EU Digital Product Passport deadlines and compliance calendar

Treat an ESPR sector date as a framework or rulemaking milestone until the product-specific delegated act is adopted and its application provision is known. Under Article 9, an ESPR product can be placed on the market or put into service only with a Digital Product Passport when the applicable Article 4 delegated act requires one.

Article 4 normally gives economic operators at least 18 months from a delegated act's entry into force to comply. A duly justified act, or a partial repeal or amendment, may set an earlier application date. Record the act's adoption, Official Journal publication, entry into force, application date, product scope, and any transitional rule separately.

The Commission adopted Implementing Regulation (EU) 2026/1778 on 16 July 2026 to set the registry's access, verification, registration, storage, and technical arrangements. It launched the DPP Registry and a testing environment on 20 July 2026. The infrastructure is available, but a product's duty to create and register a passport still comes from the applicable product legislation.

For an ESPR-covered imported product, the person seeking release for free circulation must provide or make available the registry's unique registration identifier once both the registry is operational and an applicable Article 4 delegated act covers the product. Automated customs matching is a later trigger: Article 15 requires the registry-to-customs interconnection to become operational within four years after the registry implementing act entered into force.

Battery passport dates are stronger than most ESPR product-group planning dates because Regulation (EU) 2023/1542 sets explicit dates for QR codes and electronic battery passports. Keep these entries separate from ESPR product groups so teams do not apply battery-specific dates to non-battery products.

The battery category determines the obligation. From 18 February 2027, light means of transport (LMT) batteries, industrial batteries with a capacity greater than 2 kWh, and electric vehicle batteries must have an electronic battery passport.

For every DPP entry, label the event as legislation, infrastructure launch, indicative Commission planning, consultation, delegated-act adoption, entry into force, application, recurring review, or enforcement. This prevents an adoption target from being treated as a product deadline.

Update a product-group row only when the Official Journal text supplies the missing details: product scope, application and transition dates, passport data, data-carrier rules, access rights, model/batch/item level, responsible actors, conformity assessment, and passport availability period.