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The Omnibus simplification package does not pause the Digital Product Passport.

The European Commission’s Omnibus simplification agenda has generated a comfortable narrative in boardrooms: "Brussels is rolling back sustainability rules, so the Digital Product Passport will probably be softened or delayed too." That inference does not hold. The Omnibus packages have so far centred on sustainability reporting and due diligence instruments — separate legislation from the ESPR and the Batteries Regulation. Treating an evolving simplification debate elsewhere as a reason to pause DPP preparation is a bet, not a strategy.

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In one line: the Omnibus simplification debate concerns other instruments — ESPR’s DPP framework and the Battery Regulation’s 18 February 2027 passport deadline stand on their own legal feet, and neither has been suspended by it.

What the Omnibus agenda actually is

Under pressure to reduce the administrative burden on European companies, the Commission has been pursuing an "Omnibus" simplification agenda: bundled proposals that amend several existing laws at once to trim reporting obligations, thresholds and timelines. The instruments most prominently targeted have been the corporate sustainability reporting and due diligence frameworks — the disclosure-heavy rules that generate annual reporting work for large companies.

Two things matter about its status. First, it is a legislative process, not a finished law: proposals are negotiated and amended by the European Parliament and Council, and the final scope of any package is not settled until it is adopted and published. Second, an Omnibus proposal only changes the specific instruments it amends. It is not a general deregulation switch.

What it does not change: ESPR and the battery passport

The Ecodesign for Sustainable Products Regulation — Regulation (EU) 2024/1781, in force since July 2024 — is the legal basis for the Digital Product Passport. Its DPP obligations arrive product group by product group through delegated acts, with the first working plan (April 2025) prioritising textiles, furniture including mattresses, tyres, iron and steel, and aluminium. The Batteries Regulation — Regulation (EU) 2023/1542 — makes the battery passport mandatory from 18 February 2027 for EV batteries, all LMT batteries and industrial batteries above 2 kWh.

These are separate instruments from the reporting laws in the simplification spotlight. Unless and until a legislative act is adopted that explicitly amends ESPR or the Batteries Regulation, their obligations and timelines stand. The EU DPP Registry opened for registration on 19 July 2026 — the infrastructure is being built out, not wound down.

Why "wait and see" is a bad compliance strategy

Betting on relief that has not been legislated carries an asymmetric risk profile:

Companies that lobbied for simplification of reporting rules did so while continuing to comply with the law as it stood. That is the correct posture here too.

What a sensible operator does now

You do not need to predict Brussels to act rationally. Anchor on what is already law: if you place in-scope batteries on the EU market, the 18 February 2027 passport deadline is fixed. If your products sit in the first ESPR working plan’s priority groups, obligations are expected to bite roughly 18 months after each delegated act enters into force — which makes data readiness, not passport publication, the work of 2026.

Concretely: inventory which regulations actually touch your products; map the data you already hold in spec sheets, certificates and supplier declarations; and close gaps with suppliers now, while lead times are sane. PassPer’s free readiness check tells you in minutes which obligations apply to your products and how large your data gap is — a far cheaper way to resolve uncertainty than waiting for the Official Journal.

Frequently asked questions

Has the Omnibus package delayed the Digital Product Passport?
No. The Omnibus simplification proposals have centred on sustainability reporting and due diligence legislation — separate instruments from the ESPR, which is the legal basis for the DPP. ESPR entered into force in July 2024 and its delegated-act process is proceeding; no adopted act has suspended or delayed the DPP framework.
Could the DPP still be simplified or postponed later?
The legislative process is evolving and future proposals could in principle touch any instrument, so certainty is impossible. But compliance planning has to be based on the law as it stands — and as it stands, ESPR and the Batteries Regulation timelines apply. If relief ever comes, preparation costs little; if it does not, waiting costs a lot.
Does the Omnibus debate affect the 18 February 2027 battery passport deadline?
No adopted legislation has changed it. The battery passport obligation in Regulation (EU) 2023/1542 applies from 18 February 2027 to EV batteries, all LMT batteries and industrial batteries above 2 kWh, and that is the date to plan against.
Our competitors seem to be waiting. Why should we move first?
Because supplier data collection is the slow, queue-based part of DPP compliance. When a delegated act lands, thousands of companies will chase the same suppliers for the same declarations at once. Early movers collect data on normal lead times and turn compliance into a sales asset; late movers pay rush premiums or miss shipping windows.

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