ESPR timeline: which products need passports, and when

2026-06-24 · Updated 2026-08-05 · Onpack

The EU Ecodesign for Sustainable Products Regulation is a framework: it entered into force in July 2024 and creates obligations product group by product group through delegated acts, each with its own dates. Tracking ESPR therefore means tracking a timeline of timelines. Here is the map as it stands, with the official trail at the European Commission.

The timeline, in order

DateEventStatus
July 2024ESPR framework in forceDone
April 2025First working plan adopted: textiles, furniture, mattresses, tyres, iron and steel, aluminiumDone
Feb 18, 2027Battery passports mandatory (separate regulation, 2023/1542)Fixed date
2026 to 2028Delegated acts adopted per category, each defining passport data and datesIn preparation
Roughly 18 months after each actThat category's obligations applyFollows each act

How to read a delegated act's arrival

Each act answers three questions for its category: what data the passport must contain, who may see which fields, and when compliance starts. The lead time between adoption and application, historically around 18 months, is your implementation window, and it is short for data you do not yet collect. That asymmetry drives the standard advice: data gathering starts before your act is final; publication infrastructure, the QR and resolver, is settled far earlier because it is category-independent.

The categories in motion

Batteries are fixed and first. Textiles are the bellwether consumer category. Furniture, mattresses and tyres follow their own drafting tracks, and iron, steel and aluminium bring passports upstream into industrial intermediates, which will pull passport data through supply chains that consumer brands sit atop.

The stable ground under the moving dates

Every version of every act assumes the same physical mechanism: a data carrier on the product resolving to a record, with the industry converging on QR codes carrying GS1 Digital Link. That part does not move, which is why printing the right code at your next artwork cycle, per the checklist, is the rare ESPR action with no regret risk: it is simultaneously your Sunrise 2027 readiness.

Common questions

What is in force today under ESPR?

The framework regulation itself, since July 2024, plus the adopted first working plan (April 2025) naming priority categories. Product obligations arrive per category through delegated acts.

Which categories are in the first working plan?

Textiles and apparel, furniture, mattresses, tyres, and the intermediates iron and steel and aluminium. Batteries run earlier under their own regulation.

When do the first product passports become mandatory?

Batteries: February 18, 2027. ESPR categories: per delegated act, with adoptions expected from around 2026 to 2028 and obligations typically applying 18 months after each act.

What should a brand do while dates are still moving?

Split the work: start gathering product data now, since supply chains are slow, and put a Digital Link QR on packs at the next reprint so the eventual passport is a data update, not a packaging project.

Print a code that stays alive

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