The ESPR is law. Your obligations are not — yet. Delegated acts are the missing piece.

The most common confusion about the EU Digital Product Passport is treating it as one law with one deadline. It is neither. The ESPR — Regulation (EU) 2024/1781, in force since July 2024 — is a framework: it creates the DPP mechanism but deliberately leaves the product-specific rules to be written later, group by group, in delegated acts. Until the delegated act for your product group exists, you have no dated DPP obligation; once it does, the clock runs fast. Understanding this mechanism is the difference between tracking the right document and being surprised by it.

In one line: the ESPR framework is in force, the working plan names the priority product groups, and a delegated act per group then sets the actual data requirements — with obligations biting roughly 18 months after each act enters into force, starting indicatively with iron and steel around 2026.

The four-step mechanism

DPP obligations arrive through a fixed sequence:

1. Framework. The ESPR (Regulation (EU) 2024/1781) entered into force in July 2024. It establishes what a Digital Product Passport is and empowers the Commission to require one — but names no products and sets no dates itself.
2. Working plan. The Commission periodically publishes a working plan selecting priority product groups. The first, in April 2025, named textiles (apparel), furniture including mattresses, and tyres as final products, plus iron and steel and aluminium as intermediates.
3. Delegated act. For each group, the Commission adopts a delegated act — a piece of secondary legislation that turns the framework into concrete, enforceable requirements for that group.
4. Transition. Obligations typically apply roughly 18 months after the delegated act enters into force. Products placed on the EU market after that point need a compliant passport.

No delegated act, no dated obligation. Delegated act adopted, and the countdown has started.

What a delegated act actually specifies

The delegated act is where the abstract becomes operational. For its product group, it defines:

The data requirements — the exact information the passport must carry: material composition, substances of concern, durability, repairability and recyclability data, and whatever else the group demands.
Access tiers — who may see which fields: consumers, recyclers, market-surveillance authorities and customs do not all get the same view.
Passport granularity — whether the passport applies per model, per batch or per individual item.
The timing — the date from which products placed on the market must carry the passport.

This is why generic "DPP requirement lists" circulating today should be read as indicative: until your group's act is published, the definitive list does not exist.

The timeline so far — decided vs indicative

Separating the settled from the expected:

Decided: ESPR in force (July 2024); first working plan published (April 2025) with its five priority groups plus horizontal requirements on repairability and recyclability that can cut across groups, including electronics.
Expected: the first delegated act around 2026, covering iron and steel; textiles indicatively in 2027. Furniture including mattresses, tyres and aluminium follow without scheduled dates yet.
Infrastructure: the EU DPP Registry — where passports must be filed — opens for registration on 19 July 2026, ahead of the first product obligations.

Note what this means for the question "is there a DPP law for my product?": the honest answer is always two-part. The framework and the political selection are done; the enforceable, dated rules for your group arrive only with its delegated act.

How to track delegated acts — and why waiting for them is the wrong plan

Delegated acts are published in the Official Journal of the EU, with drafts appearing earlier through the Commission's consultation process — so the practical tracking routine is: know your product group, watch for its draft act, and read the adopted version for the data list and the application date. PassPer does this monitoring for our customers as part of the service.

But tracking is not preparing. The ~18-month transition is consumed almost entirely by data work: chasing supplier declarations, reconciling spec sheets, verifying claims. Companies that start assembling structured, verified product data before their act is adopted turn the transition into a formality. That is the PassPer model — AI extraction from the documents you already hold, human review, an eIDAS-sealed passport behind a GS1 Digital Link QR, and EU registry filing — from €79/month with a free 30-day pilot. Start with the free 2026 compliance guide or the free readiness check.

Frequently asked questions

Is there a DPP law for my product yet?

That question has a two-part answer. Part one: yes — the ESPR framework has been law since July 2024, and if your product group is in the first working plan (textiles, furniture including mattresses, tyres, iron and steel, aluminium), the direction is decided. Part two: your concrete, dated obligations only exist once the delegated act for your group is adopted — and for every group, that act is still to come.

When is the first delegated act expected?

The first delegated act is expected around 2026, covering iron and steel. Textiles are indicatively expected in 2027. These are working expectations rather than fixed dates — delegated acts are only certain once formally adopted and published.

How long do companies get after a delegated act is adopted?

The ESPR pattern is a transition of roughly 18 months between a delegated act entering into force and the obligations applying to products placed on the market. That sounds generous, but assembling verified material and supplier data across a full product range routinely consumes most of it.

My product group is not in the first working plan. Can I ignore the ESPR?

Not safely. Working plans are revised periodically, and groups that missed the first plan — detergents, paints and lubricants were candidates in the preparatory studies, for instance — are plausible in later plans from around 2028 onwards. There is no dated obligation for them yet, but horizontal requirements on repairability and recyclability can also cut across groups. Building data-readiness now costs little and removes the future fire drill.

See where you stand — three ways, all free.

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