Polarpass

Product passport deadlines by product group

The EU and national rules that may affect your products, with their dates, status and sources. Rules that are not adopted yet have indicative dates, which are likely to move.

Last checked 27 October 2026

Which rules may apply to you?
In force
The rule applies now.
Adopted
The rule is law and applies from the date shown.
Expected
The rule is not adopted yet. Its date is indicative and may change.
Indicative date
An estimate based on the Commission’s planning and the minimum transition period.

General information, not legal advice. Check the rules for your products with your adviser.

Show rules for

2023

  1. In force

    Netherlands: producer responsibility for textiles (UPV Textiel)

    Anyone who first places new clothing, workwear, bed and table linen or household linen such as towels on the Dutch market, including manufacturers, importers and suppliers based abroad. It does not apply to second-hand textiles.

    Fashion & textiles, Home & household

    What it means and sources
    What it means
    Producers organise free take-back of discarded textiles and tell customers about it, on their own or through a producer organisation. Each year they notify Rijkswaterstaat of what they expect to sell, and before 1 August they report what they placed on the market the year before. Targets for reuse and recycling rise each year until 2030.
    What to prepare
    Keep yearly sales per product type, with weight and fibre composition. Decide whether to join a producer organisation.
    Polarpass
    Polarpass records the material composition of each product. It does not register you, organise take-back or file reports.

    Sources

    Last checked

2024

  1. In force

    General Product Safety Regulation (GPSR)

    Manufacturers, importers and sellers of consumer products in the EU, of any size.

    All product groups

    What it means and sources
    What it means
    Regulation (EU) 2023/988 sets the general safety rules for consumer products. For online and other distance sales, each listing shows the manufacturer’s name and postal and electronic address, the responsible person in the EU where the manufacturer is outside the EU, details that identify the product such as a picture and its type, and any warnings or safety information.
    What to prepare
    Check that each product listing shows these details in the listing itself, and that the manufacturer’s details are on the product or its packaging. Keep your company details the same everywhere.
    Polarpass
    Polarpass keeps manufacturer and responsible person details in one record and can show them on the passport. A passport behind a QR code does not replace the details in your online listings.

    Sources

    Last checked

2025

  1. Earlier phases from 2023 with higher thresholds

    In force

    France: environmental product sheet (AGEC Article 13)

    Producers and importers of new consumer products in many French producer responsibility categories, with an annual turnover above EUR 10 million and more than 10,000 units a year placed on the French market. Both thresholds count.

    Fashion & textiles, Furniture & interiors, Electronics, Toys & children’s products, Sports & outdoor, Home & household, Packaging, Batteries, Detergents & surfactants

    What it means and sources
    What it means
    French law (Environment Code Article L.541-9-1 and Decree 2022-748) asks for a sheet on each product’s environmental qualities and characteristics. It covers categories such as household packaging, electrical and electronic equipment, batteries, furniture, textiles and footwear, toys, sports and leisure goods, DIY and garden products and chemical products. The sheet is a dedicated web page, free to consult when the product is bought, in a format machines can reuse. A QR code is not required. Traceability details apply only to textiles and footwear. Earlier phases started in 2023 and 2024 with higher thresholds.
    What to prepare
    Collect the characteristics per product, such as recycled content, hazardous substances and, for textiles and footwear, the countries of the main production steps. Publish them on a dedicated web page in a reusable format, not a scanned PDF.
    Polarpass
    A public Polarpass passport shows materials, recycled content and production origin on its own web page. It does not follow the official French sheet format, and Polarpass does not check the French requirements.

    Sources

    Last checked

2026

  1. In forceProduct passport

    First harmonised standards for passports

    Passport service providers, and companies that build or host their own passports.

    Fashion & textiles, Furniture & interiors, Toys & children’s products, Sports & outdoor, Home & household, Batteries, Iron & steel, Construction materials, Aluminium, Tyres, Detergents & surfactants

    What it means and sources
    What it means
    Implementing Decision (EU) 2026/1736 cites six CEN and CENELEC standards: EN 18216, 18219, 18220, 18221, 18222 and 18223. They cover data exchange, unique identifiers, data carriers such as QR codes, storage and back-up, interfaces and interoperability. Following them gives a presumption of conformity with the passport rules in ESPR Articles 10 and 11, as far as the standards cover them.
    What to prepare
    Ask your passport provider how they use these standards, especially for identifiers and QR codes. You do not need the standards to start collecting product data.
    Polarpass
    Polarpass supports QR codes and GS1 Digital Link identifiers. It does not claim conformity with these standards.

    Sources

    Last checked

  2. In force

    Ban on destroying unsold clothing and footwear: large companies

    Large companies with unsold apparel, clothing accessories or footwear. Micro and small companies are exempt. Medium-sized companies follow from 19 July 2030.

    Fashion & textiles, Sports & outdoor

    What it means and sources
    What it means
    ESPR Article 25 bans destroying these unsold products. Delegated Regulation (EU) 2026/296 lists when destruction is still allowed, for example for unsafe or damaged products, products that infringe intellectual property, or when offers to donate to social economy organisations are turned down. Recycling counts as destruction unless an exception applies.
    What to prepare
    Record what happens to unsold stock, plan resale, donation and reuse routes, and keep evidence when you rely on an exception.
    Polarpass
    Not covered by Polarpass. The ban concerns how you handle stock, which a passport does not record.

    Sources

    Last checked

  3. In forceProduct passport

    EU registry for digital product passports

    Companies that place products with a passport duty on the EU market, and passport service providers. The first products are batteries, from 18 February 2027.

    Fashion & textiles, Furniture & interiors, Toys & children’s products, Sports & outdoor, Home & household, Batteries, Iron & steel, Construction materials, Aluminium, Tyres, Detergents & surfactants

    What it means and sources
    What it means
    The registry under Implementing Regulation (EU) 2026/1778 opened with a test environment on 20 July 2026, and the regulation entered into force on 6 August 2026. It holds product identifiers and registration data, not the passports themselves, and customs use it for imports. A product is registered only once a passport rule applies to it. To enrol, a company proves its identity with a qualified electronic seal, a qualified electronic signature or a qualified electronic attestation of attributes. Companies outside the EU can enrol too. Registration alone does not show that a product follows the rules.
    What to prepare
    Find out how your company can get a qualified electronic seal or signature, as arranging one takes time. You register products once their passport rule applies.
    Polarpass
    Not covered by Polarpass. Polarpass does not register passports in the EU registry.

    Sources

    Last checked

  4. In force

    Packaging and Packaging Waste Regulation (PPWR) applies

    Every company that places packaging or packaged products on the EU market.

    All product groups

    What it means and sources
    What it means
    Regulation (EU) 2025/40 has applied since 12 August 2026. It is not a passport law. Many of its labelling and design rules start later, each on its own date.
    What to prepare
    Map the packaging of each product, with materials, weights and suppliers. Check which national packaging schemes you are registered with.
    Polarpass
    A passport can show packaging materials and how to dispose of them. Polarpass does not handle packaging registrations, reports or fees.

    Sources

    Last checked

  5. In force

    Rules on green claims (Empowering Consumers Directive)

    Every business that sells to consumers and makes environmental or sustainability claims. There is no exemption for small companies.

    All product groups

    What it means and sources
    What it means
    Directive (EU) 2024/825 applies from 27 September 2026 through national law. It bans generic environmental claims such as ‘eco-friendly’ or ‘green’ without proof of recognised excellent environmental performance, sustainability labels that are not based on a certification scheme or set up by public authorities, and claims that a product is climate neutral because of carbon offsets. Several countries adopted their national law late. In the Netherlands, parliament adopted the law and a royal decree sets its start date.
    What to prepare
    List every environmental claim on your products, packaging, website and ads. Keep the evidence for each one, make vague claims specific or remove them, and check where each label comes from.
    Polarpass
    In Polarpass, sustainability claims stay internal until you make them public, and you can note the evidence and certification for each claim. Polarpass does not check whether a claim is allowed.

    Sources

    Last checked

  6. Voluntary score since 1 October 2025

    In force

    France: environmental cost score for clothing

    Clothing brands that sell in France.

    Fashion & textiles

    What it means and sources
    What it means
    Decree 2025-957 set up a voluntary ‘coût environnemental’ score for clothing, calculated with the official Ecobalyse method. A transitional limit lapsed on 1 October 2026, so third parties may now publish a garment’s score without the brand’s consent. Showing the score stays voluntary, unless you make certain other environmental claims.
    What to prepare
    Decide whether to calculate and publish your own score before others do. Collect the data the method uses, such as fibre composition, weight and the countries of each production step.
    Polarpass
    Polarpass records materials and production origin, which the calculation uses. It does not calculate or submit the score.

    Sources

    Last checked

  7. Last checked

  8. About November 2026

    ExpectedIndicative dateProduct passport

    Two more passport standards to be cited

    Passport service providers, and companies that build or host their own passports.

    Fashion & textiles, Furniture & interiors, Toys & children’s products, Sports & outdoor, Home & household, Batteries, Iron & steel, Construction materials, Aluminium, Tyres, Detergents & surfactants

    What it means and sources
    What it means
    EN 18239 (access rights, information security and business confidentiality) and EN 18246 (data authentication, reliability and integrity) were reportedly published by CEN in September 2026, but they are not yet cited in the Official Journal. The Commission’s timeline plans that decision for November 2026. Until then they give no presumption of conformity.
    What to prepare
    If your passports will need restricted access for authorities, repairers or recyclers, take these standards into account before choosing a setup.
    Polarpass
    Not covered by Polarpass. Passport details can be public, internal or hidden, but there is no restricted access for authorities or other parties.

    Sources

    Last checked

2027

  1. Adopted

    Packaging: producer responsibility marking only by QR code or other digital marking

    Companies whose packaging is part of an extended producer responsibility (EPR) scheme and that mark it as such.

    All product groups

    What it means and sources
    What it means
    From 12 February 2027, PPWR Article 12(9) allows packaging in an EPR scheme to be marked as such only through a symbol in a QR code or another standardised, open digital marking. Marking is optional; if you mark packaging, it is done digitally.
    What to prepare
    Check which of your packaging carries EPR symbols today, and plan to move them into a QR code before you reprint.
    Polarpass
    Not covered by Polarpass. Polarpass’s QR codes open a product passport; they do not carry EPR scheme markings.

    Sources

    Last checked

  2. AdoptedProduct passport

    Battery passport for e-bike, EV and large industrial batteries

    The company that places a finished battery on the EU market: every light means of transport battery (such as for e-bikes and e-scooters), every industrial battery over 2 kWh and every EV battery. This includes importers of finished e-bikes with the battery inside.

    Batteries

    What it means and sources
    What it means
    Under Batteries Regulation (EU) 2023/1542 Article 77, each of these batteries needs its own electronic battery passport, reached through the QR code on the battery and registered in the EU registry. Part of the data is public; other parts are only for people with a legitimate interest, such as repairers and recyclers, and for authorities. The act that sets these access rights was due on 18 August 2026 and is still pending. No delay of the passport date has been proposed.
    What to prepare
    Ask your battery supplier which passport data they will provide. Choose a battery passport provider that offers restricted access, data per battery and registry registration.
    Polarpass
    Not covered by Polarpass. Polarpass does not provide battery passports: it has no restricted access for authorities, repairers or recyclers, no structured battery data and no registry registration.

    Sources

    Last checked

  3. Adopted

    QR code on every battery

    Companies that place batteries on the EU market, including batteries built into or sold with products such as electronics, toys, tools and beauty devices.

    Batteries, Electronics, Toys & children’s products, Beauty & personal care, Home & household, Sports & outdoor

    What it means and sources
    What it means
    Batteries Regulation Article 13(6) requires a QR code on all batteries from 18 February 2027. For e-bike, EV and industrial batteries over 2 kWh, the code leads to the battery passport. For other batteries, such as portable batteries, it gives access to the label information, the EU declaration of conformity, the due diligence report and information on preventing and handling waste batteries. When a battery is too small, the code goes on the packaging and accompanying documents. Some label details depend on an implementing act that is delayed.
    What to prepare
    List every battery type you sell, built in or on its own. Collect the EU declaration of conformity and label information from your supplier, and decide where the QR code goes.
    Polarpass
    For portable and other batteries without a passport duty, a public Polarpass passport per battery model can hold these documents behind a QR code. Polarpass does not check the label or the QR code against the regulation. For e-bike, EV and large industrial batteries it is not covered, as they need a battery passport.

    Sources

    Last checked

  4. Adopted

    Standard format for reporting discarded unsold products

    Large companies that discard unsold consumer products. Micro and small companies are exempt. Medium-sized companies follow from 19 July 2030.

    All product groups

    What it means and sources
    What it means
    Under ESPR Article 24, large companies already disclose each year how many unsold consumer products they discard and why, starting with their first full financial year after ESPR entered into force. Implementing Regulation (EU) 2026/2 sets a standard format for this disclosure, which applies from 2 March 2027. The disclosure covers the products, the numbers and weight discarded, the reasons, and the shares reused, recycled, recovered or disposed of.
    What to prepare
    Track discarded unsold products per product category, with numbers, weight, reasons and where they went.
    Polarpass
    Not covered by Polarpass.

    Sources

    Last checked

2028

  1. Adopted

    Producer responsibility for textiles and footwear in every EU country

    Producers of textile products and footwear that sell into each EU country. Micro companies follow from 17 April 2029.

    Fashion & textiles, Home & household, Sports & outdoor

    What it means and sources
    What it means
    Directive (EU) 2025/1892 requires every Member State to run an extended producer responsibility scheme for textiles and footwear by 17 April 2028, with national laws due by 17 June 2027. It includes a producer register and separate collection. The Netherlands and France already run schemes.
    What to prepare
    Keep sales per country with weight and fibre composition for each product, as registrations and reports are likely to use them.
    Polarpass
    Polarpass records the material composition of each product. It does not register you with schemes or file reports.

    Sources

    Last checked

  2. Or 24 months after the label rules, if that is later

    Adopted

    Packaging: harmonised material labels

    Every company that places packaged products on the EU market.

    All product groups

    What it means and sources
    What it means
    PPWR Article 12(1) introduces a harmonised label that shows what the packaging is made of. It applies from 12 August 2028 or 24 months after the implementing acts that define the label enter into force, whichever is later. Labels for reusable packaging follow from 12 February 2029 at the earliest.
    What to prepare
    Wait for the implementing acts before redesigning labels, and keep packaging material data per product up to date.
    Polarpass
    Not covered by Polarpass. Polarpass does not create packaging material labels.

    Sources

    Last checked

  3. Second half of 2028 at the earliestAct planned for Q4 2026

    ExpectedIndicative dateProduct passport

    Ecodesign passport for iron and steel

    Producers and importers of iron and steel intermediate products.

    Iron & steel

    What it means and sources
    What it means
    Iron and steel is the first product group planned under ESPR. The Commission targets adoption of the act in Q4 2026. Its consultation closed on 12 August 2026, and no draft had been published by October 2026. Duties apply at least 18 months after the act enters into force. The expected passport covers identification, technical and material data, recycled content, sustainability information, and conformity and traceability documents.
    What to prepare
    Collect material, recycled content and production data per heat or batch.
    Polarpass
    Polarpass has an iron and steel category with prompts for these details, at model, batch or item level. The final rules are not adopted, so Polarpass cannot follow them yet.

    Sources

    Last checked

  4. Late 2028 at the earliestAct planned for Q2 2027

    ExpectedIndicative dateProduct passport

    Passport for construction products

    Manufacturers of construction products covered by new harmonised technical specifications under the Construction Products Regulation.

    Construction materials

    What it means and sources
    What it means
    The Construction Products Regulation (EU) 2024/3110 mostly applies since 8 January 2026. Its passport becomes mandatory 18 months after a delegated act enters into force, and the Commission plans that act for Q2 2027. Passports then follow per product family, as new harmonised standards arrive.
    What to prepare
    Follow the working plan for your product family, and keep declarations of performance and product data together.
    Polarpass
    Polarpass has a construction materials category for organising product information and documents. The passport rules are not adopted, so Polarpass cannot follow them yet.

    Sources

    Last checked

2029

  1. AdoptedProduct passport

    Passport for detergents and surfactants

    Manufacturers of detergents and of surfactants sold to end users. Manufacturers outside the EU appoint an authorised representative in the EU.

    Detergents & surfactants, Home & household

    What it means and sources
    What it means
    The Detergents and Surfactants Regulation (EU) 2026/405 entered into force on 22 March 2026 and mostly applies from 23 September 2029. Detergents and surfactants for end users then need a digital product passport, reached through a data carrier and linked to the EU passport system.
    What to prepare
    Collect formulation, labelling and safety information per product, and review the new labelling rules, which also allow some digital labelling.
    Polarpass
    Polarpass has a detergents and surfactants category for organising product information and documents. It does not follow the passport requirements of this regulation yet.

    Sources

    Last checked

  2. Mid to late 2029 at the earliestAct planned for Q3 to Q4 2027

    ExpectedIndicative dateProduct passport

    Ecodesign passport for textiles and apparel

    Apparel brands and importers of every size, as ESPR has no exemption for small companies. A Commission study suggests the first act covers apparel with at least 80% textile fibre. Footwear is being studied separately.

    Fashion & textiles, Sports & outdoor

    What it means and sources
    What it means
    The Commission plans to adopt the textile act in Q3 to Q4 2027, and duties apply at least 18 months after it enters into force. A May 2026 study by the Commission’s Joint Research Centre proposes content such as fibre composition, durability, substances of concern, recycled content, care information and identifiers. That study is not law, and the act may differ.
    What to prepare
    Collect fibre composition, production countries, suppliers, care instructions and certificates per style. Decide whether you will publish per model, batch or item.
    Polarpass
    Polarpass lets you publish clothing passports now, with materials, origin, care and repair details, at model, batch or item level and with a QR code. The act is not adopted, so the required details may change.

    Sources

    Last checked

  3. Mid to late 2029 at the earliestAct planned for Q3 to Q4 2027

    ExpectedIndicative dateProduct passport

    Ecodesign passport for tyres

    Tyre manufacturers and importers.

    Tyres

    What it means and sources
    What it means
    Tyres are a priority group in the ESPR working plan, and the Commission’s passport timeline plans the act for Q3 to Q4 2027. Duties apply at least 18 months after it enters into force. Its content is not known yet.
    What to prepare
    Follow the Commission’s preparatory work for tyres, and keep product and material data together.
    Polarpass
    Polarpass has a tyres category for organising product information. The rules are not adopted, so Polarpass cannot follow them yet.

    Sources

    Last checked

  4. Mid to late 2029 at the earliestAct planned for Q3 to Q4 2027

    ExpectedIndicative dateProduct passport

    Ecodesign passport for aluminium

    Producers and importers of aluminium intermediate products.

    Aluminium

    What it means and sources
    What it means
    Aluminium is a priority group in the ESPR working plan, and the Commission’s passport timeline plans the act for Q3 to Q4 2027. Duties apply at least 18 months after it enters into force. Its content is not known yet.
    What to prepare
    Collect alloy, recycled content and production data per batch.
    Polarpass
    Polarpass has an aluminium category for organising product information. The rules are not adopted, so Polarpass cannot follow them yet.

    Sources

    Last checked

2030

  1. Adopted

    Ban on destroying unsold clothing and footwear: medium-sized companies

    Medium-sized companies with unsold apparel, clothing accessories or footwear. Micro and small companies stay exempt.

    Fashion & textiles, Sports & outdoor

    What it means and sources
    What it means
    The ESPR Article 25 ban that applies to large companies since 19 July 2026 extends to medium-sized companies. The exceptions in Delegated Regulation (EU) 2026/296 apply to them too.
    What to prepare
    Record what happens to unsold stock, and plan resale, donation and reuse routes before the ban applies.
    Polarpass
    Not covered by Polarpass. The ban concerns how you handle stock, which a passport does not record.

    Sources

    Last checked

  2. Adopted

    Reporting discarded unsold products: medium-sized companies

    Medium-sized companies that discard unsold consumer products. Micro and small companies stay exempt.

    All product groups

    What it means and sources
    What it means
    The yearly disclosure under ESPR Article 24 extends to medium-sized companies, in the standard format of Implementing Regulation (EU) 2026/2.
    What to prepare
    Track discarded unsold products per product category, with numbers, weight, reasons and where they went.
    Polarpass
    Not covered by Polarpass.

    Sources

    Last checked

  3. AdoptedProduct passport

    Passport for toys

    Toy manufacturers and importers.

    Toys & children’s products

    What it means and sources
    What it means
    The Toy Safety Regulation (EU) 2025/2509 applies from 1 August 2030. Every toy model then needs a digital product passport, which replaces the EU declaration of conformity. It is reached through a data carrier, has a back-up copy with a passport service provider and is registered in the EU registry. Until then, toys follow Directive 2009/48/EC, and toys placed on the market before 1 August 2030 under those rules can still be sold.
    What to prepare
    Keep the technical documentation and safety assessment of each toy model up to date, and plan one passport per model.
    Polarpass
    Polarpass can publish a passport per toy model with documents and a QR code today. It does not offer a back-up copy with a separate service provider or registry registration.

    Sources

    Last checked

  4. About 2030Act planned for 2028

    ExpectedIndicative dateProduct passport

    Ecodesign passport for furniture

    Furniture makers and importers of every size.

    Furniture & interiors

    What it means and sources
    What it means
    Furniture is a priority group in the ESPR working plan. The Commission plans the act for 2028, and duties apply at least 18 months after it enters into force, so realistically about 2030. No draft has been published.
    What to prepare
    Collect materials, finishes, spare parts and repair information per model.
    Polarpass
    Polarpass lets you publish furniture passports now, with materials, care and repair information and a QR code. The act is not adopted, so the required details may change.

    Sources

    Last checked

2031

  1. About 2031Act planned for 2029

    ExpectedIndicative dateProduct passport

    Ecodesign passport for mattresses

    Mattress makers and importers.

    Furniture & interiors, Home & household

    What it means and sources
    What it means
    Mattresses are a priority group in the ESPR working plan. The Commission plans the act for 2029, and duties apply at least 18 months after it enters into force, so realistically about 2031.
    What to prepare
    Collect materials, components and end-of-life information per model.
    Polarpass
    Polarpass lets you publish passports for mattresses now, with materials, care and recycling information and a QR code. The act is not adopted, so the required details may change.

    Sources

    Last checked

How we keep this list

Each rule links to the legal text or official guidance where we could check it, and to reliable secondary sources otherwise. Dates for rules that are not adopted come from the Commission’s indicative planning plus the transition period of at least 18 months under ESPR, so treat them as estimates. Spotted something out of date? Let us know.

Start with one product.

Your first published passport is free, with no card and no expiry. Add materials, origin and care, and get a QR code for your label.

Start your free passport