ESPR
The DPP Timeline by Sector, Compared
DPP timeline by sector in one table: legal basis, dates and certainty for batteries, steel, aluminium, textiles, tyres, furniture, electronics and more
The answer to "when is the Digital Product Passport mandatory?" depends on the sector — and so does the legal certainty of that answer. One date is written into a regulation: the battery passport on 18 February 2027. Everything else is an indicative year in the ESPR Working Plan, a separate regulation (construction, packaging) or, for smartphones, ecodesign rules without a passport yet.
This article puts twelve product groups in one table and proposes a reading method for exporters selling into several sectors.
The comparison table
| Sector | Legal basis | Delegated act | Expected obligation | Likely granularity | Registry |
|---|---|---|---|---|---|
| Batteries (EV, LMT, industrial above 2 kWh) | Battery Regulation 2023/1542 | None; Annex XIII is in the regulation | 18 February 2027 (fixed) | Item | Battery Regulation; Registry link expected |
| Iron and steel | ESPR | 2026 (indicative) | ~2027–2028 | Batch (heat) | EU DPP Registry |
| Aluminium | ESPR | 2027 (indicative) | ~2028–2029 | Batch (cast) | EU DPP Registry |
| Textiles / apparel | ESPR | 2027 (indicative) | ~2028–2029 | Model or item | EU DPP Registry |
| Tyres | ESPR | 2027 (indicative) | ~2028–2029 | Batch or item | EU DPP Registry (EPREL continues) |
| Furniture | ESPR | 2028 (indicative) | ~2029–2030 | Model or item | EU DPP Registry |
| Mattresses | ESPR | 2029 (indicative) | ~2030–2031 | Item | EU DPP Registry |
| Repairability score (electronics, small appliances) | ESPR horizontal measure | 2027 (indicative) | ~2028–2029 | Model | EU DPP Registry |
| EEE recycled content | ESPR horizontal measure | 2029 (indicative) | ~2030–2031 | Model | EU DPP Registry |
| Construction products | CPR 2024/3110 | Its own implementing rules | Staged (with hEN renewal) | Batch | CPR system; Registry link expected |
| Packaging | PPWR 2025/40 | Implementing acts | Applies since 12 August 2026; label ~August 2028 | Packaging record, linked to product | Registry designed to cover packaging |
| Smartphones and tablets | Ecodesign 2023/1670 and energy label | ESPR review for a passport (2030) | Ecodesign since 20 June 2025; passport later | Model | EPREL |
Reading the table as an exporter
Three columns answer three different questions:
- Legal basis tells you which text to read: for ESPR groups nothing binds until the delegated act arrives; for the CPR and PPWR the rule sits in the regulation and its implementing acts.
- Degree of certainty sets your planning horizon. "Fixed" applies only to batteries; clarify which batteries are in scope. Indicative years can move at the 2028 mid-term review — usually later, not earlier.
- Granularity and registry determine the architecture: item level (batteries) needs unique identifiers per unit; batch level (steel) works with the heat number; model level can lean on an existing EPREL record.
Being off the list is not an exemption. Chemicals, cosmetics and machinery are absent from the 2025–2030 plan yet sit in ESPR scope and enter other products' passports through substance declarations, as whether chemical products are in ESPR scope explains. In textiles one date has already passed: separate collection of textile waste has applied since 1 January 2025, and sorters want the composition data the passport carries.
Selling into several sectors: prioritisation
The typical Turkish exporter is rarely in a single sector: a steel producer also supplies furniture makers; a textile mill sells technical fabric to automotive. Four criteria:
- Law or plan? In the battery supply chain (cells, modules, packs, e-bikes) the 2027 date is beyond debate; start with the battery passport.
- Are you an intermediate producer? Data is requested from iron and steel and aluminium suppliers before finished-goods makers; steel DPP data fields gives the expected list.
- Where is the buyer pressure? Textile and furniture buyers (mattresses included) are not waiting for the delegated act; a tyre maker starts from label and EPREL data.
- Is there an adjacent regime? The CPR for construction products and the PPWR for packaging ask for data before the passport; in electronics the repairability score and smartphone ecodesign rules do the same.
The common denominator never changes: identity, composition, origin and carbon. Build that core once and add sector fields as each delegated act arrives; the timeline guide tracks the dates.
Frequently asked questions
Which DPP date is fixed in law today?
Only the battery passport: 18 February 2027 for EV, LMT and industrial batteries above 2 kWh. Every other ESPR date is indicative.
When does the iron and steel DPP become mandatory?
The delegated act is indicatively expected in 2026; with an 18–36-month transition the obligation lands around 2027–2028. The exact date will be in the act.
What should I do if my product group is not in the table?
It does not mean no obligation: the 2028 review can add groups, buyers can demand data by contract, and your product may feed another passport. Build the core data now.
