Six product groups are scheduled for a passport, and most companies only know about two

The public conversation about the digital product passport (DPP) has been about two things: clothes and batteries. That is where the press coverage went, and it has left whole industries assuming the rules are aimed at someone else.

The ESPR Working Plan 2025-2030 lists more.

What is scheduled

The working plan, adopted as COM(2025) 187 on 16 April 2025, schedules delegated acts for iron and steel, textiles and apparel, tyres, aluminium, furniture and mattresses. Electronics and ICT are not in the first working plan and are expected later. Construction products now run on their own track: the Construction Products Regulation working plan for 2026 to 2029, published in December 2025, schedules a DPP delegated act for construction materials in Q2 2027. Packaging and chemicals are under study, with overlaps into the packaging regulation and REACH respectively.

Iron and steel are indicatively first, with a delegated act in Q4 2026. Textiles, tyres and aluminium follow indicatively in Q3 to Q4 2027. Furniture is indicatively 2028 and mattresses 2029, as two separate sub-categories.

Every one of those dates is indicative. They come from a working plan, not from a legal text, and each act adds a transitional period of 18 to 36 months before anything binds. Two dates are fixed in law and worth separating out clearly: the EU DPP Registry went live on 20 July 2026, one day after its Article 13 deadline, and the battery passport is mandatory from 18 February 2027 under a different regulation entirely.

Why the list reaches further than the headline categories

Read the six groups as materials rather than as industries and the reach changes.

Tyres pulls in automotive and logistics. Iron, steel and aluminium pull in construction, machinery, appliances, packaging and anything fabricated from metal stock. Furniture and mattresses pull in foam, textiles, adhesives and coatings. Very few manufacturers touch none of these.

The question to ask is not "is my industry on the list". It is "does anything I make, or anything I put inside what I make, fall into one of these groups". The passport obligation reaches the economic operator placing the product on the market, and the data obligation reaches everyone upstream of them through contracts.

The mid-term review

A mid-term review of the working plan is scheduled for 2028. It can add product groups and reschedule existing ones.

For a company currently outside the list, that is the date worth watching, and it is also the reason "we are not in scope" is a position with a review date attached rather than a permanent answer.

What to do with the list

Map your product lines against the six groups and mark the ones that touch two or more, since those carry the earliest effective date. Watch the adopted acts rather than the working plan, because the working plan tells you the order and the acts tell you the requirements. And treat any category without an adopted act as "in phases from 2027" in your own planning documents, which keeps your internal statements accurate when the dates move.

Full per-category detail is in our regulation timeline.

Sources

• ESPR Working Plan 2025-2030, COM(2025) 187 final, adopted 16 April 2025, including the 2028
• mid-term review.
• Regulation (EU) 2024/1781 (ESPR), Regulation (EU) 2023/1542 (Battery Regulation).