ESPR
Which Product Groups Will Need a DPP?
Which products will require a Digital Product Passport? ESPR priority product groups and the categories exporters should watch.
"Will the DPP cover my product too?" is the question exporters ask most. The short answer: ESPR places nearly all physical products in potential scope, but obligations arrive in stages, starting with priority groups.
Priority product groups
Groups highlighted in the EU's ESPR working plan:
- Textiles and apparel — prioritised for high environmental impact and low recycling rates. Details: textile DPP guide.
- Iron, steel and aluminium — carbon-intensive.
- Electronics and IT equipment — see electronics DPP.
- Furniture, tyres (tyre DPP), detergents, paints, chemicals.
- Batteries, already in scope under a separate regulation (battery passport).
The logic behind scope
Prioritising a product group is not arbitrary. The EU looks at:
- Volume of environmental impact — how large is it on the market and how polluting?
- Improvement potential — how much can circularity and durability gain?
- Market failure — how much does missing information block consumers and recyclers?
These criteria also explain why circularity data sits at the heart of the passport.
What should an exporter do?
Even if your product is not on today's priority list, scope keeps expanding. The right strategy is to keep the data ready rather than wait for the first acts. Start with the data-collection checklist and track the timeline. When you fall in scope, you'll be ready months ahead, not scrambling in weeks.
Frequently asked questions
My product group is not listed. Can I relax?
No. The Working Plan is revised in 2028 and brands already request the data. See what retailers ask suppliers for.
Are food and medicines in scope?
No, they fall outside ESPR.
Is packaging in scope?
Packaging has its own regulation (PPWR) and will use the same infrastructure. See packaging DPP and PPWR.
