The first DPP product groups are set by the ESPR Working Plan COM(2025) 187 final: iron and steel at an indicative 2026, then textiles with a focus on apparel, tyres and aluminium around 2027, furniture in 2028 and mattresses in 2029, each binding only once its delegated act applies.
Which groups the ESPR names first
The Digital Product Passport is established by the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, in force since 18 July 2024. The framework itself sets no product-specific obligation; the data, carrier, access rights and dates are fixed group by group through delegated acts. Which DPP product groups come first is set by the first ESPR and Energy Labelling Working Plan 2025 to 2030, Communication COM(2025) 187 final, adopted 16 April 2025. Digital Product Passport readiness work begins by placing a product against that plan. The Working Plan names six priority groups plus two horizontal measures:
- Textiles, with a focus on apparel (final product)
- Furniture (final product)
- Tyres (final product)
- Mattresses (final product)
- Iron and steel (intermediate product)
- Aluminium (intermediate product)
- Horizontal measures on repairability and on the recyclability and recycled content of electrical and electronic equipment
Indicative years, not legal deadlines
The adoption years attached to each group are indicative planning years, not binding deadlines. As of mid-2026 no product-specific ESPR delegated act had been adopted, so no group yet carries a binding DPP obligation; the requirement for any group begins only once its delegated act is adopted and applies.
| Product group | Indicative year |
|---|---|
| Iron and steel | 2026 |
| Textiles, tyres, aluminium | 2027 |
| Furniture | 2028 |
| Mattresses | 2029 |
| Mid-term review | 2028 |
Across GreenSutra’s DPP work, exporters most often assume one fixed start date applies to every product group, when the timing is staggered and delegated-act dependent.
A separate, dated battery rule
One obligation already carries a firm date. Under the EU Batteries Regulation, Regulation (EU) 2023/1542, Article 77(1), from 18 February 2027 each light means of transport battery, each industrial battery above 2 kWh and each electric vehicle battery must carry a battery passport; portable and consumer batteries below those thresholds are not covered. The DPP guide sets out how these dates map to an export-readiness plan. Obligations sit with EU economic operators, including importers, once a delegated act covers the product group.
Sources: Regulation (EU) 2024/1781 (ESPR) · Regulation (EU) 2023/1542 (EU Batteries) · COM(2025) 187 final Working Plan