There is no single deadline for the Digital Product Passport (DPP); instead, there is a multi-stage, product-specific roadmap. Anyone who wants to plan the deadlines for their own company in a legally compliant manner must divide the implementation into three stages:
• Stage 1 – The foundation is in place: The technical infrastructure for the DPP is already active at the EU level. The European Commission launched the central DPP registry in the summer of 2026. Basic data such as product identifiers and customs codes can be processed. The complete data set remains decentralized with the company and is linked to the product via a data carrier (e.g., QR code).
• Stage 2 – The product-specific legal act: The legal obligation does not arise until a specific regulation under the Ecodesign Regulation (ESPR) or a standalone law is adopted for a particular product group.
• Stage 3 – The effective date: Only this final date triggers the actual obligation. The ESPR provides for a transition period of at least 18 months following the adoption of the respective legal act.
An Overview of the Specific Timeline
• Batteries are first in line (effective date: February 18, 2027): In a few months, every new electric vehicle and LMT battery (e-bikes, etc.) as well as every industrial battery with a capacity exceeding 2 kWh placed on the market will require an electronic battery passport. Although the implementing act on access rights has been delayed and is expected to be released for consultation in October/November 2026, the February deadline remains in effect.
• Iron, Steel & Aluminum: The regulations for steel are expected by the end of 2026 (mandatory starting mid-2028); for aluminum and tires, implementation is planned for the end of 2027 (mandatory starting in 2029).
• Textiles & Furniture: Here, the DPP requirement will be phased in between 2029 and 2031.
What does this mean for retailers?
The primary responsibility for creating the pass lies with manufacturers and importers. However, retailers and marketplace operators must ensure that end users can easily access the pass, even in distance selling. Those who sell private-label brands or import directly from non-EU countries will also immediately assume full manufacturer liability for the DPP.
Use the remaining time to take stock of your data flows. There are only a few months left until the launch of the first Battery Passport in February 2027.
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