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4. Is a Digital Product Passport Mandatory for My Business?

So far in our series, we've explored the what, why, and how of the Digital Product Passport. Feel free to take a look at the previous blogs if you haven't! Now, we arrive at the most pressing question for many businesses: "Do we need one?" The short answer is: yes, for many. And for many more, it will be soon. Let's break down which sectors are affected and when.

What is the overarching schedule?

The overarching Ecodesign for Sustainable Products Regulation (ESPR) legislation is already in effect since 18 July 2024. After that, the EU will roll out the DPP requirement in waves, starting with sectors that have a high environmental impact and a high potential for circularity.  

For each product group, the EU will publish a Delegated Act. This specific regulation will define the exact DPP requirements and, crucially, the final timeline for that sector. Once a Delegated Act is officially adopted, businesses have 18 months to comply.  

Is a Digital Product Passport (DPP) Mandatory for my business

The first wave: priority product groups

Starting from February 2027, DPPs will be required for industrial and EV batteries over 2kWh. Shortly after, according to the ESPR and Energy Labelling working plan for 2025-2030, a range of other high-priority product groups will follow. These include:

  • Iron and steel (2026)
  • Textiles/apparel (2027)
  • Tyres (2027)
  • Aluminium (2027)
  • Furniture (2028)
  • Mattresses (2029)

If your business is active in any of these sectors, the DPP is no longer a distant concept, but a concrete compliance deadline that you need to start acting on.

The second wave: other key regulations

The DPP's role doesn't stop with the priority list. Digital Product Passports will also be a core component in several other key EU regulations related to transparency, safety and traceability.  

However, establishing a precise timeline is difficult: many regulations and their deadlines are subject to change. With that in mind, here are some initiatives that will feature the DPP:

EU Strategy for Sustainable and Circular Textiles

Here, the DPP is the primary tool to verify 'green claims' and give consumers reliable information on the durability, repairability, and recyclability of textiles.

Revised EU Toy Safety Regulation

All toys sold in the EU will need a visible DPP to prove they meet safety standards. This will simplify market surveillance for authorities and give consumers easy access to safety warnings.

Revised Detergent & Surfactant Regulation

The DPP will be key for providing accessible product information that increases product safety and market access for all detergent products.

Construction Products Regulation (CPR)

The DPP will support the CPR by ensuring construction products in Europe meet strict safety and environmental requirements.


The future: who's next?

The EU's long-term vision for the DPP is extensive. A wide range of other product groups are already being considered for future waves of implementation. The concrete timelines are not yet fixed, but if your business deals with any of the following, the DPP is very likely in your future:

  • Electronics-related products
  • Chemicals, paints, and varnishes
  • Cosmetics
  • Plastics and polymers
  • Footwear
  • Ceramic products
  • And many more, from pulp and paper to non-ferrous metals.

It's worth noting the specific situation for electronics. The decision on a DPP will be made per product type (e.g., for dishwashers, smartphones, ...). For some categories, the EU may decide to use existing systems like the EPREL database instead of mandating a brand-new DPP.

Overall, the message is clear: the DPP will become a reality for most, if not all physical product sectors.  

Wondering how to get started on your DPP journey, regardless of your sector? We can help.

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