A delegated act is not a deadline: how to read the 18 month transition

The single most misread mechanism in the digital product passport (DPP) rules is the gap between two dates that get treated as one.

A delegated act is adopted. That is the date in every headline. The obligation binds 18 to 36 months later. That is the date in the law. Companies plan against the first number, feel comfortable, and lose the only preparation window they get.

How the sequence actually runs

The Ecodesign Regulation is a framework. It does not, by itself, require a passport for any specific product. What it does is create the mechanism, and then the Commission adopts a delegated act for each product group setting out what that group's passport must contain.

Each delegated act carries a transitional period before the obligation applies. That period runs from 18 to 36 months depending on the act.

So the timeline for any product group has three points, not one: the act is adopted, the transition runs, the obligation binds. What is scheduled in the ESPR Working Plan 2025-2030 is the first point only.

Why the middle period is the whole game

Here is the arithmetic that catches teams out.

Assume a delegated act for your category is adopted in 2027 with a 24 month transition. The obligation binds in 2029. It feels like two years of preparation time.

It is not, because the preparation work does not start when the act is published. It starts when you know what to collect, and much of it does not depend on the final field list at all. Mapping which suppliers can evidence what takes twelve to eighteen months done properly, as the readiness checklist sets out step by step. If that exercise begins on the day the act is published, it finishes with months to spare and no room for the suppliers who cannot deliver. If it begins a year later, it does not finish.

The transitional period is not a grace period. It is the project.

What follows for your planning

Any settled compliance year you read for a category without an adopted act is a guess. Treat per-category compliance years as planning assumptions, not commitments, and check the adopted acts rather than the working plan when the answer matters. The safe phrasing, and the one we use, is "in phases from 2027".

The dates can move in both directions. A mid-term review is scheduled for 2028 and can add or reschedule categories. A category that looks distant today can be brought closer, and a company that planned to the latest possible date has no margin when that happens.

Waiting for certainty is itself a decision. The work that fills the transition is supplier data, and none of it is wasted whatever the final field list says. Fibre origin, recycled content, substances of concern and facility identification appear in every draft act so far. Collecting them early is not a bet on a specific rule.

Do the arithmetic for your category

Take your category's indicative delegated act date from the working plan. Add 18 months, the shortest transition, not 36. Then subtract the twelve to eighteen months the supplier data exercise takes.

If the result is in the past, you already know what to do next.

If the DPP is on your radar but not yet on your roadmap, now is the time to act.

Sources

• Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation).
• ESPR Working Plan 2025-2030, COM(2025) 187 final, adopted 16 April 2025, including the mid-term
• review scheduled for 2028.