Which Products Come First EU Digital Product Passport priority

For binding passport planning, separate the battery passport from the ESPR Digital Product Passport. The Batteries Regulation says that from 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.

For ESPR product groups, there is no single universal DPP start date. The adopted working plan gives indicative years for adopting measures. After an ESPR delegated act is adopted, economic operators normally receive at least 18 months before its requirements apply, subject to the act's stated transition.

The adopted 2025-2030 working plan selects textiles and apparel, furniture, tyres, mattresses, iron and steel, and aluminium for new product work. It also includes horizontal work on repairability and on recycled content and recyclability of electrical and electronic equipment, plus carried-over measures for specified energy-related products.

Its indicative adoption sequence is iron and steel in 2026; textiles and apparel, tyres, aluminium, and repairability in 2027; furniture in 2028; and mattresses plus the electrical and electronic equipment horizontal measure in 2029. These are dates for planned adoption of measures, not product compliance dates.

Under ESPR, the delegated act is where the general framework becomes product-specific. ESPR Article 9 says products can be placed on the market or put into service only if a digital product passport is available in accordance with the applicable delegated acts, and Article 9 also says those acts specify which data must be included, the data carriers to be used, and how the carrier is presented and positioned.

A priority category, consultation, or technical standard can support early architecture work but does not create the final product duty. Check the delegated act before locking product labels, carrier placement, access tiers, registry fields, or contractual supplier-data duties.

For batteries, use the Batteries Regulation passport scope if the business places covered LMT, industrial greater-than-2 kWh, or electric vehicle batteries on the EU market or puts them into service. That work should include the battery category decision, the responsible economic operator, QR-code access, and the information set in Annex XIII.

For ESPR products, prepare the parts that are unlikely to be wasted: product-group mapping, supplier data ownership, identifier strategy, data-quality controls, and change monitoring. Hold back from asserting final product-group passport dates, mandatory fields, or carrier layout until the delegated act for that group exists and has been reviewed.