Dates that should not be confused
- 18 July 2024: the ESPR framework entered into force.
- 20 July 2026: the EU DPP Registry and testing environment became operational.
- 18 February 2027: battery passports for LMT batteries, industrial batteries above 2 kWh and EV batteries.
- Other products: requirements and dates depend on delegated acts or relevant sector legislation.
Why there is no universal date
Regulation (EU) 2024/1781—the ESPR—sets the general architecture for ecodesign requirements and the Digital Product Passport. It does not impose one identical dataset on every good sold in the EU on the same day. A garment, tyre, piece of furniture and electronic component require different performance evidence and lifecycle information.
For product groups covered by the ESPR, delegated acts define requirements, data, granularity, access, availability periods and application dates. Other EU legislation can introduce a DPP or sector passport under its own rules.
The fixed date: 18 February 2027 for specified batteries
Article 77 of Regulation (EU) 2023/1542 requires an electronic battery passport from 18 February 2027 for:
- all batteries for light means of transport, generally referred to as LMT batteries;
- all industrial batteries with a capacity greater than 2 kWh;
- all electric-vehicle batteries.
The date does not automatically cover every cell or battery. Product classification and the economic operator’s role still need to be checked. The battery passport also has a sector-specific dataset and access rules.
Registry and batteries
The Commission linked the current Registry testing phase to preparation for the first 18 February 2027 implementation deadline. Relevant companies can therefore test identifiers, APIs and registration before the application date.
What about textiles, furniture, tyres and other products?
The ESPR Working Plan 2025–2030 identifies priority product groups and horizontal measures for future work. A working plan guides regulatory activity; it is not an immediately applicable DPP obligation. A binding date can only be established by reading the relevant act, its entry into force and transitional period.
It is therefore misleading to present an indicative roadmap as a final deadline for every business. For textiles, for example, the policy direction is clear, but the final dataset and binding application date must be checked in the acts in force when the product is placed on the market.
A live Registry does not bring every product into scope
The EU Registry has been operational since 20 July 2026 together with a testing environment. This makes a central infrastructure component available, but it does not automatically make every product subject to a DPP.
The Registry is a common service. The duty arises when legislation for the product category requires a passport and registration. Businesses that are not yet in scope can still use a pilot to prepare processes and systems.
How to check whether a product is already affected
- Classify the product. Identify category, use, technical characteristics and customs classification, without relying on the customs code alone.
- Define the company’s role. Manufacturer, importer, authorised representative and distributor responsibilities differ.
- Identify sector legislation. ESPR, Batteries Regulation and other product rules can coexist with safety, substance and conformity duties.
- Read the implementing product act. Check dataset, granularity, carrier, access, retention and application date.
- Review thresholds and transitional rules. Capacity, use, size or placing-on-the-market conditions may change the scope.
- Document the conclusion. Retain the sources and reasoning, and review them when legislation changes.
What to prepare before the deadline
Waiting until the final date to request supply-chain data is risky. Information may be spread across ERP and PLM systems, laboratories, raw-material suppliers, non-EU manufacturers, quality systems and unstructured documents. Collection and verification often take longer than building the public page.
Low-regret preparation includes selecting a pilot product, assigning a data owner to each field, inventorying evidence, governing identifiers, designing access levels, testing the carrier, and verifying exports and APIs. These activities remain valuable even if the final product dataset changes.
Official sources
- Regulation (EU) 2024/1781 — ESPRFramework for ecodesign requirements and the Digital Product Passport.
- Regulation (EU) 2023/1542 — BatteriesArticle 77 sets the covered battery categories and 18 February 2027 date.
- European Commission — DPP Registry is live20 July 2026 announcement and reference to the first battery implementation deadline.
- ESPR Working Plan 2025–2030Commission priorities; it does not replace product acts and their application dates.
This guide is not a legal classification of a product. Dates must be checked against the current version of the applicable acts.