Digital product passport by industry: which products need one, and from when?

Three routes lead to a passport

The first route is the Ecodesign for Sustainable Products Regulation (EU) 2024/1781, the ESPR. It applies to almost all physical goods, including components and intermediate products (Art. 1(2)). A duty only arises once a delegated act for your product group requires a passport (Art. 4, Art. 9(1)). How the passport works in general is covered in the guide Digital product passport: deadlines and product groups.

The second route is product legislation with its own passport: batteries (Regulation (EU) 2023/1542), detergents (Regulation (EU) 2026/405), toys (Regulation (EU) 2025/2509) and construction products (Regulation (EU) 2024/3110). The third route concerns vehicles: they get a Digital Circularity Vehicle Passport under the end-of-life vehicles Regulation (EU) 2026/1738.

Status by industry on 11 November 2026

“Binding” means the date is in a regulation published in the Official Journal. “Planned” means the regulation provides for a further act whose date is open. “Indicative” means the year comes from the Commission’s working plan and is the provisional year in which the act is to be adopted, not the start of the duty.

The pages by industry

Each page gives the legal basis, the timeline with status, the data already fixed and what you can do today.

• Batteries: the only passport with a fixed date before 2029
• Detergents and cleaning products: passport from 23 September 2029, content in Annex VI
• Toys: passport from 1 August 2030 instead of the declaration of conformity
• Textiles and apparel: act provisionally 2027
• Furniture and mattresses: acts provisionally 2028 and 2029
• Tyres: act provisionally 2027, today the tyre label and the product database
• Iron and steel: first group in the working plan
• Aluminium: act provisionally 2027
• Electrical and electronic equipment: horizontal rules and the battery inside the device
• Automotive and vehicle parts: battery passport, environmental vehicle passport, circularity passport
• Aviation: no passport of its own, but batteries

Construction products take their own route

For construction products the Commission sets up a construction digital product passport system by delegated act (Art. 75(1) Regulation (EU) 2024/3110). The system has to be running six months after that act enters into force; 18 months after it, the manufacturers’ duty applies (Art. 80(1), Art. 22(7)). In between, manufacturers may use it voluntarily. On 11 November 2026 we did not find this act on EUR-Lex.

The content is already in the Regulation: the declaration of performance and conformity, product information, instructions for use and safety information, the technical documentation and the unique identifiers (Art. 76(2)). The system has to remain accessible for 25 years after the last product of a type; the economic operator keeps the passport available for at least ten years (Art. 75(2)(i)). The declaration itself is covered in the guide Declaration of performance under Regulation (EU) 2024/3110.

What every industry has in common

The passports look alike because the Toy Safety Regulation, the Detergents Regulation and the Construction Products Regulation refer to the ESPR. They share these points:

• A data carrier such as a QR code connects the product to a persistent unique product identifier (Art. 10(1) ESPR, Art. 19(2) Regulation 2025/2509, Art. 21(2) Regulation 2026/405).
• Consumers do not have to register or provide a password (Art. 20(4) Regulation 2025/2509, Art. 22 Regulation 2026/405).
• Dealers and providers of online marketplaces receive a digital copy of the data carrier free of charge within five working days (Art. 10(3) ESPR, Art. 19(12) Regulation 2025/2509, Art. 21(12) Regulation 2026/405).
• A back-up copy is kept with a digital product passport service provider.
• The identifiers go into the Commission’s digital product passport registry (Art. 13 ESPR, Implementing Regulation (EU) 2026/1778).

If you manufacture outside the EU

The passport duties attach to placing a product on the EU market, so they apply to imported goods as well. For products covered by an ESPR act, whoever places them under the customs procedure “release for free circulation” gives customs the unique registration identifier from the registry (Art. 15(1) ESPR); the Toy Safety Regulation has the same rule for toys (Art. 23(2)). Agree early with your EU importer who creates the passport and who uploads the identifiers.

What you can do today

• Assign each product to a row of the table. A product can sit in two rows, for example a toy with a rechargeable battery.
• Note the date and the status for each row. Plan firmly only with “binding”.
• Give every product an address that stays, and a QR code that points there.
• Keep declarations of conformity, instructions and safety information per model in one place, with versions.
• Check the status in the deadline tracker before you print labels.

Further reading

• The product passport module: permanent address, QR code and documents per product
• The basics in the guide Digital product passport: deadlines and product groups
• Every date per product group in the deadline tracker

Frequently asked questions