DPPCalendarEU

EU Digital Product Passport deadlines and compliance calendar

A date-backed calendar for ESPR Digital Product Passport planning and battery passport obligations.

Use it to separate fixed legal dates from product-group milestones that still depend on delegated or implementing acts.

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Author

Sorena AI

Published

May 9, 2026

Updated

May 9, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated May 9, 2026

Overview

The EU Digital Product Passport calendar has two different clocks. The Batteries Regulation already sets fixed passport and QR-code dates for specified battery categories. ESPR sets the horizontal DPP framework, but product-group passport duties apply through delegated acts, so most ESPR product-group dates are planning triggers rather than final go-live dates until the relevant act is adopted.

Section 1

Fixed ESPR dates and delegated-act triggers

Treat ESPR dates as framework milestones unless a product-specific delegated act has been adopted. A product can be required to have a Digital Product Passport only where the applicable ESPR delegated act makes that passport available condition a requirement for placing the product on the market or putting it into service.

The calendar owner should record the legal source, the affected product group, the delegated-act status, and the earliest internal readiness date. Do not convert a working-plan priority into a mandatory product launch deadline.

18 July 2024: Regulation (EU) 2024/1781 entered into force; this starts the ESPR framework clock, not a universal DPP launch date for every product.
By 19 April 2025: ESPR required the first working plan to prioritise product groups and estimated timelines for ecodesign requirements.
16 April 2025: the Commission published the first ESPR and Energy Labelling Working Plan for 2025-2030; use it as the public planning baseline for prioritised product groups.
Not before 19 July 2025: the first ESPR Article 4 delegated act could enter into force.
Delegated-act dependent: iron and steel; aluminium; textiles, especially garments and footwear; furniture, including mattresses; tyres; detergents; paints; lubricants; chemicals; new or reviewed energy-related products; and ICT products and other electronics are priority groups, but their DPP duties depend on the adopted delegated act for the product group.
Delegated-act dependent cement window: if adequate environmental-footprint and carbon-footprint requirements are absent under the Construction Products Regulation, ESPR says cement requirements are to be set not earlier than 31 December 2028 and not later than 1 January 2030.

Sources for this answer

Regulation (EU) 2024/1781 (ESPR)

Supports ESPR entry into force, the Article 4 delegated-act gate, the first working-plan deadline, priority product groups, and the product-specific nature of DPP requirements.

European Commission ESPR overview

Supports the public adoption date for the first ESPR and Energy Labelling Working Plan and the Commission's implementation calendar context.

Recommended next step

Turn DPP deadlines into a tracked implementation calendar

Use this calendar to separate fixed battery passport dates from ESPR product-group milestones that still depend on adopted delegated or implementing acts.

Research workflow

Open Research Copilot

Check Digital Product Passport questions against cited EU source material.

Explore next step

Talk to Sorena

Discuss DPP readiness

Review product scope, delegated-act status, data architecture, and battery passport timing with Sorena.

Explore next step

Section 2

Digital Product Passport system milestones to monitor

ESPR assigns several system-level DPP tasks to delegated or implementing acts. These matter for procurement, data architecture, service-provider selection, and customs readiness, even before a specific product group becomes mandatory.

Calendar entries for service providers, identifiers, access rights, registry upload, web portal, and customs should stay labelled as system triggers until the relevant act and product-group rules are in force.

9 April 2025: the Commission launched a public consultation on DPP data storage, management by service providers, and whether a certification scheme is needed.
1 July 2025: deadline stated by the Commission for feedback to the April 2025 DPP service-provider consultation.
25 July 2025: the Commission launched four impact-assessment surveys on DPP service-provider requirements and certification feasibility.
27 August 2025: deadline stated by the Commission for responses to the July 2025 impact-assessment surveys.
Delegated-act dependent: ESPR DPP requirements must specify the data included, data carrier, carrier layout and positioning, model/batch/item level, pre-contract access, access rights, update actors, update arrangements, and passport availability period.
Implementing-act dependent: the ESPR registry must communicate a unique registration identifier after uploaded data, and customs checks apply from the moment the registry and customs interconnection are operational.

Sources for this answer

Commission consultation on Digital Product Passport service providers

Supports the April 2025 consultation launch, its scope, and the 1 July 2025 feedback deadline.

Commission impact assessment surveys on the Digital Product Passport

Supports the July 2025 impact-assessment surveys, stakeholder groups, service-provider focus, and 27 August 2025 response deadline.

Regulation (EU) 2024/1781 (ESPR)

Supports DPP data-carrier, access-rights, registry, web-portal, and customs triggers that depend on delegated or implementing acts.

Section 3

Battery passport milestones with fixed dates

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 key implementation boundary is category-based: LMT batteries, industrial batteries with a capacity greater than 2 kWh, and electric vehicle batteries have the electronic battery passport obligation from 18 February 2027.

18 February 2024: the Batteries Regulation applies generally, except for provisions with separate application dates.
18 August 2025: all batteries must be marked with the separate collection symbol; this is a battery compliance date adjacent to the passport program.
18 August 2026 or 18 months after the relevant implementing act enters into force, whichever is later: battery labels for general information, capacity, and non-rechargeable duration apply.
By 18 August 2026: the Commission must adopt implementing acts specifying who has a legitimate interest in access to specified battery passport information and how far they may download, share, publish, and reuse it.
18 February 2027: all batteries must be marked with a QR code; for LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries, that QR code must provide access to the battery passport.
18 February 2027: each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service must have an electronic battery passport.

Sources for this answer

Regulation (EU) 2023/1542 concerning batteries and waste batteries

Supports the fixed battery passport date, battery QR-code date, label timing, access-rights implementing-act date, and battery categories in scope.

Section 4

How to keep the calendar accurate

For every DPP entry, record whether the date is fixed in legislation, stated in Commission consultation material, or dependent on a delegated or implementing act. This prevents a planning date from being treated as a compliance deadline.

Update a product-group row only when the adopted act supplies the missing details: product scope, application date, passport data fields, data-carrier rules, access rights, level of passport granularity, and passport availability period.

Use the Batteries Regulation as the source of truth for battery passport launch dates and battery-specific QR obligations.
Use ESPR as the source of truth for the DPP framework, priority product groups, registry, web portal, customs, and the delegated-act dependency.
Use Commission consultation pages only for consultation launch dates, response deadlines, and policy-development status; do not treat consultation text as adopted product duties.
Flag any product group without an adopted delegated act as delegated-act dependent, even when it appears in the ESPR working plan.
Do not add penalties or market-withdrawal dates to this calendar unless the grounding source states the exact penalty rule or enforcement trigger.

Sources for this answer

Regulation (EU) 2024/1781 (ESPR)

Supports the need to derive product-specific DPP obligations from adopted delegated acts rather than from the framework regulation alone.

Regulation (EU) 2023/1542 concerning batteries and waste batteries

Supports keeping battery passport dates separate from ESPR product-group planning dates.

Primary sources