Products in scope · as of August 2026
The short answer: eventually, nearly all physical products in the EU single market – but not all at once. Batteries lead the way (18 February 2027), followed by the priority groups from the ESPR working plan: iron & steel, textiles, tyres, aluminium, furniture, mattresses. Here is the full scope – including what is exempt.
01 — Short answer
The ESPR (EU) 2024/1781 is deliberately designed as a framework regulation: in principle it covers all physical goods placed on the market or put into service in the EU – whether B2C or B2B, and whether manufactured inside or outside the EU. Which product group actually needs a Digital Product Passport, and when, is set by the European Commission through delegated acts.
The order is laid out in the ESPR working plan 2025–2030 (April 2025). Priority goes to product groups with the biggest environmental leverage: iron & steel, aluminium, textiles and apparel, tyres, furniture and mattresses. Independently of that, the battery passport runs under the Battery Regulation – it becomes the very first mandatory DPP on 18 February 2027. Construction products get their product passport via their own Construction Products Regulation.
Just as important is what is not covered by the ESPR: food, feed and medicinal products are explicitly exempt. Vehicles are exempt to the extent that dedicated EU legislation already governs their environmental requirements – yet the automotive industry is right in the middle of it via traction batteries, tyres and steel.
For everyone else, the rule is: if you sell physical products in the EU single market, the question is not whether the DPP is coming, but when – and how much preparation time realistically remains. You will find the complete schedule with all deadlines on our timeline page.
02 — Overview
Fixed points are the EU DPP registry (live since 20 July 2026) and the battery passport. All delegated-act dates are expected values from the ESPR working plan 2025–2030 – they have shifted before and may shift again.
| Product group | Date | Status | Legal basis |
|---|---|---|---|
| EU DPP registry (infrastructure for all product passports) | live since 20 July 2026 | fixed | ESPR (EU) 2024/1781, Art. 13 |
| Batteries (EV, LMT, industrial > 2 kWh) | 18 Feb 2027 | fixed | Battery Regulation (EU) 2023/1542 |
| Iron & steel | delegated act expected Q4 2026 | expected | ESPR |
| Textiles & apparel | delegated act expected 2027 | expected | ESPR |
| Tyres | delegated act expected 2027 | expected | ESPR |
| Aluminium | delegated act expected 2027 | expected | ESPR |
| Furniture | delegated act expected 2028 | expected | ESPR |
| Mattresses | delegated act expected 2029 | expected | ESPR |
| Electronics & ICT | expected, date open | expected | ESPR / ecodesign |
| Construction products | phased from 2026 | expected | CPR (EU) 2024/3110 |
| Packaging | phased, date open | expected | Packaging Regulation (EU) 2025/40 (PPWR) |
| Detergents & cleaning products | date open | expected | New Detergents Regulation (revision with DPP) |
| Critical raw materials / permanent magnets | implementing acts pending | expected | CRMA (EU) 2024/1252 |
As of August 2026. Delegated-act dates are indicative and based on the ESPR working plan 2025–2030. Rule of thumb: delegated act + ~18 months of transition = DPP obligation. Not legal advice.
Send us your product group via WhatsApp – we will tell you free of charge whether and when your product needs a Digital Product Passport.
03 — Applicability check
Four questions are enough for a first assessment. If you can answer all four cleanly, you know your DPP applicability – and your time window.
01
Check the table above: if your product group is listed, the delegated act is in the works and the countdown is running. If it is not (yet) listed, you are not off the hook – just later in line. The working plan is updated over time.
02
What matters is market access, not the place of production. If you import, you take on the manufacturer obligations: importers and distributors must ensure a valid, registered product passport exists – otherwise the product cannot be sold.
03
The delegated act defines per product group whether the passport attaches to the final product, the component, or both. Example: the EV battery needs its own passport from 2027 – regardless of the vehicle it sits in. Steel gets its passport as an intermediate product.
04
The DPP is not a consumer-only obligation. Industrial batteries, steel coils, aluminium profiles – pure B2B products are actually at the start of the timeline. If you supply business customers only, you are just as affected as a consumer-goods manufacturer.
04 — Special cases
Intermediate products. Steel and aluminium are not final products, yet they sit at the very front of the working plan. The logic: whoever documents the input material cleanly provides the data foundation for every downstream passport – from furniture fittings to car bodies. The requirements travel up the supply chain. In the long run this also concerns chemicals and plastics: polymers, additives and recyclates are the inputs of almost every priority product group, and without material data from this tier, every downstream passport stays incomplete.
Spare parts. Whether spare and accessory parts need their own passport is decided in each delegated act. What is foreseeable: safety- and environmentally relevant components (such as batteries in electronic products) are more likely to be covered than screws. Until then: spare parts for products placed on the market before the respective deadline do not trigger a retroactive passport obligation.
Second-hand & refurbished. The obligation attaches to the first placing on the EU market. Used goods already in circulation do not need a passport retroactively. But watch out with refurbishment: if you modify a product so substantially that it legally counts as a new product, you place it on the market anew – passport obligation included. For refurbishers the DPP is also an opportunity: repair and disassembly data from the passport make refurbishment far more predictable.
Non-EU manufacturers. The passport obligation follows market access, not production location. A manufacturer in China, India or the US whose products are sold in the EU needs the passport all the same – in practice the obligation shifts to the EU importer or authorised representative, who has to collect the data from the manufacturer. That is exactly where supply chains fail most often: not on the technology, but on missing data from overseas suppliers. How to close those gaps systematically is covered in our data management approach.
Vehicles. Complete vehicles are governed by dedicated EU legislation, including the planned End-of-Life Vehicles Regulation with its own vehicle circularity passport. The supply chain of the automotive industry, however, is already inside the DPP regime several times over – via batteries, tyres and steel. If you supply OEMs, do not judge your applicability by the final product “vehicle”.
05 — FAQ
Yes, without restriction. The ESPR does not distinguish between consumer and industrial goods. The first product groups in the timeline – industrial batteries, iron & steel, aluminium – are in fact predominantly B2B. If you supply business customers only, you are just as obliged.
No. Food, feed and medicinal products are explicitly excluded from the scope of the ESPR – they have their own labelling and traceability rules. The packaging of a food product, however, may eventually be covered by product requirements.
The passport obligation attaches to placing products on the EU market, not to the place of production. If you import goods from China, you as the importer are responsible for ensuring a valid product passport registered in the EU registry exists. In practice that means: request material data, carbon values and evidence from your supplier – well before the deadline.
Electronics and ICT are on the list, but a concrete date for the delegated act is still open – requirements are realistically expected towards the end of the decade. Note: battery-powered devices with LMT or industrial batteries are partly affected from 2027 already, via the battery passport.
No. The obligation applies to products placed on the market from the respective cut-off date. Stock and products already sold do not need a passport retroactively. But: if you substantially modify a product and place it on the market anew, the obligation is triggered afresh.
Contact
Name your product group, get an honest assessment: whether you are in scope, from when, and which data you are still missing today. Free and without obligation.
Vincubate Ventures · Across the DACH region and Europe, remote & on site
Two sentences about your industry and product group are enough – we usually reply within 24 hours on business days.