ESPR Timeline: Which Products and When
One of the most common questions about ESPR is: "which products, and when?" The answer is not a single date but a schedule spread over years. This article organises what is already known and clearly separates it from what is not yet settled.
Why the schedule is phased
ESPR (Regulation 2024/1781) is a horizontal framework. It does not itself impose obligations on specific products — that is done by delegated acts adopted separately for individual groups. That is why obligations arrive in waves, sector by sector.
This staggering is deliberate. It gives companies time to prepare data and the regulator time to refine requirements for each category. The key conclusion is that there is no single "DPP start date for everyone".
Batteries: the first firm deadline
The best-established point in the schedule is batteries. Under a separate instrument, Regulation (EU) 2023/1542, the battery passport applies from 18 February 2027, and at the level of the individual item.
Batteries are therefore the practical "first case" of the Digital Product Passport in the EU. Companies in this sector have the least time and the most reason to act now. We cover this in more depth in The battery passport from 2027.
Detergents: the next expected wave
After batteries, detergents are indicated as the next area. A passport obligation in this sector is expected around 2029, at the level of the product model.
The exact data scope and details will follow from sector-specific rules. At this stage it is best to treat the timing as indicative and to watch for it being firmed up.
Toys: a further stage
Toys are another announced group. Product-passport obligations in this sector are expected around 2030.
As with detergents, the specific requirements will be set in sector rules. Toy makers therefore have a little more time, but the direction is already set.
Construction products: a separate track
Construction products are a special case. They fall under a separate legal framework for that sector, with its own schedule that runs in parallel to ESPR.
This means construction companies should not be lumped into the first ESPR wave. Their obligations follow a separate track and have their own implementation logic.
Textiles and other sectors: no dates yet
Many frequently mentioned industries — such as textiles, steel products, tyres, electronics or furniture — are also set to be covered by the DPP. The key caveat: for these sectors there are no fixed, binding dates yet.
Their timings are expected later this decade, but they remain legally unsettled until the relevant delegated acts are adopted. So it is wiser to speak of order and direction than of specific dates.
The role of delegated acts
The whole schedule rests on delegated acts. They turn the general ESPR framework into concrete obligations: the data scope, the level of detail and the deadline for a given product group.
Until the act for a sector is adopted, its requirements remain provisional. That is why some dates must be treated as indicative rather than final.
The EU registry: launching from mid-2026
Alongside the sector obligations, the infrastructure is being built — the EU DPP registry. According to available information it is to launch from mid-2026.
The registry acts as an index and a verification layer for identifiers, not a central database of full passports. Its launch precedes the first major sector deadlines, including batteries.
What we still do not know for certain
It is worth honestly marking the limits of this knowledge. What is binding is above all the dates written into rules already adopted, such as batteries. Many of the remaining dates are indicative.
So when planning it helps to distinguish three levels of certainty: settled dates, expected dates and directions without dates. Mixing them leads to poor decisions.
How to prepare your company
Whenever your sector is covered, a few actions make sense today:
- work out which wave your products probably belong to,
- tidy up product data and its sources,
- check whether suppliers will deliver the information you need,
- consider choosing a platform to build and publish passports.
Early preparation lets you spread the work over time rather than acting under deadline pressure.
Different levels for different products
The schedule is not only about dates — it is also about different requirements for detail. Batteries require a passport at the level of the individual item, while for detergents a model level is expected.
This means the workload differs between sectors. An item-level passport involves managing far more records than a model passport. It is worth factoring this difference in at the planning stage.
What the 'waves' mean for planning
The split into waves has a practical benefit: it lets companies learn from earlier sectors. Solutions and good practices developed for batteries will be useful for industries covered later.
For a company in a later wave this is an opportunity, not just a postponement. Instead of waiting, you can watch the first rollouts and prepare your own data and processes in advance.
Why it pays to act before the deadline
The biggest risk is not the date itself but the time needed to gather and organise data. Information on composition or origin often comes from suppliers, and obtaining it can be time-consuming.
So it is sensible to start preparing before your sector's deadline draws near. An early start turns a stressful last-minute project into a calm process spread over time.
The most common misconceptions
A few myths have grown around the schedule. The first is the belief that 'the DPP arrives on a single day for everyone' — in reality it applies in stages.
The second is treating every circulating date as certain. In fact only some are written into adopted rules; the rest stay indicative until delegated acts are adopted.
Key takeaways
- ESPR rolls out the DPP in waves — there is no single common start date.
- Batteries are the first certain deadline: 18 February 2027, at item level.
- Detergents (around 2029) and toys (around 2030) are the next expected waves.
- Construction products have a separate track; textiles and other sectors have no binding dates yet.
- The EU registry is to launch from mid-2026 as an index, not a data warehouse.
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