First live DPP
18 Feb
2027
2027
EV batteries & industrial batteries >2kWh — binding EU-wide. Battery Reg 2023/1542
Products covered
~30
Product categories in the ESPR 2025–2030 working plan. 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
01 · The rollout timeline
The DPP is not one deadline — it is a staged rollout over six years. Batteries go first. Textiles follow. Consumer electronics, steel, aluminium, furniture and tyres 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
Detergents, chemicalsExpected 2029–30
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
First priority product groups named: textiles & apparel, iron & steel, aluminium, furniture, tyres, detergents, chemicals, energy-related products. Each 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, detergents
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 and tyres are in the first 2025–2030 working 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.
FMCG / consumer goods
Detergents, chemicals, energy-related products
Expected 2029–30
Ingredient transparency, substances of concern, biodegradability, energy-use declarations.
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)
Textile, electronics and construction DPP pilots, funded by the EU Horizon Europe programme. Confirmed industry partners include Decathlon on the sporting-goods side. The full consortium 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
FY2025 annual and sustainability report publicly commits to DPP readiness and supplier-level traceability across commercial product.
Mass-market retail
Decathlon
CIRPASS-2 participant on the sporting-goods / textiles pilot track.
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 1 · Direct supplier
Commonly disclosed
Final-stage manufacturer — cut & sew for apparel, final assembly for electronics. Public factory lists are maintained by H&M, Nike, Inditex, Adidas and other major brands.
Tier 2 · Component
Patchy
Fabric mills, dye houses, battery cell makers, component suppliers. Disclosure varies brand by brand and is far less complete than tier-1.
Tier 3+ · Raw material
The real DPP compliance cliff
Cotton fields, lithium mines, steel mills, rubber plantations. Rarely disclosed today. DPP requires traceability for key inputs (recycled content, substances of concern, country of origin).
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.
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.