DPPCalendarEU

EU Digital Product Passport deadlines and compliance calendar

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

Separate binding dates from the Commission's indicative product schedule, then calculate each ESPR application date from the adopted delegated act.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
9

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

The EU Digital Product Passport calendar has three clocks. The became operational on 20 July 2026. The Batteries Regulation fixes 18 February 2027 for QR codes on all batteries and electronic passports for specified battery categories. ESPR product-group duties still depend on delegated acts, and each act normally must allow at least 18 months between entry into force and application. Treat the Commission's sector schedule as an indicative adoption plan, not as a product compliance date.

Section 1

Fixed ESPR dates and delegated-act triggers

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.

  • 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.
  • 19 July 2025: the legal bar on the first Article 4 delegated act entering into force before this date expired. This was never a product application deadline.
  • Indicative Q4 2026: the Commission's DPP timeline targets adoption of sector-specific requirements for iron and steel.
  • Indicative Q3-Q4 2027: the Commission targets sector-specific acts for textiles, aluminium, and tyres; it lists furniture for 2028 and mattresses and ICT products for 2029.
  • Other working-plan priorities include detergents, paints, lubricants, chemicals, and new or reviewed energy-related products. Priority or an indicative adoption year does not itself create a DPP duty.
  • Cement backstop: if adequate environmental-footprint and carbon-footprint requirements are absent under the Construction Products Regulation, ESPR requires the Commission to set cement ecodesign requirements in an act adopted no earlier than 31 December 2028 and no later than 1 January 2030. The act still determines whether and how a DPP applies.
Recommended next step

Turn DPP deadlines into a tracked implementation calendar

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

Section 2

Digital Product Passport system milestones to monitor

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 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.

  • 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.
  • 14 July 2026: the Commission adopted Implementing Decision (EU) 2026/1736, publishing references to harmonised parts of six DPP standards.
  • 16 July 2026: the Commission adopted Implementing Regulation (EU) 2026/1778 for the ; it was published on 17 July 2026.
  • 20 July 2026: the Commission launched the operational and its testing environment. This infrastructure milestone is not a universal passport deadline.
  • Indicative Q4 2026: the Commission plans the Batteries Regulation implementing act on access to restricted battery-passport information.
  • Indicative Q2-Q3 2027: the Commission plans DPP service-provider requirements. This is a policy schedule, not an adopted compliance date.
  • 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.
  • Registry sequence: the responsible economic operator uploads the required identifiers and registration data; the registry returns a unique registration identifier. That response is not proof of product compliance.
  • Customs sequence: provide the unique registration identifier for a covered product now that the registry is operational; automated identifier and commodity-code verification starts only when the separate customs interconnection is operational. Article 15 requires that interconnection within four years after Implementing Regulation (EU) 2026/1778 enters into force on 6 August 2026, so the outer date is 6 August 2030.
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 battery category determines the obligation. From 18 February 2027, LMT batteries, industrial batteries with a capacity greater than 2 kWh, and electric vehicle batteries must have an electronic battery passport.

  • 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 Article 13(10) implementing act enters into force, whichever is later: general battery information labels apply, with capacity labels for rechargeable portable, LMT, and SLI batteries and minimum-duration and non-rechargeable labels for non-rechargeable portable batteries.
  • 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.
Section 4

How to keep the calendar accurate

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.

  • Use the Batteries Regulation for battery passport launch dates and battery-specific QR obligations.
  • Use ESPR for the DPP framework, priority product groups, registry, web portal, customs, and the delegated-act dependency.
  • Use Implementing Regulation (EU) 2026/1778 for registry procedures; do not treat successful registration or a registry-issued identifier as proof of product compliance.
  • Use Commission consultation pages only for consultation launch dates, response deadlines, and policy-development status; do not treat consultation text as adopted product duties.
  • Use the Commission DPP timeline for monitoring only. Replace an indicative sector date with the adopted act's dates once that act is published.
  • 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 source states the exact penalty rule or enforcement trigger.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Supports deriving product-specific DPP obligations and application dates from adopted delegated acts rather than the framework or working plan alone.
"in accordance with the applicable delegated acts adopted pursuant to Article 4"
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