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Digital Product Passport requirements under ESPR are defined progressively through delegated acts, with timelines and scope varying by product group.
This article reflects the current status and is updated as new regulatory developments are released. Last updated: September 2026.
The Ecodesign for Sustainable Products Regulation (ESPR) defines the framework for Digital Product Passports.
But it does not define how they apply to specific products.
Delegated acts define how those requirements apply to specific products, setting the scope, data requirements, and conditions for implementation across sectors.
While ESPR is now in force, most delegated acts are still under development.
This is where the current uncertainty sits, as implementation continues to take shape over time.
This article provides a clear view of their role, current status, and what to expect next.
Delegated acts are the mechanism through which the European Commission defines how a regulation applies to specific products and requirements.
Under ESPR, they establish product-specific requirements, including:
Delegated acts supplement the ESPR by defining the technical and operational requirements needed for its application, without changing the essential elements established by the Regulation.
Delegated acts have been central to ESPR from its early development, but their scope and rollout have evolved over time.
Initial discussions focused on extending ecodesign requirements beyond energy-related products, with limited clarity on how Digital Product Passports would be implemented.
Over time, this developed into a broader framework covering product performance and product information, with the Digital Product Passport positioned as a central mechanism for making that information accessible.
The publication of the ESPR Working Plan 2025–2030 marks a shift from concept to implementation.
It defines priority product groups and confirms that requirements will be introduced progressively through delegated acts, rather than all at once.
Product-specific delegated acts establishing Digital Product Passport requirements under the ESPR are still under development.
The European Commission has published a more detailed indicative timeline for their adoption. The first product-specific delegated act is expected for iron and steel in the fourth quarter of 2026. Delegated acts for textiles, aluminium and tyres are currently expected between the third and fourth quarters of 2027, followed by furniture in 2028 and mattresses and ICT products in 2029.
The ESPR Working Plan 2025–2030 remains the basis for this rollout. It identifies the priority product groups and horizontal measures to be developed, including requirements related to repairability, recyclability and recycled content.
Preparatory studies, impact assessments and stakeholder consultations are underway for the different product groups. Until the relevant delegated act is adopted, the scope, mandatory data points, granularity and access rules for each category should not be treated as final.
Following the adoption of a product-specific delegated act, economic operators will generally have a transition period of at least 18 months before the requirements become applicable. The adoption date of a delegated act therefore does not correspond to the date on which the Digital Product Passport becomes mandatory for that product group.
The Commission has already adopted other delegated and implementing acts under the ESPR. These include the rules supporting the prohibition on the destruction of unsold apparel, clothing accessories and footwear. These measures show that ESPR implementation is underway, but they do not establish product-specific Digital Product Passport requirements.
Delegated acts under ESPR are being introduced progressively, following a phased regulatory timeline.
These dates refer to the expected adoption of the delegated acts. Economic operators will generally have a transition period of at least 18 months before the corresponding requirements become applicable. The timelines remain indicative and depend on the outcome of preparatory studies, impact assessments, stakeholder consultations and the formal regulatory adoption process.
Delegated acts define how ESPR requirements apply in practice at product level.
What changes from one delegated act to another is the level of specificity.
Each product group is defined through a specific set of data points, calculation methods, and conditions that reflect how that product is manufactured, used, and circulated.
This is where differences across sectors become visible.
Requirements for textiles, for example, will not mirror those for electronics or furniture, because the underlying materials, supply chains, and environmental impacts are fundamentally different.
In practice, compliance is no longer defined at a general level, but through product-specific configurations that need to be maintained over time.
Each delegated act includes:
These elements are typically detailed in annexes, where parameters, thresholds, and calculation rules are specified.
This is where requirements become measurable and directly applicable.
Delegated acts related to DPP are not limited to defining requirements for product groups.
They are also used to establish the technical and operational components that enable Digital Product Passports to function. This includes:
These elements are defined through dedicated delegated acts and implementing legislation, and form the infrastructure that enables Digital Product Passports to function across the EU market.
As delegated acts are introduced, compliance shifts to product-level implementation.
Information can no longer be created on request. It needs to exist as structured, product-level data maintained over time.
This affects how companies manage:
Requirements will not apply uniformly.
Each product category will be subject to a specific set of rules, requiring different data, calculations, and verification methods.
Companies should also distinguish between the adoption date of a delegated act and its date of application. The transition period provides time for implementation, but the underlying work on product data, supplier information, internal responsibilities and system integration can begin before the final requirements enter into force.
Beyond ESPR, delegated acts are used across multiple EU regulations with different roles.
Under the Batteries Regulation (EU) 2023/1542, they define requirements on sustainability, performance, labelling, and the battery passport.
Under the Construction Products Regulation, they define harmonised technical specifications and performance requirements.
In sectors such as toys or chemicals, product requirements are defined through other legal instruments, with a more limited use of delegated acts.
The next product-specific milestone is the delegated act for iron and steel, currently expected in the fourth quarter of 2026. This will provide the first practical example of how the ESPR translates its general framework into category-specific requirements.
Further developments to monitor include:
For companies, monitoring adoption dates alone will not be sufficient. Each delegated act will introduce category-specific requirements that affect product data, supplier engagement, internal responsibilities and the systems used to create and maintain Digital Product Passports.
👉 Explore Renoon’s DPP Newstracker to follow the latest delegated acts and understand their operational implications.
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