Executive report · 2026

Digital Product Passport 2026

What is fixed, what is developing, and what buyers should prepare for.

Author Thomas Christian Melskens, Founder, yellow3 lab Regulatory status checked 6 October 2026

In March 2026, we published an executive report on the Digital Product Passport. It presented the European Commission's indicative timeline as confirmed legal deadlines and attributed several rules to legislation that had not been adopted. We withdrew the report.

This is the corrected edition. It is built around a simple rule: every date carries its legal status. 'Adopted', 'planned' and 'proposed' are not the same thing, and a board deciding where to invest needs to know the difference.

Fixed in law

18 Feb 2027

First fixed passport obligation

Battery passport

Timing pending

No date in law

Indicative rule adoption: 2026 to 2029

Most ESPR product groups

Infrastructure live

20 Jul 2026

EU Digital Product Passport Registry

Live and operating

Why this report was rewritten

We corrected the methodology, not just the wording.

Our March 2026 edition presented indicative Commission timelines as legal deadlines and incorrectly attributed rules to legislation that had not been adopted. We withdrew it. This edition separates enacted requirements from indicative and proposed timelines throughout.

Correction is part of evidence-led research.

The short version

Six things executives need to know.

The framework is law.

The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) has been in force since 18 July 2024.

A passport is required only where product-specific EU legislation says so.

There is no general obligation for every product.

The first passport obligation with a fixed date is the battery passport.

From 18 February 2027.

Most other product groups are still on an indicative adoption programme.

Obligations follow at least 18 months after each rule is adopted. No ESPR product-group rule has been adopted yet.

The infrastructure is arriving ahead of the obligations.

The EU Registry is live and all eight horizontal Digital Product Passport standards have been published.

Responsibility sits with the economic operator.

A service provider can operate the passport. It does not take over that responsibility.

Legal certainty timeline

Different stages. Different certainty.

Dates only make sense when their legal status travels with them.

Fixed in lawAdopted requirements with a date set in legislation.

19 Jul 2026

Unsold apparel destruction ban (large enterprises)

18 Feb 2027

Battery passport

23 Sep 2029

Detergents and surfactants

1 Aug 2030

Toys

Adopted framework, timing pendingIndicative adoption timing, not obligation dates.

Q4 2026

Iron and steel

Q3-Q4 2027

Textiles, aluminium, tyres

2028

Furniture

2029

Mattresses

Under developmentPreparation and proposals. Not current deadlines.

Status pending

Battery access rights

Planned 2027

Service-provider rules

Planned 2027

Repairability requirements

Proposal

Green Claims Directive

Fixed in law

Adopted requirements with dates set in legislation.

Battery passport

Application18 February 2027

ScopeEvery light means of transport (LMT) battery, every electric vehicle battery, and every industrial battery with a capacity above 2 kWh, placed on the market or put into service.

ResponsibilityThe economic operator placing the battery on the market must keep the passport accurate, complete and up to date. It may authorise another operator in writing to act on its behalf.

SourceRegulation (EU) 2023/1542, Article 77.

Ban on destroying unsold apparel and footwear

Application19 July 2026 for large enterprises; 19 July 2030 for medium-sized enterprises. Micro and small enterprises are exempt.

ScopeUnsold apparel, clothing accessories and footwear (ESPR Annex VII), with derogations set by Delegated Regulation (EU) 2026/296.

SourceRegulation (EU) 2024/1781, Article 25.

Why it mattersThis is not a passport obligation, but it is the first ESPR rule that bites, and it applies to exactly the companies that will later need textile passports.

Rules on environmental claims

Application27 September 2026.

What it doesBans generic environmental claims such as "eco-friendly" without recognised excellent environmental performance, and claims that a product has a neutral or reduced impact on the basis of offsetting.

SourceDirective (EU) 2024/825 (Empowering Consumers for the Green Transition).

NoteThis is often attributed to the proposed Green Claims Directive. That proposal has not been adopted.

Toys

Application1 August 2030.

RequirementA Digital Product Passport replaces the EU declaration of conformity for toys.

SourceRegulation (EU) 2025/2509.

Detergents and surfactants

Application23 September 2029, with a digital product passport as part of the new rules.

CustomsCustoms use of the passport data starts on 23 September 2029 or when the customs connection is operational, whichever is later.

SourceRegulation (EU) 2026/405.

The infrastructure

The system is arriving before most obligations.

ProductUnique identifier, for example QR code.

→

Digital Product PassportContent held by the economic operator or provider.

→

EU DPP RegistryIdentifiers and registration data. Live since 20 July 2026.

→

EU customs systemAutomatic connection due by 6 August 2030 at the latest.

European standards published

Complete horizontal family published by CEN-CENELEC.

Currently verified as cited in the Official Journal

Implementing Decision (EU) 2026/1736.

Published, OJ citation not yet verified

EN 18239 and EN 18246.

Responsibility at a glance

Manufacturer, importer or other economic operator

Responsible. The operator placing the product on the EU market carries the obligation.

↓

Digital Product Passport service provider

Performs technical work. A provider can operate the passport on behalf of the responsible operator.

You can delegate the work. You cannot delegate the responsibility.

Adopted framework, product timing pending

The law exists. Most product-specific dates do not.

ESPR product groups

Status: framework adopted. Product-specific Digital Product Passport requirements depend on delegated acts, and none has been adopted as of 6 October 2026. Once an act enters into force, its requirements normally apply no earlier than 18 months later (ESPR Article 4(4)).

Iron and steel: Q4 2026. The public consultation ran from 20 May to 12 August 2026; no draft act has been published.
Textiles and apparel: Q3 to Q4 2027. The Commission's textile page says Q4 2027.
Aluminium and tyres: Q3 to Q4 2027.
Furniture: 2028.
Mattresses: 2029.

Source: Commission ESPR Working Plan 2025-2030 and the Commission's Digital Product Passport pages, both marked indicative.

What this means: on the Commission's current indicative plan, a textile passport obligation would not be expected before 2029.

Construction products

Status: the Construction Products Regulation (EU) 2024/3110 has applied since 8 January 2026. Its digital passport becomes due 18 months after the delegated act under Article 75(1), which the Commission plans for Q2 2027 (indicative). So not before late 2028.

Customs checks

The person declaring a covered product for release into free circulation will have to provide its Registry identifier (ESPR Article 15). Automatic checking depends on linking the Registry to the EU customs certificate exchange system, due by 6 August 2030 at the latest. Customs can already refuse non-compliant products under the Market Surveillance Regulation (EU) 2019/1020.

yellow3 view, not a regulatory requirement

Start with your data. Not the platform.

The passport content comes from your own systems and your suppliers. In our experience, establishing that data takes considerably longer than selecting a provider.

What do you know?Product, material and supplier data.

What can you prove?Sources, evidence and traceability.

What is missing?Data gaps, unresolved claims and supplier dependencies.

Under development

Planning and proposals, not current deadlines.

Official Journal citation of EN 18239 and EN 18246

Both are published European standards. As of our check, we have not verified that the Commission has cited their references in the Official Journal.

Battery passport access rights

The implementing act due by 18 August 2026 has not been adopted. The Commission indicates Q4 2026. The 18 February 2027 passport date is unchanged.

Digital Product Passport service-provider rules

ESPR delegated act planned for 2027. The Commission's pages give both Q2 and Q3 2027.

Horizontal repairability requirements

Planned for 2027.

Green Claims Directive

Proposal 2023/0085(COD), still awaiting the Council's first-reading position. It is not law and has no application date.

Who is responsible

The operator remains responsible.

The economic operator that places the product on the EU market carries the responsibility: making the passport available, keeping it accurate and up to date, registering it where required, and keeping a back-up copy with a Digital Product Passport service provider.

A service provider can perform the technical work; the operator remains responsible (Implementing Regulation (EU) 2026/1778, Article 19(4)). Where the manufacturer is outside the EU, the operator placing the product on the market is usually the EU importer; a non-EU company selling directly to EU customers places the product itself.

Where applicable EU product legislation requires a Digital Product Passport, an in-scope product will need to meet that requirement from the applicable date in order to be placed on the EU market.

What buyers should prepare for

Prepare by certainty, not by noise.

Know what is covered.

Know which of your products are covered, and by which rule. Batteries have a fixed date; most other groups have an indicative adoption year and no obligation yet.

Separate fixed from planned.

Separate what is fixed from what is planned in every internal plan and board paper. Budget for the fixed dates; prepare, without committing irreversibly, for the planned ones.

Separate responsibility from execution.

Establish who carries the responsibility and who will perform the work. They are not the same role. Technical work can be delegated; regulatory responsibility remains with the responsible economic operator.

Start with your data.

Start with your data, not the platform. The passport content comes from your own systems and your suppliers. In our experience establishing that data takes considerably longer than selecting a provider. This is yellow3's own view, not a regulatory requirement.

Buy on evidence.

Ask providers what they can demonstrate, including export, registry submission and continuity if you change provider, and keep their statements separate from what is independently shown. The yellow3 Digital Product Passport Supplier Register shows what is published about each provider, with sources.

Check environmental claims now.

The rules on generic and offset-based claims apply from 27 September 2026, independently of any passport.

What changed from the March 2026 edition

Correction is visible by design.

March 2026 edition

"Confirmed legislative deadlines" was wrong.
Textiles "mid-2027" and furniture, tyres, steel and aluminium "2027 to 2029" were adoption plans presented as obligation dates.
The Green Claims Directive was described as adopted and enforced from September 2026.
The battery passport threshold was stated too broadly.
Several statistics could not be traced to a primary source.

→

Corrected 2026 edition

The Commission's plan is identified as an indicative adoption timeline.
Obligation timing is separated from adoption timing.
Directive (EU) 2024/825 is distinguished from the still-proposed Green Claims Directive.
The 2 kWh threshold is limited correctly to industrial batteries. All EV and LMT batteries are covered.
Unsupported statistics have been removed.

Sources

Primary and official sources.

Retrieved 28 September 2026.

Regulation (EU) 2024/1781 (ESPR), Articles 4, 15, 25, Annex VII
Regulation (EU) 2023/1542 (Batteries), consolidated to 13 August 2026, Article 77
Implementing Regulation (EU) 2026/1778 (Digital Product Passport Registry)
Implementing Decision (EU) 2026/1736 (harmonised standards)
CEN-CENELEC, EN 18216, EN 18219 to EN 18223, EN 18239 and EN 18246 (2026)
Delegated Regulation (EU) 2026/296 (destruction ban derogations)
Directive (EU) 2024/825 (Empowering Consumers for the Green Transition), Article 4
Regulation (EU) 2025/2509 (Toy Safety)
Regulation (EU) 2026/405 (Detergents and surfactants)
Regulation (EU) 2024/3110 (Construction Products), Articles 22 and 75
Regulation (EU) 2019/1020 (Market Surveillance)
Commission communication COM(2025) 187, ESPR Working Plan 2025-2030
European Commission, Digital Product Passport pages (main, iron and steel, textiles, batteries) and Registry announcement of 20 July 2026
European Parliament Legislative Observatory, 2023/0085(COD) (Green Claims)

Regulatory status checked: 6 October 2026 This report distinguishes enacted requirements from planned, proposed and preparatory timelines. It is not legal advice.