"When does the Digital Product Passport actually apply to my products?" is the question we hear most. The honest answer is: it depends on your product category, and the schedule keeps moving. Here is the full timeline as of October 2026 — split into what is already in force, what is scheduled, and what is still an open gap. We keep this article updated as the Commission's planning changes.
Already in force
January 2026 — CBAM financial obligations. Not a DPP, but the same data problem: importers of iron, steel, aluminium, cement, fertilisers and hydrogen now buy CBAM certificates based on embedded emissions. The product data you assemble for CBAM overlaps heavily with what a DPP will ask for.
20 July 2026 — the EU DPP Registry is live. The Commission's central index of DPP identifiers launched with a public testing environment and an API. Important nuance: it stores unique identifiers and commodity codes only — the passport data itself stays with the economic operator or their DPP service provider. Battery registration specifically is not yet possible, because the battery data model ("semantic catalogue") is still pending.
August 2026 — the battery data points are defined. The Commission's guidance "Digital Batteries Passport – data points by category" v2.0 labels 71 data points per access category. If you make or import batteries, this is the list you are collecting against today.
The hard deadline: 18 February 2027
Battery passports become mandatory under Article 77 of Regulation (EU) 2023/1542 — for EV batteries, LMT batteries (e-bikes, scooters) and industrial batteries above 2 kWh, including stationary storage. This is the first product category where a DPP is legally required, and the only date on this page backed by an adopted regulation rather than a schedule.
Two things commonly get confused with this date:
- Battery labels are not in force yet. The labelling obligations (Art. 13 / Annex VI A) apply 18 months after the label-format implementing act — which has not been adopted. Anyone telling you labels apply from August 2026 is wrong.
- The Art. 77/78 delegated acts are still pending. The passport obligation stands regardless; the delegated acts will finalise formats and access rules. Build versioned, re-mappable passports — not one-off PDFs.
If this deadline is yours, start with whether you're in scope (two-minute battery check) and read our battery passport software and service page for how the data work actually gets done.
Scheduled by the Commission (dates from the Commission's own DPP planning)
Q4 2026 — iron & steel delegated act, plus the battery access-rights implementing act (originally due August 2026, now expected Q4). Iron & steel is set to be the second DPP category — and if you're a CBAM-affected importer, this is where your two compliance tracks merge onto one data record.
Q2 2027 — construction products (CPR). The revised Construction Products Regulation brings its own digital product passport for construction products.
Q2–Q3 2027 — the delegated act for DPP service providers. This one regulates the companies that host and operate passports on behalf of economic operators — certification, interoperability and portability requirements. If your provider can't tell you how they're preparing for it, ask why.
Q3–Q4 2027 — textiles, aluminium, and tyres. The ESPR working plan's biggest wave. Textiles in particular affects the largest number of companies of any category so far.
2028 — furniture.
2029 — mattresses, plus the recycled-content requirements.
The notable gap: no electronics act is scheduled
Despite electronics being the category everyone assumed would come first, no electronics/ICT delegated act is on the Commission's current schedule. If you sell electronics, your DPP obligations today come only through components that are in scope — batteries above 2 kWh being the obvious one.
How to read this timeline
- Count backwards from your date. The battery companies that will make February 2027 comfortably started their data collection in 2025–2026. Supplier data has lead times of months; carbon footprint calculations take longer. For a Q3 2027 textiles date, "start in 2027" is already late.
- Scheduled ≠ adopted. Every date in the "scheduled" section can slip (the battery access-rights act already has). But slipping dates change when, not whether — none of these categories is going away.
- One data record, many obligations. CBAM, DPP, and national reporting increasingly draw from the same product data. Assembling it once, cleanly and versioned, is the only approach that doesn't multiply the work.
Last reviewed: 19 October 2026. The scheduled dates reflect the Commission's published DPP planning and will be updated as delegated acts are adopted.