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 in the grounded sources for this page. ESPR creates the framework, requires the Commission to prioritise product groups in a working plan, and makes product-specific passport obligations depend on delegated acts adopted for the product group.

ESPR Article 18 sets the first working-plan priority list. The listed groups are iron and steel; aluminium; textiles, especially garments and footwear; furniture, including mattresses; tyres; detergents; paints; lubricants; chemicals; relevant energy-related products; and information and communication technology products and other electronics.

That list is useful for sequencing preparation because it tells product, sustainability, supply-chain, and data teams where to watch first. It does not answer the operational DPP questions by itself: what data must be in the passport, where the carrier sits, who gets which access rights, what conformity route applies, and when the product-specific requirements apply.

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.

That is why a company should avoid treating a priority category, a consultation, or a technical standard as the final compliance rule. They can justify early architecture work, but the delegated act is the source to check before locking product labels, QR placement, access tiers, registry fields, or contractual supplier data duties.

For batteries, build against the grounded 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.