When Will I Need a Digital Product Passport?

Digital Product Passport requirements depend on your product category, business role, and market location. This timeline guide shows exactly when DPPs become mandatory for different sectors.

Quick Timeline Overview

Confirmed Dates

Battery Passports (Confirmed)

February 1, 2027:

• Electric vehicle batteries (all capacities)
• Industrial batteries > 2 kWh
• Light means of transport batteries (e-bikes, scooters)

August 18, 2028:

• All rechargeable batteries
• Portable device batteries
• Starting, lighting, ignition batteries

ESPR Products (Expected 2026-2030)

Priority Products (2026-2027):

• Textiles and clothing
• Electronics and ICT equipment
• Iron and steel products
• Household appliances

Second Wave (2027-2028):

• Furniture
• Tyres
• Detergents
• Paints

Third Wave (2028-2030):

• Construction materials
• Chemicals
• Plastics
• Paper products

By Business Role

Manufacturers

You need DPPs before placing products on the EU market:

• Create DPPs during production
• Implement 6-12 months before deadline
• Test systems 3 months before going live

Importers

You need to verify DPPs at the point of import:

• Check DPP existence before customs clearance
• Validate data accuracy
• Ensure hosting compliance

Retailers/Distributors

You need to provide DPP access at point of sale:

• Display QR codes visibly
• Train staff on DPP information
• Handle customer queries

Online Marketplaces

You must verify DPPs before listing products:

• Automated DPP checking systems
• Block non-compliant listings
• Provide DPP links to customers

Geographic Requirements

Selling TO the EU

Mandatory: All products placed on EU market need DPPs regardless of origin

Manufacturing IN the EU

Mandatory: For EU sales and potentially for exports (buyer requirements)

Manufacturing OUTSIDE the EU

Mandatory: Only for products exported to EU market

Selling OUTSIDE the EU

Not mandatory: Unless destination country has similar requirements

Preparation Timeline

Early Adoption Benefits

Why Start Before Mandatory Dates?

Competitive Advantage:

• First-mover market position
• Customer trust building
• Supply chain readiness

Risk Mitigation:

• Avoid last-minute rush
• Time to fix issues
• Gradual cost spreading

B2B Requirements:

• Large buyers requiring DPPs early
• Tender requirements
• Sustainability reporting needs

Special Considerations

Stock Products

Products manufactured before the deadline but sold after:

• Generally exempt if proven manufactured earlier
• May need retroactive DPPs for high-risk products
• Check specific delegated acts for details

Custom Products

One-off or bespoke items:

• Still require DPPs if in covered categories
• Simplified requirements possible
• Batch DPPs may be acceptable

Spare Parts

Components and replacement parts:

• Required if sold separately
• Can reference main product DPP
• Simplified data requirements

Second-hand Products

Used products first placed on market before requirements:

• Generally exempt from new DPP requirements
• May need proof of original market placement
• Voluntary DPPs can add value

Determining Your Deadline

Answer these questions to find your timeline:

1. What products do you make/sell?

   • Check against product categories above
   • Review harmonized system (HS) codes
   • Consult trade associations

2. Where are your customers?

   • EU market = mandatory
   • Global buyers may require early
   • Future markets to consider

3. What's your supply chain position?

   • Manufacturers need longest lead time
   • Importers need verification systems
   • Retailers need display capabilities

Enforcement and Penalties

Grace Periods

• No official grace periods announced
• Strict enforcement expected from day one
• Market surveillance authorities ready

Non-compliance Consequences

• Products blocked at borders
• Removal from market
• Fines up to 4% of EU turnover
• Criminal liability possible

Action Steps by Timeline

If deadline is 2+ years away

• Monitor delegated acts
• Start data organization
• Budget planning
• Pilot projects

If deadline is 1-2 years away

• Select DPP provider
• Begin implementation
• Train teams
• Test systems

If deadline is less than 1 year away

• Accelerate implementation
• Prioritize critical products
• Ensure compliance testing
• Prepare for audits

Stay Updated

The key is starting preparation well before mandatory dates to ensure smooth compliance and capture early adoption benefits.