“Batteries already have a Digital Product Passport deadline — why doesn’t my product?” is a fair question, and the usual answer — something vague about batteries being a bigger priority — isn’t quite right. The real answer is simpler and more useful: batteries were never waiting on ESPR in the first place. They’re running on a completely different legal track, one that started earlier and skips several steps ESPR categories can’t skip.
Two different machines, one shared idea
The Digital Product Passport as a concept — a structured, QR-linked record of a product’s materials, origin and end-of-life information — shows up in several EU laws. But “shows up in the law” and “has a confirmed deadline” are different things, and which law a product falls under changes how long that takes.
- ✓The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, is a framework. It doesn’t set product deadlines itself — Article 4 empowers the Commission to adopt a separate delegated act per product category, deciding whether and when a passport applies to it, and it’s that delegated act which switches on the DPP content and registration rules ESPR itself already sets out in Articles 9–13.
- ✓The Battery Regulation, Regulation (EU) 2023/1542, is a self-contained sectoral law. It doesn’t delegate its passport requirements to a future act — Article 77 and Annex XIII, already written into the regulation itself, set out exactly what a battery passport must contain and by when.
The Battery Regulation had a year's head start — and no pipeline to sit in
The Battery Regulation was adopted in July 2023 and entered into force on 17 August 2023 — roughly a year before ESPR itself entered into force in July 2024. It was never part of the ESPR Working Plan, and it didn’t need to be: its passport rules didn’t depend on a Commission delegated act being drafted, consulted on and adopted after the fact. They were part of the original text.
Compare that to what an ESPR category has to go through before a deadline even exists:
- ✓The Commission adopts a Working Plan naming priority categories — ESPR’s first Working Plan landed on 16 April 2025, naming textiles, furniture, iron & steel, tyres, aluminium and mattresses.
- ✓The Commission’s Joint Research Centre runs a preparatory study for that category, gathering technical input on what the passport should contain.
- ✓An impact assessment and Ecodesign Forum consultation with member states and stakeholders follows.
- ✓The Commission publishes a proposal, then formally adopts the delegated act.
- ✓Only after adoption does the clock start on the minimum 18-month transition before the obligation actually applies.
As of this writing, no ESPR delegated act setting ecodesign requirements and passport content for a product category has been adopted yet. (The one ESPR delegated act adopted so far, in February 2026, only set disclosure rules for unsold-goods destruction — a horizontal transparency measure, not a category’s ecodesign requirements or passport content.) The closest to landing is iron & steel, where the Commission ran a public consultation on its draft delegated act from 20 May 2026, with adoption expected in the fourth quarter of 2026. Textiles, furniture, tyres and aluminium are all still earlier in the same pipeline. None of that is a delay — it’s what the process looks like when a deadline has to be built from scratch rather than inherited from an existing law.
Batteries aren't the only ones who skipped the queue
The same pattern shows up wherever a product category already had its own dedicated EU regulation before ESPR arrived, or gets one through a different route entirely. Construction products, toys and detergents all have confirmed DPP dates that come from their own laws, not from ESPR’s delegated-act machinery:
The dividing line isn’t importance or urgency — it’s whether a category already had (or gets) its own dedicated law with the passport content written in directly, or whether it has to wait for ESPR’s own delegated-act process to run.
What this means if you're waiting on an ESPR category
If your product is textiles, furniture, or one of the other ESPR priority categories, seeing batteries get a deadline first tells you nothing about how close your own is. It just confirms the structural point above: your category is going through a pipeline that batteries never had to enter. The realistic estimates haven’t moved — textiles around 2028–2029, furniture around 2029–2030, iron & steel around 2028 — and none of them accelerate because a different, already-regulated product got its passport first.
The useful move isn’t watching the battery deadline for clues about your own. It’s checking whether your product already has a dedicated EU regulation of its own (the way batteries, construction products and toys do) before assuming the ESPR Working Plan is where your date will come from at all.
How to check your own category in two minutes
- ✓First, check for a dedicated regulation. Search for “[your product] EU regulation” — if one exists with its own passport or labelling requirements, that law's dates apply, not ESPR's Working Plan.
- ✓If none exists, check the ESPR Working Plan. Our Digital Product Passport timeline lists every confirmed and expected date by category, and separates the two clearly.
- ✓Either way, start the data work now. Materials, origin, certifications and end-of-life information take a season or more to collect properly from suppliers — that part of the job doesn’t change no matter which legal track your category is on.