There is no single date on which every product needs a digital product passport. ESPR sets up the system, and the obligation for a product group starts only once the EU adopts specific rules for that group and their transition period ends. Some other EU laws, such as the Batteries Regulation, have their own passport with their own dates. This guide explains how that works and where things stand.

How ESPR rolls out

ESPR, Regulation (EU) 2024/1781, entered into force on 18 July 2024. On its own it does not oblige any product to have a passport, and as of October 2026 no ESPR product group has a passport duty yet. For each product group, the Commission adopts a delegated act with ecodesign requirements. That act says whether a passport is required, what it must contain and from when.

As a rule, those requirements apply no earlier than 18 months after the act enters into force, not after it is adopted. Only in duly justified exceptional cases can an act set an earlier date. So for any product group, the order is: the working plan names it, the Commission prepares and adopts the act, the act enters into force, and then the transition period runs.

The shared infrastructure is already in place. The EU digital product passport registry went live on 20 July 2026 under Implementing Regulation (EU) 2026/1778. Implementing Decision (EU) 2026/1736 cites the first six European standards for passports, and the Commission expects to cite two more around November 2026. Neither creates a duty for your product on its own: you register a passport only once a rule for your product group applies.

The working plan: which groups come first

The first ESPR working plan, published in April 2025, lists the groups the Commission will work on first:

  • textiles, starting with apparel;
  • furniture;
  • mattresses;
  • tyres;
  • iron and steel, and aluminium, as intermediate products.

It also plans cross-cutting rules, such as repairability for electronics and household appliances. The plan gives target years for adopting each act, not dates from which duties apply.

The Commission’s current indicative timeline plans the iron and steel act for the fourth quarter of 2026, the textiles, tyres and aluminium acts for the second half of 2027, furniture for 2028 and mattresses for 2029. Adding at least 18 months from entry into force, the earliest duties fall in the second half of 2028 for steel, mid or late 2029 for textiles, about 2030 for furniture and about 2031 for mattresses. Treat these dates as indicative, and check the adopted act before you plan around a deadline. The Commission’s digital product passport page keeps the timeline up to date.

Passports outside ESPR

Several product laws introduce their own passport, with dates that do not depend on the ESPR plan:

  • Batteries. EV batteries, light means of transport batteries such as e-bike batteries, and industrial batteries over 2 kWh need a battery passport from 18 February 2027, and from the same date every battery needs a QR code. See the battery passport guide. Polarpass does not provide the battery passport.
  • Construction products. The Construction Products Regulation, (EU) 2024/3110, provides for a passport. Its rollout depends on further acts per product family. The Commission plans the first one for the second quarter of 2027, so expect passports from late 2028 at the earliest.
  • Detergents. The new Detergents Regulation, (EU) 2026/405, includes a passport and generally applies from 23 September 2029.
  • Toys. The Toy Safety Regulation, (EU) 2025/2509, requires a passport for every toy model from 1 August 2030. The passport replaces the EU declaration of conformity.

What is out of scope

ESPR excludes food, feed, medicinal products and living plants, animals and micro-organisms, among others. Vehicles are covered by their own rules. You can still publish a voluntary passport for these products, for example to share origin or care information, but no ESPR passport is required.

What to do now

If your products are in one of the first groups, the most useful thing you can do is collect the data that every likely requirement depends on: materials and their origin, suppliers, care and repair instructions, and the documents that back up your claims. That work does not change much once the final rules are published.

Polarpass shows category-specific guidance and regulatory review prompts while you create a passport, with links to the source texts. They help you organise evidence, but they are not legal advice, so check your own obligations for the markets you sell in. Our guide to preparing product information lists what to collect.