the exact calendar date still depends on further legal acts or their entry into force.

Iron and steel, aluminium, textiles, tyres, furniture and mattresses are among the main ESPR priorities. The years in the working plan are not compliance dates; they initially indicate when the European Commission intends to adopt the respective rules.

For companies, this means there is no reason to panic, but there is a strong reason to put product data in order now. Businesses that wait until shortly before the deadline to clarify material data, supplier evidence, product identifiers and approval processes will start most of the work too late.