First live DPP
18 Feb
2027
2027
EV batteries & industrial batteries >2kWh — binding EU-wide. Battery Reg 2023/1542
Products covered
6
New priority product groups in the ESPR 2025–2030 working plan (textiles, furniture, tyres, mattresses, iron & steel, aluminium), plus 16 carried-over energy-related groups. EC press corner, 16 Apr 2025
First non-battery group
Textiles
2027–28
2027–28
ESPR delegated act in preparation. Mandatory digital passport expected from 2027. DG Environment — ESPR
—
days to battery passport
18 Feb 2027
18 Feb 2027
~365
days after that
textiles follow (2027–28)
textiles follow (2027–28)
2030
end-state: majority of
non-food goods covered
non-food goods covered
How big is the passport challenge?
Two product categories lead the DPP rollout. The numbers behind each deadline — sourced from ACEA, SolarPower Europe, Eurostat, and EEA.
Battery Passport · 18 Feb 2027
1.88M
EV batteries registered in EU in 2025. Each one requires a Digital Product Passport from 18 February 2027. Industrial batteries above 2 kWh — including stationary energy storage — fall under the same deadline.
2024
1,447,934
2025
1,880,370
Source: ACEA, January 2026 · EU-27 BEV only
Textile Passport · 2028 Target
29.3B
Garments imported into EU in 2024. Every item of clothing placed on the EU market will require a Digital Product Passport under ESPR. The delegated act for textiles is expected in 2027, compliance from 2028.
€170B
EU sector turnover (2023)
197K
EU textile companies in scope
Also in scope from 18 Feb 2027: 18.5 GWh of battery energy storage systems (BESS) installed across EU-27 in 2024 — industrial batteries above 2 kWh are covered by the same Battery Regulation deadline as EV batteries. Source: SolarPower Europe, May 2025
01 · The rollout timeline
The DPP is not one deadline — it is a staged rollout over six years. Batteries go first. Textiles follow. Steel, aluminium, furniture, tyres and mattresses are in the European Commission's 2025–2030 working plan. Every date below is public.
2024
2025
2026
2027
2028
2029
2030
BatteriesLive · 18 Feb 2027
Textiles & apparelExpected 2027–28
Iron & steel, aluminiumExpected 2028
Furniture, tyresExpected 2028–29
Sources: ESPR Regulation (EU) 2024/1781 · Battery Regulation (EU) 2023/1542 · European Commission — ESPR 2025–2030 working plan (16 April 2025)
18 Jul2024
ESPR enters into force
Regulation (EU) 2024/1781 — the master law creating the Digital Product Passport obligation — was adopted 13 June 2024 and entered into force 18 July 2024.
16 Apr2025
ESPR 2025–2030 working plan adopted
New priority product groups named: textiles & apparel, iron & steel, aluminium, furniture, tyres, mattresses. Detergents, chemicals and footwear are explicitly excluded from this first working plan. 16 energy-related product groups carried over from the old Ecodesign Directive. Each group gets its own delegated act.
18 Feb2027
Battery passport goes live — first mandatory DPP
Every EV battery, LMT battery and industrial battery >2 kWh placed on the EU market must carry a digital passport accessible via QR code. Covers chemistry, carbon footprint, recycled content, supply-chain due diligence and recycling data.
2027–28Expected
Textiles & apparel delegated act applies
First ESPR product group. Delegated act under preparation. DPP becomes mandatory for clothing, footwear and household textiles sold in the EU, including imports. Fibre composition, country of origin per manufacturing stage, recycled content, chemicals of concern, end-of-life instructions.
2028–30Phased
Iron & steel, aluminium, furniture, tyres, mattresses
Delegated acts published progressively. DPP becomes mandatory for each group on the date fixed by its own act. End-state: the majority of non-food physical goods sold in the EU carry a verifiable digital passport.
02 · Who goes first
The first product categories inside the ESPR scope. Batteries are already in force. Textiles, steel, aluminium, furniture, tyres and mattresses are in the first 2025–2030 working plan. Detergents, chemicals and footwear are explicitly excluded from this plan.
Batteries
EV, industrial & LMT batteries
Live 18 Feb 2027
Carbon footprint, recycled content, chemistry, supply-chain due diligence, recycling data. Own regulation (EU) 2023/1542 predates ESPR.
Fashion & apparel
Textiles, clothing, footwear
Expected 2027–28
First ESPR delegated act. Fibre composition, each manufacturing-stage origin, recycled content, durability, repairability, chemicals of concern.
Heavy industry
Iron & steel, aluminium
Expected 2028
Embodied carbon, recycled content, alloy composition. Critical for construction, automotive and packaging supply chains.
Home & living
Furniture
Expected 2028–29
Material composition, origin, repairability, recycled content, end-of-life instructions.
Automotive aftermarket
Tyres
Expected 2028–29
Rubber composition, durability, rolling resistance, recycled content, end-of-life processing route.
Home & living
Mattresses
Expected 2028–29
Material composition, recycled content, durability, repairability, end-of-life instructions. Included in the 2025–2030 working plan alongside furniture.
03 · What every passport must carry
ESPR Article 9–10 sets out the baseline information that every Digital Product Passport must contain, with category-specific extensions in each delegated act. Access is through a QR code or data carrier on the product. The structure is standardised via GS1 Digital Link and W3C Verifiable Credentials.
Unique product ID
GS1 Digital Link URL resolvable by anyone with a scanner.
Manufacturer & supply chain
Named economic operator plus stages of production with their location.
Material composition
Ingredients, substances, chemical declarations. For textiles: fibre breakdown.
Recycled content
Percentage recycled inputs, evidence and certification trail.
Substances of concern
Linked to ECHA SCIP and REACH data.
Durability & repairability
Scores, expected lifetime, spare-parts availability.
Carbon & environmental footprint
Cradle-to-gate greenhouse-gas emissions, water footprint where applicable.
End-of-life instructions
Disassembly, sorting, recycling route, take-back scheme.
04 · Who's already building it
Two large EU-funded pilot programmes shape the textile and battery DPP architectures. Their participant lists are public — and they are effectively the brands with the most DPP-ready infrastructure today.
Cross-sector · EU pilot
CIRPASS-2 (Horizon Europe, 2024–27)
EU Horizon Europe programme running 13 lighthouse pilots across textiles, electronics, tyres and construction. 49 consortium partners including technology providers, research institutes and standardisation bodies. The full partner list is published on the project site.
Automotive · battery passport
Catena-X
Industry consortium building the shared data architecture for the EU battery passport. Founding members and participants include major European automotive and chemical groups — BMW, Mercedes-Benz, Volkswagen, Bosch, BASF, SAP, Siemens.
Fashion retail
H&M Group
Piloted Digital Product Passports on their Men's Essentials collection (2022) with technology partner EON, embedding QR codes for product origin, material composition and circular services. H&M has stated that a broad rollout across all products is not yet committed.
Mass-market retail
Decathlon
100% of Decathlon products carry a GS1 serialised identifier via RAIN RFID since 2019 — the item-level infrastructure required for DPP compliance. The company published a 2024 position paper formally supporting the EU DPP regulation.
Industry
Status
Readiness
AutomotiveCatena-X consortium
Shared battery-passport data architecture live. BMW, Mercedes-Benz, VW, Bosch, BASF, SAP, Siemens co-building. Hard deadline: 18 Feb 2027.
Live
Fashion retailH&M · Decathlon
Building independently. H&M piloted on Men's Essentials (2022). Decathlon has 100% RAIN RFID coverage since 2019. Deadline: 2028.
Piloting
Rest of industryMost brands
Waiting for delegated acts to be finalised before committing to infrastructure investment. Compliance cliff approaches 2028.
Waiting
05 · Where the real gap sits
The Digital Product Passport is not a labelling exercise. It is a supply-chain data architecture. The compliance gap is not between brands with good sustainability marketing and brands with bad marketing — it is between those with tier-2 and tier-3 supplier data and those without.
Tier 1Direct supplier
Factory lists public — H&M, Nike, Inditex, Adidas and others
Commonly disclosed
Tier 2Component
Fabric mills, dye houses, battery cell makers
Patchy
Tier 3+Raw material
Cotton fields, lithium mines, rubber plantations
The compliance cliff
06 · What it costs
Two independent analyst estimates converge on the same range. Marginal cost per product is modest — the real investment is in the data infrastructure behind it.
Per product
Low marginal cost
QR tag, data storage, and API serving add a small per-unit cost. Magnitude depends on product complexity and the depth of verification the buyer demands.
Upstream data infrastructure
Multi-million-euro
The real investment sits in tier-2 / tier-3 traceability systems, supplier onboarding and chain-of-custody architecture. Brands that have not yet mapped their supply chain face the largest capex step.
Non-compliance
Product withdrawal
Under ESPR, products without a valid DPP cannot legally be placed on the EU market. Penalties are set by each member state. Withdrawal is the baseline enforcement action.
07 · Three scenarios for 2030
How the DPP rollout reshapes European supply chains by the end of the decade.
Scenario A · Compliance leadership
Early movers compound an advantage
Brands with tier-2/3 traceability today turn DPP into a marketing and operations advantage — pricing power, lower enforcement risk, faster product iteration. Catena-X and CIRPASS-2 participants disproportionately represented.
Scenario B · Middle-tier scramble
Retailers without tier-2 data outsource compliance
Mid-tier brands lean on shared industry platforms (Catena-X style) to close the data gap. Margin compression for those paying to rent the infrastructure rather than own it.
Scenario C · Withdrawal risk
Pure price-driven brands lose EU market access
Importers relying on opaque tier-3 supply chains cannot produce a valid DPP. Products withdrawn from the EU market or de-listed by large EU retailers. Most acute in textiles and consumer electronics.
08 · Who's already selling the DPP foundation
8 companies are selling DPP infrastructure as a service to fashion brands — from raw fibre traceability to consumer-facing digital passports. Mapped across two axes: where in the value chain (supply chain data vs product identity) and which market segment (luxury vs mass market).
Luxury & Premium · Supply chain data
Fairly Made
Paris · Series A €15M (Apr 2025)
Supply chain traceability, LCA impact measurement, ecodesign scoring and EU DPP compliance in one platform.
LVMH · Versace · Fendi · Karl Lagerfeld · SMCP
Luxury & Premium · Product identity
EON
New York · Series A $13M
Digital product cloud — unique ID per garment, resale enablement, EU DPP compliance.
Chloé · Balenciaga · Coach · Mulberry · H&M
Certilogo eBay
Milan · acquired by eBay 2023 · 570M+ products
NFC label authentication and digital IDs for luxury and streetwear, enabling resale.
Stone Island · Off-White · CP Company · Versace
Temera Beontag
Florence · acquired by Beontag
RFID & NFC item-level digital passports for luxury, from factory floor to consumer.
Tod's · Bulgari · Dolce & Gabbana · Pinko
Mass Market · Supply chain data
Retraced
Düsseldorf · Series A €15M (Sep 2024)
Supplier compliance, audit management and DPP readiness for volume fashion brands.
Tom Tailor · S.Oliver · Victoria's Secret · SKIMS
TextileGenesis Lectra
Paris · acquired by Lectra Dec 2022
Fibre-to-retail token traceability — certified sustainable materials tracked at every supply chain tier.
H&M · Lululemon · Marks & Spencer · Zegna · On
FibreTrace
Singapore
Luminescent pigment tracers embedded in raw fibre — physically scan-verified from farm to recycling facility.
Target · Reformation · Everlane · Napapijri
Mass Market · Product identity
Sourcemap
New York (MIT origin) · Series B $20M
Multi-tier supply chain mapping with auto-discovery of sub-suppliers — forced-labour compliance and DPP data foundation.
← Supply chain data / traceability
Product identity / consumer passport →
Sources: Company websites and press releases · Crunchbase · April 2026. Acquisition status: Certilogo → eBay (Jul 2023) · TextileGenesis → Lectra (Dec 2022) · Temera → Beontag.
About the Author
TrendsOnFire is an AI-based market intelligence platform publishing editorial analysis on retail, technology, supply chain, people and transformation trends across Europe.
Created by Olga Bressers, a senior executive with experience in commercial & digital operations, ecommerce, omni-channel strategy, operations, programs and business transformation.