A DPP Regulation Checklist for Economic Operators

The main framework behind most Digital Product Passport (DPP) obligations in the EU is the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, which sets horizontal rules covering nearly all physical goods placed on the EU market. Two further regulations — the Battery Regulation (EU) 2023/1542 and the Construction Products Regulation (EU) 2024/3110 create DPP obligations of their own outside that framework.  A fourth imposes a narrower, adjacent duty. Two more, CSRD and WEEE, get mistaken for DPP triggers often enough to rule out here.

ESPR, The Framework Regulation

Ecodesign for Sustainable Products Regulation (ESPR) [Regulation (EU) 2024/1781]

• In force since 18 July 2024
• Covers almost all physical goods by default. Article 1 excludes food, feed, and medicinal products, motor vehicles already regulated under other EU type-approval legislation, and products intended solely for defence or national security
• A product only gets a live DPP obligation once the Commission adopts a delegated act under Article 4 for its specific category
• The Working Plan 2025-2030, adopted 16 April 2025, prioritises steel and aluminium, textiles, furniture, tyres, and mattresses for that delegated act work
• Being on the Working Plan signals direction, not a compliance date. Treating the two as the same thing is the most common mistake economic operators make when reading ESPR

Textiles: A Priority Category, Where the Delegated Act Actually Stands

Two different processes run under ESPR for textiles, and they're easy to conflate.

• Destruction ban and disclosure rules: already adopted. The Commission adopted the delegated and implementing acts on 9 February 2026, banning destruction of unsold apparel, clothing accessories, and footwear, with limited exemptions under Article 25(5). Applies to large companies from 19 July 2026, medium-sized companies from 2030
• The main ecodesign delegated act for textile apparel: the one that will set the actual DPP data requirements, still in preparatory study. Stakeholder workshop held 14-15 January 2026, written comments accepted until 23 March 2026. Adoption expected early 2027
• These are two separate legal instruments moving at two different speeds. A company can be compliant with the destruction ban and still have no live DPP obligation for the same garments

What a Textile DPP Will Likely Contain

A JRC study on DPP content for textile apparel under ESPR groups the required information into four categories:

• Product identification and classification
• Producer identification
• Product information
• Compliance documentation

These categories don't yet have the force of law, since they come from a preparatory study rather than the delegated act itself. Still, they give the clearest picture available of what the eventual data fields will look like.

Regulations That Independently Require a DPP

Battery Regulation [Regulation (EU) 2023/1542]

• In force since 17 August 2023
• Doesn't wait on ESPR's delegated act mechanism; sets its own passport requirement directly
• Article 77(1) requires an electronic battery passport from 18 February 2027 for LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries. This is the closest thing to a fixed, settled deadline anywhere in this checklist
• Due diligence obligations run on a separate clock, postponed to 18 August 2027 by Regulation (EU) 2025/1561

Construction Products Regulation (CPR) [Regulation (EU) 2024/3110]

• Creates its own construction products digital passport system, separate from ESPR's. Chapter X, Articles 75-80 of the CPR itself define the requirements for the DPP and the DPP system
• Functionalities and requirements for the passport are still to be set through delegated acts
• A feasibility study published 26 September 2025 assessed three implementation options: a centralised Commission database, a decentralised licensed-provider model, and a decentralised manufacturer-run model with backup providers (Executive Summary, p. 13)
• The study stops short of naming a preferred option. Its conclusions section focuses on cross-cutting requirements instead: alignment with ESPR, BIM/CEN compatibility, a shared EU data dictionary, and states cooperation is needed "regardless of the selected option" (p. 91)

A Narrower Duty: Critical Raw Materials Act (CRMA)

[Regulation (EU) 2024/1252]

• In force since 23 May 2024
• Doesn't create a DPP in the ESPR sense. Creates a narrower, product-specific label and data carrier requirement for goods containing permanent magnets 
• Article 28 requires that the label and data carrier on listed products, including motor vehicles and light means of transport, disclose the type and location of any permanent magnets and information needed to access and remove them 
• Article 29 requires recycled content disclosure for the main magnet raw materials, for products where the magnet weighs above roughly 200g 
• Where a product already requires a DPP under another EU law, Article 28(6) folds the magnet information into that DPP rather than keeping it as a standalone disclosure, so once an ESPR delegated act creates a DPP for a product category, the CRMA magnet data becomes one more field inside it, not a separate system 
• Targets a single component, not a product's whole lifecycle, so it doesn't replace an ESPR DPP where one eventually applies to the same product. The two obligations can converge once a DPP exists; the underlying legal basis stays separate 

Do CSRD or WEEE Count as DPP Obligations?

• CSRD (Directive (EU) 2022/2464): requires large companies to disclose sustainability information at company level, not product level. Doesn't create a DPP
• WEEE Directive  (Directive 2012/19/EU): requires producers of electrical and electronic equipment to give recyclers treatment information under Article 15. A duty that predates the DPP and runs alongside it, not instead of it

DPP Regulation Timeline

Already in force or adopted

• 17 August 2023 — Battery Regulation in force (Regulation (EU) 2023/1542)
• 18 July 2024 — ESPR in force (Regulation (EU) 2024/1781)
• 23 May 2024 — CRMA in force (Regulation (EU) 2024/1252)
• 26 September 2025 — CPR passport feasibility study complete (Regulation (EU) 2024/3110)
• 9 February 2026 — Textile destruction ban delegated and implementing acts adopted (ESPR Art. 25(5))
• July 2026 — EU DPP registry launched (ESPR Art. 13)

Confirmed upcoming dates

• 18 February 2027 — Battery passport required for LMT, industrial >2kWh, and EV batteries (Battery Reg. Art. 77(1))
• Early 2027 — Textile DPP delegated act adoption expected (ESPR)
• 2027, indicative — Tyres delegated act adoption (ESPR Working Plan 2025-2030)
• 2028, indicative — Furniture DPP adoption (ESPR Working Plan 2025-2030)
• 2029, indicative — Mattresses DPP adoption (ESPR Working Plan 2025-2030)

Still pending, no confirmed date

• Iron and steel, aluminium, and EEE recyclability requirements. Iron and steel specifically is at a second stakeholder consultation as of April 2026

Where This Leaves You

None of these regulations moves at the same speed:

• A battery business is already working to a fixed February 2027 deadline
• A textile business faces the destruction ban, but still has no live DPP obligation for those same garments until the separate delegated act is adopted 
• A construction products business knows a passport is coming but not yet when
• A business dealing in permanent magnets has a live labelling duty today with no connection to any of the above

The practical next step is the same regardless of category: confirm which regulation applies, confirm whether a delegated act exists yet for that product, and start mapping what data would need collecting and where it currently lives in the business or supply chain. Waiting for a delegated act before starting that mapping is often the expensive choice, since traceability data usually sits several tiers back in the supply chain. DigiProd Pass works with manufacturers and suppliers across battery, automotive, textile, and other sectors on exactly this mapping, sector by sector.

FAQs

What happens if a product doesn't have a required DPP? It doesn't clear customs and can't legally be sold in the EU. Beyond that, Member States set their own penalty rules under each regulation's own penalties article, which must be effective, proportionate, and dissuasive.

Does ESPR apply to a product right now? Only if a delegated act has been adopted for that product's category.

Has the textile delegated act been adopted yet? No. The main ecodesign delegated act for apparel is still in preparatory study, with adoption expected early 2027. A separate, already-adopted rule bans destruction of unsold apparel and footwear from July 2026, but that's not the same instrument.

Is a battery covered by ESPR or the Battery Regulation? The Battery Regulation, with passport obligations from 2027, runs independently of ESPR.

Does the CRMA require a full Digital Product Passport? No. It requires a label and data carrier for products containing permanent magnets. That's narrower than a DPP, not a substitute for one.

Does CSRD or WEEE count as meeting DPP obligations? No. CSRD reports at company level. WEEE is a pre-existing information duty under Article 15. Neither substitutes for a product-level DPP.

Sources

Regulation (EU) 2024/1781 (ESPR), Art. 1, 4, 13 — https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng

Regulation (EU) 2023/1542 (Batteries), Art. 77(1) — https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng

Regulation (EU) 2025/1561 (due diligence postponement) — https://eur-lex.europa.eu/eli/reg/2025/1561/oj/eng

Regulation (EU) 2024/3110 (CPR) — https://eur-lex.europa.eu/eli/reg/2024/3110/oj

Regulation (EU) 2024/1252 (CRMA), Art. 28, 29 — https://eur-lex.europa.eu/eli/reg/2024/1252/oj/eng

Directive (EU) 2022/2464 (CSRD) — https://eur-lex.europa.eu/eli/dir/2022/2464/oj

Directive 2012/19/EU (WEEE), Art. 15 — https://eur-lex.europa.eu/eli/dir/2012/19/oj

EC, unsold apparel/footwear destruction ban, 9 Feb 2026 — https://environment.ec.europa.eu/news/new-eu-rules-stop-destruction-unsold-clothes-and-shoes-2026-02-09_en

JRC, Textile Products preparatory study — https://susproc.jrc.ec.europa.eu/product-bureau/product-groups/467/home

González-Torres & Arcipowska, "DPP content for textile apparel," JRC, 13 May 2026, Sec. 7 — https://susproc.jrc.ec.europa.eu/product-bureau/sites/default/files/2026-05/Textiles_DPP_20260513.pdf

EC, Ecodesign & Energy Labelling Working Plan 2025-2030, COM(2025) 187 final — https://data.consilium.europa.eu/doc/document/ST-8225-2025-INIT/en/pdf

EC, CPR Digital Product Passport feasibility study, 26 Sep 2025 — https://op.europa.eu/en/publication-detail/-/publication/cf329d5e-3464-11f0-8a44-01aa75ed71a1/language-en

JRC, ETP Alcoy 2025 presentation, adoption-timeline table — https://susproc.jrc.ec.europa.eu/product-bureau/sites/default/files/2025-05/ETP-Alcoy-2025_Enrique%20Garcia_20250502.pdf

JRC, Iron and Steel preparatory study documents — https://susproc.jrc.ec.europa.eu/product-bureau/product-groups/642/documents

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