Which Products Need a Digital Product Passport?

The short answer

No product needs a Digital Product Passport (DPP) today because of the ESPR alone. The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 is a framework. It does not impose a DPP by itself. Each product group only becomes subject to a DPP when the European Commission adopts a delegated act for that group. The one exception already locked in by separate law is batteries, where the Battery Regulation (EU) 2023/1542 sets a binding 18 February 2027 date.

So the real question is: when does my product group get its delegated act, and what does that act require? This guide maps that out using the ESPR Working Plan 2025-2030 and the Battery Regulation.

How the ESPR decides which products get a DPP

The ESPR replaced the old Ecodesign Directive and widened its scope from energy-related products to nearly all physical goods placed on the EU market. The mechanics are simple:

1. The Commission publishes a multi-year Working Plan naming priority product groups.
2. For each group it drafts a delegated act setting ecodesign and DPP requirements.
3. Once a delegated act applies, every product in that group placed on the EU market must carry a compliant DPP.

The first Working Plan was adopted on 16 April 2025 and runs to 2030. Dates in it are indicative - they signal intent and sequencing, not binding obligations. Treat them as planning anchors, not deadlines.

Priority product groups in the 2025-2030 Working Plan

The Working Plan names a set of priority groups. The most relevant for DPP planning are below, with indicative timing for when delegated acts are expected to be adopted. Application (the date products must actually comply) typically follows adoption by roughly 18 to 24 months.

Horizontal measures (for example, rules on repairability scoring and on unsold consumer goods) sit alongside these group-specific acts. The exact wording and timing of each act can shift during scrutiny, so monitor the official Working Plan rather than secondary summaries.

Batteries: the one binding deadline

Batteries do not wait for an ESPR delegated act. Under the Battery Regulation (EU) 2023/1542, a battery passport becomes mandatory on 18 February 2027 for:

• EV batteries (traction batteries for electric vehicles)
• LMT batteries (light means of transport - e-bikes, e-scooters)
• Industrial batteries with a capacity above 2 kWh

This is a binding application date set directly in the regulation. If you make, assemble, import, or place these batteries on the EU market, the 2027 date applies to you. See our dedicated battery passport guide and the live deadline tracker.

A quick self-test: does my product need a DPP?

Work through these in order:

1. Is it a battery (EV, LMT, or industrial above 2 kWh)? If yes, you have a binding 2027 obligation. Stop here.
2. Is it in a named ESPR priority group (textiles, furniture, tyres, iron and steel, aluminium)? If yes, a DPP is expected once that group's delegated act applies. Start preparing now.
3. Is it a physical product placed on the EU market but not yet named? Almost everything is in scope of the ESPR framework eventually. You are likely in a later wave. Track the next Working Plan revision.
4. Is it explicitly excluded (for example food, feed, medicinal products, living organisms)? These sit outside ESPR scope.

What "in scope" actually requires

When your product group's act applies, the DPP must typically carry a unique product identifier, a data carrier (QR code or NFC), and a defined set of data fields - carbon footprint, materials and substances of concern, recycled content, repairability, and end-of-life information. We break the full field list down in our DPP requirements checklist.

Why prepare before your delegated act lands

The data behind a DPP - supplier disclosures, carbon footprint, material composition - takes months to collect, especially across multi-tier supply chains. Companies that wait for the delegated act to be published are starting the hardest part of the work with the least time. Early movers turn the same data into a marketing and operations asset rather than a last-minute scramble.

If you sell into more than one priority group (say, textiles and furniture), the overlap in data and tooling is significant. Building a single DPP capability now pays off across every future act.

Where DPPAutomate fits

DPPAutomate maps your product portfolio against the current ESPR Working Plan and the Battery Regulation, flags which SKUs fall into which wave, and automates the data collection and passport generation once an act applies. You start with a clear picture of your exposure instead of a guess.

Want to know exactly which of your products are in scope and when? Run a free scope check or explore our platform.