Which products will need a DPP? (by sector)
The EU Digital Product Passport is not arriving for every product at once. It rolls out category by category, and the sequence is already set in law and in the European Commission's working plan. If you make or import physical goods sold into the EU, the only question that matters right now is where your category sits in the queue and how long you have. This article maps the order, sector by sector, with the dates that are confirmed.
What is a Digital Product Passport?
A Digital Product Passport is a structured digital record of a product's composition, origin, and lifecycle data, accessed through a data carrier such as a QR code on the item. It is introduced under the EU Ecodesign for Sustainable Products Regulation to make product information available to regulators, supply chain partners, and consumers.
The DPP is the access layer for data the regulation already wants brands to hold. The ESPR sets the framework, and delegated acts then specify the rules for each product group in turn. That staggered structure is why scope is best understood by sector rather than as a single switch. For the full mechanics, read what a Digital Product Passport is, and the wider regulation is covered in our guide to the EU ESPR.
Which sector comes first?
Batteries are first. Under the EU Batteries Regulation 2023/1542, from 18 February 2027 every LMT battery, industrial battery above 2kWh, and electric vehicle battery must carry a QR code that links to a battery passport. This is the earliest hard DPP deadline in EU law and it sits ahead of the broader ESPR categories.
The battery passport runs on its own regulation rather than an ESPR delegated act, which is why it lands first and with a fixed date. It requires carbon footprint data, recycled content, material composition, and supply chain information tied to each battery. Manufacturers and importers placing these batteries on the EU market carry the obligation. For the detail on what the passport must hold, see EU battery passport requirements.
What comes after batteries?
Textiles and furniture are next. The European Commission's first ESPR Working Plan, adopted in April 2025, names the priority product groups for 2025 to 2030. Textiles with a focus on apparel and furniture are scheduled for 2027, with delegated acts setting the exact DPP rules and dates for each group.
Textiles is the category most often treated as the flagship for the ESPR passport. The data set covers fibre composition, recycled content, durability, and supply chain origin. Apparel and footwear brands selling into the EU should treat 2027 as the planning horizon, not the deadline. Brands preparing now can read how the Digital Product Passport applies to fashion. Furniture follows a similar shape, with material sourcing, repairability, and recyclability data attached to each product.
Which industrial sectors are in scope?
Steel, aluminium, and tyres are named priority groups. The 2025-2030 Working Plan lists steel and aluminium alongside textiles and furniture, with tyres scheduled for 2028 and mattresses also in the priority set. These cover both finished consumer goods and the industrial inputs that feed them.
Iron and steel and aluminium passports focus on recycled content, carbon footprint, and material traceability back through the supply chain. Tyres add durability, rolling resistance, and recyclability data. The Commission has said it will adopt up to 18 new delegated acts between 2024 and 2027, and 12 more between 2028 and 2030, so the list of regulated groups grows steadily across the decade rather than closing after the first wave.
What about electronics and other goods?
Electronics sit slightly apart. Ecodesign and repairability rules for smartphones and tablets began applying on 20 June 2025, and consumer electronics are widely expected to gain DPP obligations as the ESPR programme runs. Energy-related products are already named in the Working Plan, and further categories will be added through the 2028 review.
James Williamson, co-founder of Orijin Plus, has gone on record that brands underestimate how fast this sequence moves. As he puts it, his sense is that the runway is much tighter than most teams assume. The categories not yet named are not exempt. They are simply earlier in a queue that the Commission has committed to extending. The practical read is that any brand making durable physical goods should assume a passport is coming and build the data discipline now.
That principle holds across every sector in the queue. A passport is only as useful as the accuracy of the data behind it, and accuracy is built before the deadline, not after.
FAQ
Which product will need a DPP first?
Batteries. From 18 February 2027, LMT batteries, industrial batteries above 2kWh, and electric vehicle batteries placed on the EU market must carry a QR code linking to a battery passport. This obligation comes from the EU Batteries Regulation 2023/1542 and is the earliest fixed DPP deadline in EU law.
Do textiles need a Digital Product Passport?
Yes. Textiles, with a focus on apparel, are a named priority group in the European Commission's ESPR Working Plan and are scheduled for 2027. A delegated act will set the exact data requirements and date. Apparel and footwear brands selling into the EU should plan for it now.
Does the DPP apply to food and beverage?
No. The Digital Product Passport under the ESPR does not currently cover food and beverage. The early focus is non-food categories such as batteries, textiles, furniture, steel, aluminium, and tyres. Food and drink brands face similar traceability expectations through other EU regulations instead.
When do steel and aluminium need a passport?
Steel and aluminium are named priority groups in the 2025-2030 ESPR Working Plan, sitting in the same early wave as textiles and furniture. The exact dates come through delegated acts. The Commission plans up to 18 new delegated acts between 2024 and 2027, so industrial inputs should expect requirements within that window.
Is the DPP a single law for all products?
No. The ESPR is the framework, and each product group is regulated by its own delegated act with its own data set and timeline. Batteries are an exception, governed by the separate EU Batteries Regulation. This is why scope is best understood sector by sector rather than as one switch.
What data does a Digital Product Passport hold?
It varies by sector, but most passports require material composition, recycled content, carbon footprint, durability, repairability, and supply chain origin. The common thread is structured, verifiable data tied to the individual product and reached through a QR code or similar data carrier on the item.
How long do brands have to prepare?
The nearest hard deadline is 18 February 2027 for batteries. Textiles and furniture are scheduled for 2027 and tyres for 2028, with dates confirmed through delegated acts. Brands in any named category have between one and three years, and the queue keeps extending through the 2028 review.
