Deadline tracker: product document duties by product group
Next to apply: from 29 November 2026 “Euro 7: environmental vehicle passport for every vehicle” under Regulation (EU) 2024/1257; from 30 December 2026 “Deforestation Regulation: due diligence statement before placing on the market” under Regulation (EU) 2023/1115 (Deforestation Regulation); from 20 January 2027 “Machinery Regulation: digital instructions” and two further duties under Regulation (EU) 2023/1230.
Which duties on product documents apply to your products, and from when? Open your product groups. Every entry comes with its status and legal source.
As of · Not legal advice · Dates for acts that are not yet adopted are Commission statements and may move.
The next dates
- 15Days until 29 Nov 2026Euro 7: environmental vehicle passport for every vehicleAdopted · See the source
- 46Days until 30 Dec 2026Deforestation Regulation: due diligence statement before placing on the marketAdopted · See the source
- 67Days until 20 Jan 2027Machinery Regulation: digital instructionsAdopted · See the source
- 96Days until 18 Feb 2027Battery passport (LMT, industrial over 2 kWh, electric vehicle batteries)Adopted · See the source
Duties by product group
Open your group. Status and source are next to each duty.
Chemical products (substances, mixtures)Adhesives, paints, varnishes, cleaners, oils, additives
already applies (since 1 June 2007)
Supply the safety data sheet
Safety data sheet for hazardous substances and mixtures, free of charge, in an official language of the Member State where the product is placed on the market, unless the Member State concerned provides otherwise, no later than the date of first supply (Art. 31 REACH).
In ProofPass: Safety data sheet, recipient list with proof of delivery
already applies (since 1 June 2007)
New safety data sheet version to recipients of the last 12 months
Without delay as soon as new information on hazards becomes available, once an authorisation has been granted or refused, or once a restriction has been imposed (Art. 31(9) REACH).
In ProofPass: Sending new versions to the recipient list
already applies (since 1 June 2007)
10-year retention
All REACH information, including superseded safety data sheet versions, for at least 10 years after the last manufacture, import, supply or use (Art. 36 REACH).
In ProofPass: Version archive
already applies (since 1 January 2023)
Safety data sheet format under Regulation (EU) 2020/878
All safety data sheets in the new format of Annex II, including UFI, nanoforms and endocrine disrupting properties.
Regulation (EU) 2020/878 (Annex II to REACH, format of the safety data sheet)
already applies (since 1 January 2025)
UFI on the label and notification to poison centres
Hazardous mixtures carry the 16-character UFI on the label; the submission to the appointed bodies (poison centres) follows Annex VIII to CLP. The transitional period ended on 1 January 2025.
In ProofPass: UFI on the product, safety data sheet section 1.1
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
adopted, applies from 1 January 2028
New CLP label rules (format, online offers)
Minimum font sizes and formatting (Art. 31(3), section 1.2.1 of Annex I to CLP), new time limits for updating labels (Art. 30), advertisements (Art. 48) and information in distance sales offers (Art. 48a); postponed by the “stop the clock” Regulation (EU) 2025/2439, voluntary application possible until 31 December 2027. Goods labelled under the previous formatting rules and placed on the market before 1 January 2027 are not required to be relabelled until 1 January 2029 (Art. 61(8)). Parliament approved a further postponement on 22 October 2026 (Omnibus VI); the Council and the Official Journal are outstanding, so the date still stands. The voluntary digital label has been possible since 1 July 2026.
Regulation (EU) 2024/2865 (amending the CLP Regulation)Regulation (EU) 2025/2439 (“stop the clock” for CLP)European Parliament: procedure 2025/0531(COD), Omnibus VI
Construction chemicals and sealantsSealants, tile adhesives, primers, waterproofing
already applies (since 1 June 2007)
Supply the safety data sheet
Safety data sheet for hazardous substances and mixtures, free of charge, in an official language of the Member State where the product is placed on the market, unless the Member State concerned provides otherwise, no later than the date of first supply (Art. 31 REACH).
In ProofPass: Safety data sheet, recipient list with proof of delivery
already applies (since 1 June 2007)
New safety data sheet version to recipients of the last 12 months
Without delay as soon as new information on hazards becomes available, once an authorisation has been granted or refused, or once a restriction has been imposed (Art. 31(9) REACH).
In ProofPass: Sending new versions to the recipient list
already applies (since 1 June 2007)
10-year retention
All REACH information, including superseded safety data sheet versions, for at least 10 years after the last manufacture, import, supply or use (Art. 36 REACH).
In ProofPass: Version archive
already applies (since 1 January 2023)
Safety data sheet format under Regulation (EU) 2020/878
All safety data sheets in the new format of Annex II, including UFI, nanoforms and endocrine disrupting properties.
Regulation (EU) 2020/878 (Annex II to REACH, format of the safety data sheet)
already applies (since 1 January 2025)
UFI on the label and notification to poison centres
Hazardous mixtures carry the 16-character UFI on the label; the submission to the appointed bodies (poison centres) follows Annex VIII to CLP. The transitional period ended on 1 January 2025.
In ProofPass: UFI on the product, safety data sheet section 1.1
already applies (since 8 January 2026)
Declaration of performance and conformity (new Construction Products Regulation)
Regulation (EU) 2024/3110 applies; the switch comes per product family, one year after the adoption of the implementing act on the new specification, or later (Art. 95(9)); supply by electronic means is the rule (Art. 16(1)).
In ProofPass: Declaration of performance as a document type, QR code
Regulation (EU) 2024/3110 (Construction Products Regulation)European Commission: Construction Products Regulation, 2024 revision
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
adopted, applies from 1 January 2028
New CLP label rules (format, online offers)
Minimum font sizes and formatting (Art. 31(3), section 1.2.1 of Annex I to CLP), new time limits for updating labels (Art. 30), advertisements (Art. 48) and information in distance sales offers (Art. 48a); postponed by the “stop the clock” Regulation (EU) 2025/2439, voluntary application possible until 31 December 2027. Goods labelled under the previous formatting rules and placed on the market before 1 January 2027 are not required to be relabelled until 1 January 2029 (Art. 61(8)). Parliament approved a further postponement on 22 October 2026 (Omnibus VI); the Council and the Official Journal are outstanding, so the date still stands. The voluntary digital label has been possible since 1 July 2026.
Regulation (EU) 2024/2865 (amending the CLP Regulation)Regulation (EU) 2025/2439 (“stop the clock” for CLP)European Parliament: procedure 2025/0531(COD), Omnibus VI
expected, not yet adopted: Date open
Product passport for construction products
Through a delegated act under the Construction Products Regulation (Art. 75(1)); the duty applies 18 months after it (Art. 22(7), Art. 80(1)).
In ProofPass: Product address and QR code as the basis
Regulation (EU) 2024/3110 (Construction Products Regulation)European Commission: Construction Products Regulation, 2024 revision
Construction products without hazardous substancesInsulation, windows, boards, profiles
already applies (since 8 January 2026)
Declaration of performance and conformity (new Construction Products Regulation)
Regulation (EU) 2024/3110 applies; the switch comes per product family, one year after the adoption of the implementing act on the new specification, or later (Art. 95(9)); supply by electronic means is the rule (Art. 16(1)).
In ProofPass: Declaration of performance as a document type, QR code
Regulation (EU) 2024/3110 (Construction Products Regulation)European Commission: Construction Products Regulation, 2024 revision
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
expected, not yet adopted: Date open
Product passport for construction products
Through a delegated act under the Construction Products Regulation (Art. 75(1)); the duty applies 18 months after it (Art. 22(7), Art. 80(1)).
In ProofPass: Product address and QR code as the basis
Regulation (EU) 2024/3110 (Construction Products Regulation)European Commission: Construction Products Regulation, 2024 revision
Detergents and cleaning productsfor household and professional use
already applies (since 1 June 2007)
Supply the safety data sheet
Safety data sheet for hazardous substances and mixtures, free of charge, in an official language of the Member State where the product is placed on the market, unless the Member State concerned provides otherwise, no later than the date of first supply (Art. 31 REACH).
In ProofPass: Safety data sheet, recipient list with proof of delivery
already applies (since 1 June 2007)
New safety data sheet version to recipients of the last 12 months
Without delay as soon as new information on hazards becomes available, once an authorisation has been granted or refused, or once a restriction has been imposed (Art. 31(9) REACH).
In ProofPass: Sending new versions to the recipient list
already applies (since 1 June 2007)
10-year retention
All REACH information, including superseded safety data sheet versions, for at least 10 years after the last manufacture, import, supply or use (Art. 36 REACH).
In ProofPass: Version archive
already applies (since 13 December 2024)
Product information in online sales to consumers (GPSR)
Manufacturer and contact details, product identification, warnings and safety information in the online offer (Art. 19 GPSR).
In ProofPass: Instructions and safety information as a document type
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 13 December 2024)
Responsible economic operator in the EU (GPSR)
A product may only be placed on the market if an economic operator established in the Union is responsible for it; the details are indicated on the product or on its packaging, the parcel or an accompanying document (Art. 16(3) GPSR).
In ProofPass: Manufacturer details on the product and in the online offer
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)Regulation (EU) 2019/1020 (market surveillance)
already applies (since 13 December 2024)
Risk analysis and technical documentation (GPSR)
Internal risk analysis and technical documentation per product, kept for ten years after the product has been placed on the market (Art. 9(2) and (3) GPSR).
In ProofPass: Document types instructions, certificate and declaration of conformity, with version archive
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 13 December 2024)
Report accidents, deliver recalls (GPSR)
Accidents are notified to the authority through the Safety Business Gateway (Art. 20). In a recall you notify the affected consumers directly; where not all of them can be contacted, you disseminate a clear and visible recall notice through other appropriate channels (Art. 35 and 36).
In ProofPass: Recipient list with proof of delivery for safety information
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 1 January 2025)
UFI on the label and notification to poison centres
Hazardous mixtures carry the 16-character UFI on the label; the submission to the appointed bodies (poison centres) follows Annex VIII to CLP. The transitional period ended on 1 January 2025.
In ProofPass: UFI on the product, safety data sheet section 1.1
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
adopted, applies from 1 January 2028
New CLP label rules (format, online offers)
Minimum font sizes and formatting (Art. 31(3), section 1.2.1 of Annex I to CLP), new time limits for updating labels (Art. 30), advertisements (Art. 48) and information in distance sales offers (Art. 48a); postponed by the “stop the clock” Regulation (EU) 2025/2439, voluntary application possible until 31 December 2027. Goods labelled under the previous formatting rules and placed on the market before 1 January 2027 are not required to be relabelled until 1 January 2029 (Art. 61(8)). Parliament approved a further postponement on 22 October 2026 (Omnibus VI); the Council and the Official Journal are outstanding, so the date still stands. The voluntary digital label has been possible since 1 July 2026.
Regulation (EU) 2024/2865 (amending the CLP Regulation)Regulation (EU) 2025/2439 (“stop the clock” for CLP)European Parliament: procedure 2025/0531(COD), Omnibus VI
adopted, applies from 23 September 2029
Product passport for detergents
New Detergents Regulation (EU) 2026/405 with a product passport; a digital label is possible, safety-critical information stays on the label.
Batteries and rechargeable batteriesPortable, LMT, industrial and traction batteries
expected, not yet adopted: 18 months after the implementing act, at the earliest 18 August 2026
Battery label with general information
Art. 13(1) to (3) apply from 18 August 2026 or 18 months after the entry into force of the implementing act, whichever is the latest. As at 2 November 2026 we did not find this act in the EUR-Lex database.
Regulation (EU) 2023/1542, consolidated text of 13 August 2026
already applies (since 18 August 2025)
Separate collection symbol on batteries
All batteries are marked with the separate collection symbol shown in Part B of Annex VI (Art. 13(4)), with Cd or Pb beneath it above the thresholds in Art. 13(5).
Regulation (EU) 2023/1542, consolidated text of 13 August 2026
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
adopted, applies from 18 February 2027
QR code on all batteries
QR code under Art. 13(6): it gives access to the battery passport or, for other batteries, to the labelling information, the declaration of conformity, the due diligence report and the information on waste batteries. Visible, legible and indelible on the battery, otherwise on the packaging and the accompanying documents (Art. 13(7)).
In ProofPass: QR code with declaration of conformity and information
Regulation (EU) 2023/1542, consolidated text of 13 August 2026
adopted, applies from 18 February 2027
Battery passport (LMT, industrial over 2 kWh, electric vehicle batteries)
Electronic battery passport under Art. 77(1) of the Battery Regulation. The date is in the consolidated text of 13 August 2026; a pending amendment procedure (COM(2025) 981) does not change it in the Commission proposal.
Regulation (EU) 2023/1542, consolidated text of 13 August 2026Proposal COM(2025) 981 amending the Battery Regulation
adopted, applies from 18 February 2027
Batteries: removability and replaceability
Anyone placing products with incorporated portable batteries on the market ensures that end-users can readily remove and replace them. For LMT batteries this applies to independent professionals (Art. 11(1) and (5), Art. 96(2)). Commission Delegated Regulation (EU) 2026/1770 extended the derogations in paragraph 2.
Regulation (EU) 2023/1542, consolidated text of 13 August 2026Delegated Regulation (EU) 2026/1770 (derogations under Art. 11 of the Battery Regulation)
Iron, steel and aluminiumSemi-finished products and articles
expected, not yet adopted: Act expected at the end of 2026
Product passport for iron and steel (ESPR)
First product group of the ecodesign working plan; the duty usually applies 18 months after the act.
Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: digital product passport for iron and steel
expected, not yet adopted: Act likely in 2027
Product passport for aluminium (ESPR)
Priority in the ecodesign working plan 2025–2030.
Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030
Textiles, clothing, footwear
already applies (since 13 December 2024)
Product information in online sales to consumers (GPSR)
Manufacturer and contact details, product identification, warnings and safety information in the online offer (Art. 19 GPSR).
In ProofPass: Instructions and safety information as a document type
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
expected, not yet adopted: Act likely in 2027
Product passport for textiles (ESPR)
Priority in the ecodesign working plan; plus the ban on destroying unsold clothing and footwear (large enterprises since 19 July 2026, medium-sized enterprises from 19 July 2030).
Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030
Furniture and mattresses
already applies (since 13 December 2024)
Product information in online sales to consumers (GPSR)
Manufacturer and contact details, product identification, warnings and safety information in the online offer (Art. 19 GPSR).
In ProofPass: Instructions and safety information as a document type
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
expected, not yet adopted: Act likely in 2028
Product passport for furniture (ESPR)
Priority in the ecodesign working plan 2025–2030.
Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030
expected, not yet adopted: Act likely in 2029
Product passport for mattresses (ESPR)
Priority in the ecodesign working plan 2025–2030.
Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030
Tyres
expected, not yet adopted: Act likely in 2027
Product passport for tyres (ESPR)
Priority in the ecodesign working plan 2025–2030.
Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030
Electrical and electronic equipment
already applies (since 13 December 2024)
Product information in online sales to consumers (GPSR)
Manufacturer and contact details, product identification, warnings and safety information in the online offer (Art. 19 GPSR).
In ProofPass: Instructions and safety information as a document type
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 13 December 2024)
Responsible economic operator in the EU (GPSR)
A product may only be placed on the market if an economic operator established in the Union is responsible for it; the details are indicated on the product or on its packaging, the parcel or an accompanying document (Art. 16(3) GPSR).
In ProofPass: Manufacturer details on the product and in the online offer
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)Regulation (EU) 2019/1020 (market surveillance)
already applies (since 13 December 2024)
Risk analysis and technical documentation (GPSR)
Internal risk analysis and technical documentation per product, kept for ten years after the product has been placed on the market (Art. 9(2) and (3) GPSR).
In ProofPass: Document types instructions, certificate and declaration of conformity, with version archive
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 13 December 2024)
Report accidents, deliver recalls (GPSR)
Accidents are notified to the authority through the Safety Business Gateway (Art. 20). In a recall you notify the affected consumers directly; where not all of them can be contacted, you disseminate a clear and visible recall notice through other appropriate channels (Art. 35 and 36).
In ProofPass: Recipient list with proof of delivery for safety information
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 11 September 2026)
Cyber Resilience Act: manufacturer reporting duty
Actively exploited vulnerabilities and severe incidents are notified to the CSIRT and ENISA via the single reporting platform: early warning within 24 hours, notification within 72 hours (Art. 14, Art. 71(2) of Regulation (EU) 2024/2847). Also applies to products already on the market (Art. 69(3)).
Regulation (EU) 2024/2847 (Cyber Resilience Act)European Commission: Cyber Resilience Act guidance, C(2026) 5252European Commission: Cyber Resilience Act reporting
adopted, applies from 18 February 2027
Batteries: removability and replaceability
Anyone placing products with incorporated portable batteries on the market ensures that end-users can readily remove and replace them. For LMT batteries this applies to independent professionals (Art. 11(1) and (5), Art. 96(2)). Commission Delegated Regulation (EU) 2026/1770 extended the derogations in paragraph 2.
Regulation (EU) 2023/1542, consolidated text of 13 August 2026Delegated Regulation (EU) 2026/1770 (derogations under Art. 11 of the Battery Regulation)
adopted, applies from 11 December 2027
Cyber Resilience Act: documents and conformity
For products with digital elements: technical documentation (Art. 31, Annex VII), EU declaration of conformity (Art. 28), information and instructions to the user (Annex II), end of the support period. Kept for at least ten years or for the support period, whichever is longer (Art. 13(13)).
In ProofPass: Declaration of conformity and instructions as a document type, versions, fixed address
Regulation (EU) 2024/2847 (Cyber Resilience Act)European Commission: Cyber Resilience Act guidance, C(2026) 5252
expected, not yet adopted: Date open
Repairability and recycled content for electronics (ESPR)
Horizontal requirements in the ecodesign working plan; product passport depending on the act.
Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030
Machinery and power toolsDrills, saws, cordless screwdrivers
already applies (since 13 December 2024)
Product information in online sales to consumers (GPSR)
Manufacturer and contact details, product identification, warnings and safety information in the online offer (Art. 19 GPSR).
In ProofPass: Instructions and safety information as a document type
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 13 December 2024)
Responsible economic operator in the EU (GPSR)
A product may only be placed on the market if an economic operator established in the Union is responsible for it; the details are indicated on the product or on its packaging, the parcel or an accompanying document (Art. 16(3) GPSR).
In ProofPass: Manufacturer details on the product and in the online offer
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)Regulation (EU) 2019/1020 (market surveillance)
already applies (since 13 December 2024)
Risk analysis and technical documentation (GPSR)
Internal risk analysis and technical documentation per product, kept for ten years after the product has been placed on the market (Art. 9(2) and (3) GPSR).
In ProofPass: Document types instructions, certificate and declaration of conformity, with version archive
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 13 December 2024)
Report accidents, deliver recalls (GPSR)
Accidents are notified to the authority through the Safety Business Gateway (Art. 20). In a recall you notify the affected consumers directly; where not all of them can be contacted, you disseminate a clear and visible recall notice through other appropriate channels (Art. 35 and 36).
In ProofPass: Recipient list with proof of delivery for safety information
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 11 September 2026)
Cyber Resilience Act: manufacturer reporting duty
Actively exploited vulnerabilities and severe incidents are notified to the CSIRT and ENISA via the single reporting platform: early warning within 24 hours, notification within 72 hours (Art. 14, Art. 71(2) of Regulation (EU) 2024/2847). Also applies to products already on the market (Art. 69(3)).
Regulation (EU) 2024/2847 (Cyber Resilience Act)European Commission: Cyber Resilience Act guidance, C(2026) 5252European Commission: Cyber Resilience Act reporting
adopted, applies from 20 January 2027
Machinery Regulation: digital instructions
Regulation (EU) 2023/1230 applies from 20 January 2027. The instructions for use may be digital, downloadable and accessible online during the expected lifetime of the machinery and for at least ten years after it is placed on the market. Paper is available on request at the time of purchase, within one month and free of charge. For non-professional users the essential safety information stays on paper (Art. 10(7)).
In ProofPass: Instructions as a document type, QR code, form for the paper request
Regulation (EU) 2023/1230, consolidated text of 27 July 2026
adopted, applies from 20 January 2027
Machinery: include or link the EU declaration of conformity
The declaration accompanies the machinery, or the instructions give the internet address or machine-readable code. In digital form it stays online for the expected lifetime, at least ten years (Art. 10(8)).
In ProofPass: Declaration of conformity as a document type, fixed address, QR code
Regulation (EU) 2023/1230, consolidated text of 27 July 2026
adopted, applies from 20 January 2027
Partly completed machinery: assembly instructions and declaration of incorporation
Assembly instructions may also be digital, with paper on request at the time of purchase within one month (Art. 11(7)). The EU declaration of incorporation accompanies the product or is accessible through an address or code in the instructions (Art. 11(8)). Both stay online for at least ten years.
In ProofPass: Instructions and declaration as a document type, fixed address
Regulation (EU) 2023/1230, consolidated text of 27 July 2026
adopted, applies from 18 February 2027
Batteries: removability and replaceability
Anyone placing products with incorporated portable batteries on the market ensures that end-users can readily remove and replace them. For LMT batteries this applies to independent professionals (Art. 11(1) and (5), Art. 96(2)). Commission Delegated Regulation (EU) 2026/1770 extended the derogations in paragraph 2.
Regulation (EU) 2023/1542, consolidated text of 13 August 2026Delegated Regulation (EU) 2026/1770 (derogations under Art. 11 of the Battery Regulation)
adopted, applies from 11 December 2027
Cyber Resilience Act: documents and conformity
For products with digital elements: technical documentation (Art. 31, Annex VII), EU declaration of conformity (Art. 28), information and instructions to the user (Annex II), end of the support period. Kept for at least ten years or for the support period, whichever is longer (Art. 13(13)).
In ProofPass: Declaration of conformity and instructions as a document type, versions, fixed address
Regulation (EU) 2024/2847 (Cyber Resilience Act)European Commission: Cyber Resilience Act guidance, C(2026) 5252
expected, not yet adopted: Date open
Repairability and recycled content for electronics (ESPR)
Horizontal requirements in the ecodesign working plan; product passport depending on the act.
Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030
Radio equipmentDevices with radio such as Wi-Fi, Bluetooth or radio remote control
already applies (since 13 December 2024)
Product information in online sales to consumers (GPSR)
Manufacturer and contact details, product identification, warnings and safety information in the online offer (Art. 19 GPSR).
In ProofPass: Instructions and safety information as a document type
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 13 December 2024)
Responsible economic operator in the EU (GPSR)
A product may only be placed on the market if an economic operator established in the Union is responsible for it; the details are indicated on the product or on its packaging, the parcel or an accompanying document (Art. 16(3) GPSR).
In ProofPass: Manufacturer details on the product and in the online offer
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)Regulation (EU) 2019/1020 (market surveillance)
already applies (since 13 December 2024)
Risk analysis and technical documentation (GPSR)
Internal risk analysis and technical documentation per product, kept for ten years after the product has been placed on the market (Art. 9(2) and (3) GPSR).
In ProofPass: Document types instructions, certificate and declaration of conformity, with version archive
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 13 December 2024)
Report accidents, deliver recalls (GPSR)
Accidents are notified to the authority through the Safety Business Gateway (Art. 20). In a recall you notify the affected consumers directly; where not all of them can be contacted, you disseminate a clear and visible recall notice through other appropriate channels (Art. 35 and 36).
In ProofPass: Recipient list with proof of delivery for safety information
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 11 September 2026)
Cyber Resilience Act: manufacturer reporting duty
Actively exploited vulnerabilities and severe incidents are notified to the CSIRT and ENISA via the single reporting platform: early warning within 24 hours, notification within 72 hours (Art. 14, Art. 71(2) of Regulation (EU) 2024/2847). Also applies to products already on the market (Art. 69(3)).
Regulation (EU) 2024/2847 (Cyber Resilience Act)European Commission: Cyber Resilience Act guidance, C(2026) 5252European Commission: Cyber Resilience Act reporting
adopted, applies from 11 December 2027
Cyber Resilience Act: documents and conformity
For products with digital elements: technical documentation (Art. 31, Annex VII), EU declaration of conformity (Art. 28), information and instructions to the user (Annex II), end of the support period. Kept for at least ten years or for the support period, whichever is longer (Art. 13(13)).
In ProofPass: Declaration of conformity and instructions as a document type, versions, fixed address
Regulation (EU) 2024/2847 (Cyber Resilience Act)European Commission: Cyber Resilience Act guidance, C(2026) 5252
already applies (since already in force)
Radio equipment: simplified declaration of conformity with a link
The simplified EU declaration of conformity contains the internet address of the full declaration (Directive 2014/53/EU).
In ProofPass: Declaration of conformity as a document type, fixed address
expected, not yet adopted: Date open
Repairability and recycled content for electronics (ESPR)
Horizontal requirements in the ecodesign working plan; product passport depending on the act.
Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030
Toys
already applies (since 13 December 2024)
Product information in online sales to consumers (GPSR)
Manufacturer and contact details, product identification, warnings and safety information in the online offer (Art. 19 GPSR).
In ProofPass: Instructions and safety information as a document type
Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
adopted, applies from 1 August 2030
Product passport for toys
The new Toy Safety Regulation (EU) 2025/2509 applies from 1 August 2030 and provides for a product passport; details will follow.
Packaging and packaged goodsPackaging materials, fillers, own brand on the packaging
already applies (since 12 August 2026)
Packaging: EU declaration of conformity and technical documentation
The manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging.
In ProofPass: Declaration of conformity as a document type, versions, fixed address, QR code
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
already applies (since 12 August 2026)
Packaging: PFAS limits and heavy metals
Food-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation.
In ProofPass: Test reports as a document type
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026)
adopted, applies from 1 January 2030
Packaging: minimisation, recycled content, recyclability, formats (earliest date)
Minimisation by 1 January 2030 (Art. 10), format restrictions from 1 January 2030 (Art. 25). Recycled content, empty space and recyclability from 1 January 2030 or later, depending on the implementing or delegated act (Art. 6, 7, 24).
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR FAQ (August 2026)
adopted, applies from 24 months after the implementing acts, by calculation after 3 November 2028
Packaging: harmonised material label
From 12 August 2028 or 24 months from the entry into force of the implementing acts, whichever is the latest (Art. 12(1)). The acts were due by 12 August 2026; as at 3 November 2026 we did not find them in the EUR-Lex database. By calculation the duty therefore starts only after 3 November 2028.
Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084
All duties at a glance
| Duty | From | Status | Product groups | Source |
|---|---|---|---|---|
| Battery label with general informationArt. 13(1) to (3) apply from 18 August 2026 or 18 months after the entry into force of the implementing act, whichever is the latest. As at 2 November 2026 we did not find this act in the EUR-Lex database. | 18 months after the implementing act, at the earliest 18 August 2026 | expected, not yet adopted | Batteries and rechargeable batteries | Regulation (EU) 2023/1542, consolidated text of 13 August 2026 |
| Supply the safety data sheetSafety data sheet for hazardous substances and mixtures, free of charge, in an official language of the Member State where the product is placed on the market, unless the Member State concerned provides otherwise, no later than the date of first supply (Art. 31 REACH). | 1 June 2007 | already applies | Chemical products (substances, mixtures), Construction chemicals and sealants, Detergents and cleaning products | Regulation (EC) No 1907/2006 (REACH) |
| New safety data sheet version to recipients of the last 12 monthsWithout delay as soon as new information on hazards becomes available, once an authorisation has been granted or refused, or once a restriction has been imposed (Art. 31(9) REACH). | 1 June 2007 | already applies | Chemical products (substances, mixtures), Construction chemicals and sealants, Detergents and cleaning products | Regulation (EC) No 1907/2006 (REACH) |
| 10-year retentionAll REACH information, including superseded safety data sheet versions, for at least 10 years after the last manufacture, import, supply or use (Art. 36 REACH). | 1 June 2007 | already applies | Chemical products (substances, mixtures), Construction chemicals and sealants, Detergents and cleaning products | Regulation (EC) No 1907/2006 (REACH) |
| Candidate List substances in articles: information to recipientsAnyone supplying an article containing a Candidate List substance above 0,1 % weight by weight provides the recipient with sufficient information to allow safe use, as a minimum the name of the substance; to consumers on request, free of charge, within 45 days (Art. 33(1) and (2) REACH). | 1 June 2007 | already applies | Regulation (EC) No 1907/2006 (REACH) | |
| Textile labelling: fibre composition on the labelTextile products are labelled or marked with their fibre composition whenever they are made available, durably, easily legible, visible and accessible (Art. 14(1)); the information is visible before the purchase, also when buying by electronic means (Art. 16(1) of Regulation (EU) No 1007/2011). A label duty, not a product passport. | 8 May 2012 | already applies | Regulation (EU) No 1007/2011 (textile fibre names and labelling) | |
| RoHS: restriction of substances in electrical and electronic equipmentElectrical and electronic equipment, including cables and spare parts, contains the substances in Annex II only up to the maximum concentration values in homogeneous materials set out there (Art. 4). Manufacturers draw up technical documentation and an EU declaration of conformity, affix the CE marking and keep both for 10 years (Art. 7). The Directive applies through national law, to be transposed by 2 January 2013 (Art. 25). | 2 January 2013 | already applies | Directive 2011/65/EU (RoHS) | |
| WEEE: registration and collection symbol for electrical equipmentProducers are registered in the register of every Member State they supply, also in distance selling (Art. 16(1)). Electrical and electronic equipment is marked with the crossed-out wheeled bin symbol shown in Annex IX (Art. 14(4)). The Directive applies through national law, to be transposed by 14 February 2014 (Art. 24). | 14 February 2014 | already applies | Directive 2012/19/EU (waste electrical and electronic equipment, WEEE) | |
| Energy label and entry in the product databaseFor product groups covered by a delegated act, the supplier provides each unit free of charge with a printed label and a product information sheet (Art. 3(1)) and, since 1 January 2019, enters new models into the product database before placing them on the market (Art. 4(1) of Regulation (EU) 2017/1369). | 1 August 2017 | already applies | Regulation (EU) 2017/1369 (energy labelling) | |
| Notify articles with Candidate List substances to ECHA (SCIP)Suppliers of articles provide the information under Art. 33(1) REACH to the European Chemicals Agency. The duty follows from the national law transposing the Waste Framework Directive (Art. 9(1)(i) and (2) of Directive 2008/98/EC). | 5 January 2021 | already applies | Directive 2008/98/EC (Waste Framework Directive), consolidated text of 16 October 2025Regulation (EC) No 1907/2006 (REACH) | |
| Tyre label and product information sheetSuppliers accompany C1, C2 and C3 tyres with a tyre label under Annex II and a product information sheet (Art. 4(1)); in distance selling the label is displayed close to the price (para. 2). Before placing on the market they enter the tyre type into the product database (Art. 5(1) of Regulation (EU) 2020/740). | 1 May 2021 | already applies | Regulation (EU) 2020/740 (labelling of tyres) | |
| Safety data sheet format under Regulation (EU) 2020/878All safety data sheets in the new format of Annex II, including UFI, nanoforms and endocrine disrupting properties. | 1 January 2023 | already applies | Chemical products (substances, mixtures), Construction chemicals and sealants | Regulation (EU) 2020/878 (Annex II to REACH, format of the safety data sheet) |
| Product information in online sales to consumers (GPSR)Manufacturer and contact details, product identification, warnings and safety information in the online offer (Art. 19 GPSR). | 13 December 2024 | already applies | Detergents and cleaning products, Textiles, clothing, footwear, Furniture and mattresses, Electrical and electronic equipment, Machinery and power tools, Radio equipment, Toys | Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR) |
| Responsible economic operator in the EU (GPSR)A product may only be placed on the market if an economic operator established in the Union is responsible for it; the details are indicated on the product or on its packaging, the parcel or an accompanying document (Art. 16(3) GPSR). | 13 December 2024 | already applies | Detergents and cleaning products, Electrical and electronic equipment, Machinery and power tools, Radio equipment | Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR)Regulation (EU) 2019/1020 (market surveillance) |
| Risk analysis and technical documentation (GPSR)Internal risk analysis and technical documentation per product, kept for ten years after the product has been placed on the market (Art. 9(2) and (3) GPSR). | 13 December 2024 | already applies | Detergents and cleaning products, Electrical and electronic equipment, Machinery and power tools, Radio equipment | Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR) |
| Report accidents, deliver recalls (GPSR)Accidents are notified to the authority through the Safety Business Gateway (Art. 20). In a recall you notify the affected consumers directly; where not all of them can be contacted, you disseminate a clear and visible recall notice through other appropriate channels (Art. 35 and 36). | 13 December 2024 | already applies | Detergents and cleaning products, Electrical and electronic equipment, Machinery and power tools, Radio equipment | Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR) |
| UFI on the label and notification to poison centresHazardous mixtures carry the 16-character UFI on the label; the submission to the appointed bodies (poison centres) follows Annex VIII to CLP. The transitional period ended on 1 January 2025. | 1 January 2025 | already applies | Chemical products (substances, mixtures), Construction chemicals and sealants, Detergents and cleaning products | Regulation (EC) No 1272/2008 (CLP) |
| Separate collection symbol on batteriesAll batteries are marked with the separate collection symbol shown in Part B of Annex VI (Art. 13(4)), with Cd or Pb beneath it above the thresholds in Art. 13(5). | 18 August 2025 | already applies | Batteries and rechargeable batteries | Regulation (EU) 2023/1542, consolidated text of 13 August 2026 |
| Carbon border adjustment (CBAM): authorised declarant and annual declarationGoods listed in Annex I, such as iron and steel, aluminium, cement and fertilisers, may only be imported by an authorised CBAM declarant (Art. 4). The declarant submits a CBAM declaration with the embedded emissions each year by 30 September, for the first time in 2027 for 2026 (Art. 6). Exempt is whoever imports no more than 50 tonnes net mass in a calendar year (Art. 2a, Annex VII). As amended by Regulation (EU) 2025/2083. | 1 January 2026 | already applies | Regulation (EU) 2023/956 (carbon border adjustment mechanism, CBAM), consolidated text of 20 October 2025 | |
| Declaration of performance and conformity (new Construction Products Regulation)Regulation (EU) 2024/3110 applies; the switch comes per product family, one year after the adoption of the implementing act on the new specification, or later (Art. 95(9)); supply by electronic means is the rule (Art. 16(1)). | 8 January 2026 | already applies | Construction chemicals and sealants, Construction products without hazardous substances | Regulation (EU) 2024/3110 (Construction Products Regulation)European Commission: Construction Products Regulation, 2024 revision |
| Digital CLP label (voluntary)In addition to the physical label, the label elements may be provided in digital form, through a data carrier on the label or next to it (Art. 31(1b), Art. 34a(1) CLP). Digital only is allowed solely for supplemental information under Art. 25(3) (Art. 34a(2), Annex I, section 1.6). The digital label is searchable, free of charge, without registration, app or password, accessible for at least 10 years, reachable with no more than two clicks and without tracking beyond what is necessary (Art. 34b). | 1 July 2026 | already applies | Regulation (EC) No 1272/2008 (CLP)Regulation (EU) 2024/2865 (amending the CLP Regulation)Regulation (EU) 2025/2439 (“stop the clock” for CLP) | |
| Ban on destroying unsold clothing and footwear (ESPR)Unsold consumer products listed in Annex VII (apparel, clothing accessories, footwear) must not be destroyed. This does not apply to micro and small enterprises; for medium-sized enterprises from 19 July 2030 (Art. 25(1) ESPR). | 19 July 2026 | already applies | Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR) | |
| Packaging: EU declaration of conformity and technical documentationThe manufacturer carries out the conformity assessment and draws up the declaration under Annex VIII for each packaging type (Art. 15, 38, 39, Annex VII of Regulation (EU) 2025/40). It covers the requirements that already apply. Kept for five years, ten for reusable packaging. | 12 August 2026 | already applies | Chemical products (substances, mixtures), Construction chemicals and sealants, Construction products without hazardous substances, Detergents and cleaning products, Batteries and rechargeable batteries, Textiles, clothing, footwear, Furniture and mattresses, Electrical and electronic equipment, Machinery and power tools, Radio equipment, Toys, Packaging and packaged goods | Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026) |
| Packaging: PFAS limits and heavy metalsFood-contact packaging below the PFAS limit values in Art. 5(5) (25 ppb, 250 ppb, 50 ppm). All packaging: no more than 100 mg/kg of lead, cadmium, mercury and hexavalent chromium in total (Art. 5(4)). Evidence in the technical documentation. | 12 August 2026 | already applies | Chemical products (substances, mixtures), Construction chemicals and sealants, Construction products without hazardous substances, Detergents and cleaning products, Batteries and rechargeable batteries, Textiles, clothing, footwear, Furniture and mattresses, Electrical and electronic equipment, Machinery and power tools, Radio equipment, Toys, Packaging and packaged goods | Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084European Commission: PPWR FAQ (August 2026) |
| Cyber Resilience Act: manufacturer reporting dutyActively exploited vulnerabilities and severe incidents are notified to the CSIRT and ENISA via the single reporting platform: early warning within 24 hours, notification within 72 hours (Art. 14, Art. 71(2) of Regulation (EU) 2024/2847). Also applies to products already on the market (Art. 69(3)). | 11 September 2026 | already applies | Electrical and electronic equipment, Machinery and power tools, Radio equipment | Regulation (EU) 2024/2847 (Cyber Resilience Act)European Commission: Cyber Resilience Act guidance, C(2026) 5252European Commission: Cyber Resilience Act reporting |
| Euro 7: environmental vehicle passport for every vehicleThe manufacturer issues an environmental vehicle passport for each vehicle, a digital record of its environmental performance at registration, and provides it with the vehicle; displayed in the vehicle or through a QR code (Art. 3, point 68, Art. 7(4) of Regulation (EU) 2024/1257). From 29 November 2026 for new types of categories M1 and N1, from 29 November 2027 for new vehicles of those categories; for M2, M3, N2, N3, O3 and O4 from 29 May 2028 for new types and from 29 May 2029 for new vehicles (Art. 21). | 29 November 2026 | adopted | Regulation (EU) 2024/1257 (Euro 7) | |
| Deforestation Regulation: due diligence statement before placing on the marketRelevant commodities and products listed in Annex I may only be placed on the market if deforestation-free, produced in accordance with the legislation of the country of production and covered by a due diligence statement (Art. 3). The statement goes to the authorities through the information system before placing on the market (Art. 4(2)), its reference number to downstream operators and traders (Art. 4(7)). For micro and small undertakings established by 31 December 2024 from 30 June 2027, except for products covered by the Annex to Regulation (EU) No 995/2010 (Art. 38(3)). As amended by Regulation (EU) 2025/2650. | 30 December 2026 | adopted | Regulation (EU) 2023/1115 (Deforestation Regulation), consolidated text of 18 September 2026 | |
| Machinery Regulation: digital instructionsRegulation (EU) 2023/1230 applies from 20 January 2027. The instructions for use may be digital, downloadable and accessible online during the expected lifetime of the machinery and for at least ten years after it is placed on the market. Paper is available on request at the time of purchase, within one month and free of charge. For non-professional users the essential safety information stays on paper (Art. 10(7)). | 20 January 2027 | adopted | Machinery and power tools | Regulation (EU) 2023/1230, consolidated text of 27 July 2026 |
| Machinery: include or link the EU declaration of conformityThe declaration accompanies the machinery, or the instructions give the internet address or machine-readable code. In digital form it stays online for the expected lifetime, at least ten years (Art. 10(8)). | 20 January 2027 | adopted | Machinery and power tools | Regulation (EU) 2023/1230, consolidated text of 27 July 2026 |
| Partly completed machinery: assembly instructions and declaration of incorporationAssembly instructions may also be digital, with paper on request at the time of purchase within one month (Art. 11(7)). The EU declaration of incorporation accompanies the product or is accessible through an address or code in the instructions (Art. 11(8)). Both stay online for at least ten years. | 20 January 2027 | adopted | Machinery and power tools | Regulation (EU) 2023/1230, consolidated text of 27 July 2026 |
| Battery passport (LMT, industrial over 2 kWh, electric vehicle batteries)Electronic battery passport under Art. 77(1) of the Battery Regulation. The date is in the consolidated text of 13 August 2026; a pending amendment procedure (COM(2025) 981) does not change it in the Commission proposal. | 18 February 2027 | adopted | Batteries and rechargeable batteries | Regulation (EU) 2023/1542, consolidated text of 13 August 2026Proposal COM(2025) 981 amending the Battery Regulation |
| QR code on all batteriesQR code under Art. 13(6): it gives access to the battery passport or, for other batteries, to the labelling information, the declaration of conformity, the due diligence report and the information on waste batteries. Visible, legible and indelible on the battery, otherwise on the packaging and the accompanying documents (Art. 13(7)). | 18 February 2027 | adopted | Batteries and rechargeable batteries | Regulation (EU) 2023/1542, consolidated text of 13 August 2026 |
| Batteries: removability and replaceabilityAnyone placing products with incorporated portable batteries on the market ensures that end-users can readily remove and replace them. For LMT batteries this applies to independent professionals (Art. 11(1) and (5), Art. 96(2)). Commission Delegated Regulation (EU) 2026/1770 extended the derogations in paragraph 2. | 18 February 2027 | adopted | Batteries and rechargeable batteries, Electrical and electronic equipment, Machinery and power tools | Regulation (EU) 2023/1542, consolidated text of 13 August 2026Delegated Regulation (EU) 2026/1770 (derogations under Art. 11 of the Battery Regulation) |
| Cyber Resilience Act: documents and conformityFor products with digital elements: technical documentation (Art. 31, Annex VII), EU declaration of conformity (Art. 28), information and instructions to the user (Annex II), end of the support period. Kept for at least ten years or for the support period, whichever is longer (Art. 13(13)). | 11 December 2027 | adopted | Electrical and electronic equipment, Machinery and power tools, Radio equipment | Regulation (EU) 2024/2847 (Cyber Resilience Act)European Commission: Cyber Resilience Act guidance, C(2026) 5252 |
| Ban on products made with forced labourEconomic operators must not place or make available on the market, or export, products made with forced labour (Art. 3 of Regulation (EU) 2024/3015). The Regulation applies from 14 December 2027, certain articles from 13 December 2024 (Art. 39). | 14 December 2027 | adopted | Regulation (EU) 2024/3015 (prohibition of products made with forced labour) | |
| New CLP label rules (format, online offers)Minimum font sizes and formatting (Art. 31(3), section 1.2.1 of Annex I to CLP), new time limits for updating labels (Art. 30), advertisements (Art. 48) and information in distance sales offers (Art. 48a); postponed by the “stop the clock” Regulation (EU) 2025/2439, voluntary application possible until 31 December 2027. Goods labelled under the previous formatting rules and placed on the market before 1 January 2027 are not required to be relabelled until 1 January 2029 (Art. 61(8)). Parliament approved a further postponement on 22 October 2026 (Omnibus VI); the Council and the Official Journal are outstanding, so the date still stands. The voluntary digital label has been possible since 1 July 2026. | 1 January 2028 | adopted | Chemical products (substances, mixtures), Construction chemicals and sealants, Detergents and cleaning products | Regulation (EU) 2024/2865 (amending the CLP Regulation)Regulation (EU) 2025/2439 (“stop the clock” for CLP)European Parliament: procedure 2025/0531(COD), Omnibus VI |
| Product passport for detergentsNew Detergents Regulation (EU) 2026/405 with a product passport; a digital label is possible, safety-critical information stays on the label. | 23 September 2029 | adopted | Detergents and cleaning products | Regulation (EU) 2026/405 (detergents and surfactants) |
| Packaging: minimisation, recycled content, recyclability, formats (earliest date)Minimisation by 1 January 2030 (Art. 10), format restrictions from 1 January 2030 (Art. 25). Recycled content, empty space and recyclability from 1 January 2030 or later, depending on the implementing or delegated act (Art. 6, 7, 24). | 1 January 2030 | adopted | Packaging and packaged goods | Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR FAQ (August 2026) |
| Product passport for toysThe new Toy Safety Regulation (EU) 2025/2509 applies from 1 August 2030 and provides for a product passport; details will follow. | 1 August 2030 | adopted | Toys | Regulation (EU) 2025/2509 (safety of toys) |
| Digital Circularity Vehicle PassportFrom 1 September 2032 each vehicle of categories M1 and N1 placed on the market has a Digital Circularity Vehicle Passport with the information on removal and replacement of parts under Art. 11, parts containing lead, mercury, cadmium or hexavalent chromium, the declaration on recycled content and the official catalogue of spare parts; special purpose vehicles are exempt (Art. 13, Art. 2(5)(i) of Regulation (EU) 2026/1738). | 1 September 2032 | adopted | Regulation (EU) 2026/1738 (end-of-life vehicles, circularity passport) | |
| Packaging: harmonised material labelFrom 12 August 2028 or 24 months from the entry into force of the implementing acts, whichever is the latest (Art. 12(1)). The acts were due by 12 August 2026; as at 3 November 2026 we did not find them in the EUR-Lex database. By calculation the duty therefore starts only after 3 November 2028. | 24 months after the implementing acts, by calculation after 3 November 2028 | adopted | Packaging and packaged goods | Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation, PPWR)European Commission: PPWR guidance document, C/2026/3084 |
| Radio equipment: simplified declaration of conformity with a linkThe simplified EU declaration of conformity contains the internet address of the full declaration (Directive 2014/53/EU). | already in force | already applies | Radio equipment | Directive 2014/53/EU (Radio Equipment Directive, RED) |
| Product passport for construction productsThrough a delegated act under the Construction Products Regulation (Art. 75(1)); the duty applies 18 months after it (Art. 22(7), Art. 80(1)). | Date open | expected, not yet adopted | Construction chemicals and sealants, Construction products without hazardous substances | Regulation (EU) 2024/3110 (Construction Products Regulation)European Commission: Construction Products Regulation, 2024 revision |
| Repairability and recycled content for electronics (ESPR)Horizontal requirements in the ecodesign working plan; product passport depending on the act. | Date open | expected, not yet adopted | Electrical and electronic equipment, Machinery and power tools, Radio equipment | Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030 |
| Product passport for iron and steel (ESPR)First product group of the ecodesign working plan; the duty usually applies 18 months after the act. | Act expected at the end of 2026 | expected, not yet adopted | Iron, steel and aluminium | Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: digital product passport for iron and steel |
| Product passport for aluminium (ESPR)Priority in the ecodesign working plan 2025–2030. | Act likely in 2027 | expected, not yet adopted | Iron, steel and aluminium | Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030 |
| Product passport for textiles (ESPR)Priority in the ecodesign working plan; plus the ban on destroying unsold clothing and footwear (large enterprises since 19 July 2026, medium-sized enterprises from 19 July 2030). | Act likely in 2027 | expected, not yet adopted | Textiles, clothing, footwear | Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030 |
| Product passport for tyres (ESPR)Priority in the ecodesign working plan 2025–2030. | Act likely in 2027 | expected, not yet adopted | Tyres | Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030 |
| Product passport for furniture (ESPR)Priority in the ecodesign working plan 2025–2030. | Act likely in 2028 | expected, not yet adopted | Furniture and mattresses | Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030 |
| Product passport for mattresses (ESPR)Priority in the ecodesign working plan 2025–2030. | Act likely in 2029 | expected, not yet adopted | Furniture and mattresses | Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR)European Commission: ecodesign working plan 2025–2030 |
This overview may be used freely with the credit “ProofPass deadline tracker” and a link (CC BY 4.0).
Frequently asked questions
- When does the digital product passport apply?
- There is no single date. Batteries need the passport from 18 February 2027, detergents under the new Detergents Regulation from 23 September 2029. For iron and steel the first act under the Ecodesign Regulation is expected at the end of 2026; after that a transition period of 18 months usually applies.
- Since when has the new Construction Products Regulation applied?
- Regulation (EU) 2024/3110 has applied since 8 January 2026. The switch to the declaration of performance and conformity comes per product family.
- When do the new CLP label rules apply?
- After the postponement by Regulation (EU) 2025/2439, the main formatting rules of the amended CLP Regulation apply from 1 January 2028.
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