The most common question manufacturers and importers ask is: "Fine, but when do I actually have to deal with this?" The answer is that it differs by product group — and it pays to start preparing early, because data collection is the longest step.
The key date: 18 February 2027
The Battery Regulation (EU) 2023/1542 is the most concrete: for batteries with a capacity above 2 kWh (EV, industrial and LMT batteries), the battery passport becomes mandatory from 18 February 2027. This is the first DPP to apply in practice in the EU — and every other product group will learn from it.
ESPR as a horizontal framework
The ESPR (EU) 2024/1781 entered into force in mid-2024 and introduces the DPP as a horizontal instrument: not for every product at once, but through delegated acts, product group by product group, prioritised according to the so-called working plan.
Priority groups in the ESPR working plan (indicative)
- Textiles (clothing in particular) — a prominent early group.
- Iron and steel, aluminium — material-intensive industries.
- Furniture, tyres, mattresses.
- Electronics and ICT products.
- Chemicals, paints, lubricants (in part).
Exact dates depend on the adoption of each delegated act, typically with an 18–36 month transition period. A realistic planning horizon is 2027–2030 for most priority groups.
Timeline overview (for planning)
| Period | What happens | Who is affected first |
|---|---|---|
| 2024 | ESPR enters into force | everyone (framework) |
| 2026 | EmpCo (green claims) applies (27 September 2026) | distributors, brands |
| 18 February 2027 | Battery passport becomes mandatory | battery, EV, industrial makers |
| 2027–2028 | first ESPR delegated acts (e.g. textiles) | textiles, steel, aluminium |
| 2028–2030 | further product groups | furniture, electronics, tyres |
Why act early when the deadline "still feels far off"?
1. Data is the bottleneck. Gathering the carbon footprint, recycled content per material and supplier due diligence takes months — especially when suppliers are in Asia. 2. The schema evolves, the principle does not. The exact field list is being refined, but the structure (identification, materials, performance, sustainability, access groups) is already known. Organise your data and you will be ready. 3. Competitive advantage. Whoever issues a trustworthy DPP first also builds buyer and certifier confidence first.
What to do as the deadline approaches
- Gap analysis: which Annex fields are missing from your data?
- Data-source map: connect ERP, PLM, GHG systems and supplier data.
- Pilot DPP: run the full process for one product type (data → validation → signing → QR).
- Process: who owns the DPP data, how it is updated, and who signs it.
Frequently asked questions
Does it apply if I only sell within the EU?
Yes. What matters is where the product is placed on the market, not where it is manufactured.
Does it apply to me as an importer?
Yes — the importer is responsible for ensuring that the product placed on the market conforms, including its DPP.
What if a delegated act is delayed?
The framework already applies; betting on a delay is a risky strategy, because data collection is the long pole.
Preparation cannot wait until the last minute. ReadyPass helps you assess which data you are missing and gives you a turnkey platform for producing a trustworthy DPP.
Sources: ESPR (EU) 2024/1781; Battery Regulation (EU) 2023/1542; EmpCo (EU) 2024/825. Specific dates depend on the adoption of the delegated acts.
