Many entrepreneurs ask: "What is the exact date the DPP obligation enters into force for my company?" The answer is: it depends.
Before we go to the calendar, it is worth recalling what this requirement actually is. The Digital Product Passport (DPP) is not just a label, but a digital twin of the product.
The current legal state in the EU resembles building a house: we already have solid foundations (the ESPR framework regulation), but we are still waiting for the finishing designs for individual rooms (so-called Delegated Acts). It is these documents that will establish the final dates for specific industries.
Does this mean you can sit back and wait? Absolutely not. The lack of a rigid date in the calendar lulls vigilance, while in reality, the clock is already ticking.
1. The "18-Month Clock" Mechanism – Why It's Not Worth Waiting
Many manufacturers make a strategic error by waiting for an "official date" in the Official Journal of the EU. Analysis of EU legislative processes indicates a constant pattern: the time for implementation after the official adoption of executive regulations is usually only 18 months.
In the world of complex supply chains, a year and a half is a critically short period. During this time, your company must not only implement an IT system but primarily:
- Map suppliers: Often down to the raw material level (e.g., mine or plantation).
- Collect data: Obtain real indicators of carbon footprint or recycled content, not just estimates.
- Integrate systems: Connect your ERP with supplier databases.
Conclusion: The publication of a draft legal act should be a signal for you to finish implementation works, not just begin them.
2. Schedule – Who Goes First?
Although only the battery sector already has a "rigid" date, the ESPR working plan for 2025–2030 clearly indicates priorities. Here is the projected queue:
| Industry / Product Group | Legal Basis (EU Regulation) | Legal Status / Implementing Act | Expected Start |
|---|---|---|---|
| 🔋 Batteries (EV and industrial >2kWh) | Art. 65 & 96 Reg 2023/1542 | Binding Act: Reg 2023/1542 | Feb 18, 2027 |
| 🔩 Iron and steel | COM(2025) 187 final | Expected Delegated Act (2026) | Forecast: 2027 - 2028 |
| 🏗️ Construction Products (CPR) | Art. 75 Reg 2024/3110 | Reg 2024/3110 | Forecast: 2027 - 2028 |
| 🛞 Tires | COM(2025) 187 final | Expected Delegated Act | Forecast: 2027 - 2028 |
| 🧪 Detergents, paints, lubricants, chemicals | COM(2025) 187 final | Expected Delegated Act | Forecast: 2027 - 2028 |
| 👕 Textiles (clothing and footwear) | COM(2025) 187 final | Expected Delegated Act (2026/27) | Forecast: 2028 - 2029 |
| 🧴 Aluminum | COM(2025) 187 final | Expected Delegated Act (2028) | Forecast: 2029 - 2030 |
| 📱 Electronics / ICT | COM(2025) 187 final | Expected Acts (repairability) | Forecast: 2027 (Appliances) - 2030 (Smartphones) |
| 🪑 Furniture and mattresses | COM(2025) 187 final | Expected Delegated Act (2028/29) | Forecast: 2029 |
Note: Dates (except for batteries) are estimates based on the pace of the European Commission's work and working documents (e.g., COM(2025) 187 final).
3. The Domino Effect – Digitization Will Be Forced by Your Client, Not the Official
This is the most important point for the SME sector. Even if your industry (e.g., production of small metal components) is not mentioned in the first wave, regulations will affect you indirectly.
Regulations will cover not only consumer products (B2C) but also intermediate products (B2B), such as steel, aluminum, or plastics.
This creates a domino effect: A car manufacturer (covered by the requirement) will be legally obliged to obtain data from their steel supplier. The steel supplier – from the ore supplier. If you are an element of this chain and do not provide a "digital passport" for your part, you will block the sale of the final product. As a result – you will fall out of the market faster than an official inspection comes to you.
4. It's Not a Label, It's Infrastructure
Another myth is treating the Passport as a "digital leaflet" or a PDF file in the cloud. The ESPR regulation makes it clear: DPP is live data infrastructure.
Your systems must be ready for:
- Interoperability: Your passport must "talk" to other companies' systems.
- Machine-readable format: Data must be readable not only to the human eye but also to artificial intelligence algorithms, customs systems, and sorting machines in waste sorting plants.
This means the end of the era of closed Excel sheets. Companies must prepare to plug into a pan-European, open digital ecosystem.
What Can You Do Today?
Don't wait for "zero hour."
- Check if your key B2B clients are planning DPP implementations.
- Start collecting raw material data now – this is the most difficult stage.
- Test simple SaaS tools that allow you to get used to the data format without huge investments.
👉 Don't know where to start?
See our guide: DPP Implementation in 5 Steps and check how to prepare your company for this deadline without spending a fortune.