DPP deadlines by product category: when will it become mandatory?

“When should we have a DPP?” It’s a common question from executives and compliance officers. The short answer: it depends on the product category. You can read the longer answer below. We’ve listed all known deadlines for the DPP requirement, including when delegated acts are expected by product group.

How does phased implementation work?

The ESPR (EU 2024/1781) provides the framework. The specific requirements for each product group are defined in delegated acts, prioritized according to the Working Plan 2025-2030 adopted by the European Commission on April 16, 2025.

The process is always in three steps: the Commission publishes a delegated act, then there is a transitional period of at least 18 months, and only then does the DPP become mandatory. That distinction is essential. The table below shows when the delegated act is expected, not when the DPP obligation takes effect. Add at least a year and a half.

Only the battery deadline is definite. The other dates are indicative and may shift after the mid-term review in 2028.

By category: where are the challenges?

Batteries: February 2027

The Battery Regulation (EU 2023/1542) is no longer an expectation, but applicable law. From Feb. 18, 2027, all industrial batteries above 2 kWh, EV batteries and LMT batteries must have a digital battery passport with information on identification, technical characteristics, carbon footprint and critical raw materials.

What makes this pathway demanding is that the passport is not a static document. Data such as State of Health must be updated during its lifetime. In addition, the regulation requires a carbon footprint calculation per kWh and due diligence on raw materials such as cobalt, lithium and nickel. Several supporting delegated acts are still being developed, and by August 2026, the Commission must publish an “implementing act” on access rights. For battery manufacturers, EV producers and importers, this is the most pressing deadline on the DPP calendar.

Iron & steel: delegated act expected 2026

Iron and steel make up the first batch of ESPR products. The delegated act is expected in 2026, implying a DPP obligation around 2028. The carbon footprint calculation per ton of steel is data intensive, but organizations that already collect ETS or CBAM data have a head start: much of the required information overlaps. Relevant for steel producers, importers, processors and the construction industry.

ICT and Electronics: delegated act expected 2026-2027

ICT and electronics are priorities among the ESPR, but have more complex implementation than more standardized categories such as steel or tires. Technological diversity is high, innovation cycles are short, and supply chains are deeply layered and globally dispersed.

The DPP is expected to require comprehensive information on material use (including critical raw materials such as cobalt, rare earths and lithium), energy efficiency, repairability and software support. Especially the latter is new territory: the lifetime of ICT products is determined not only physically, but also by software updates and compatibility. In addition, requirements around disassembly and recyclability play a major role, with direct impact on product design.

The biggest challenge is in collecting consistent, verifiable data across multiple tiers in the chain. Many manufacturers rely on supplier networks for semiconductors, printed circuit boards and batteries, where data access is often limited. Organizations that already have experience with product compliance (RoHS, REACH), lifecycle analysis or supply chain due diligence have an edge, but will need to significantly expand their data models. Relevant for manufacturers, importers and distributors of ICT equipment.

Textiles & apparel: delegated act expected 2027

Of all the ESPR categories, textiles is perhaps the most challenging, not because of the number of fields, but because of the fragmented chains. A simple T-shirt touches dozens of suppliers across multiple continents. Fiber origin and microplastics release are data points that most textile companies do not yet track structurally. On top of that, the destruction ban for unsold textiles already goes into effect July 19, 2026, so the sector already faces another ESPR obligation in the short term. The delegated act for the DPP is expected in 2027, with an obligation around 2028-2029. This affects apparel brands, textile manufacturers, importers and retailers.

Tires: delegated act expected 2027

Tires build on the existing EU tire label. Rolling resistance, wet grip and noise level are already recorded, making preparation relatively straightforward. The wear indicator for microplastics is the main new data point.

Furniture and Aluminum: delegated acts expected 2028

Furniture and aluminum both fall into the second priority group, with a DPP requirement around 2030. For furniture, it’s about wood sourcing, certification (FSC/PEFC), formaldehyde emissions and disassembly capabilities. For aluminum, it’s about CO₂ emissions per ton and recycled content, strongly linked to CBAM. Organizations that already have EPDs or FSC certification are well on their way in both cases.

Construction products: own route through the CPR

Construction products follow a separate path through the revised Construction Products Regulation (CPR, EU 2024/3110), effective Jan. 7, 2025. And more is now known than for most ESPR categories.

In December 2025, the Commission published the first CPR Working Plan 2026-2029, with concrete milestones for each product family. The DPP registry must be operational by July 19, 2026, a delegated act is expected in Q4 2026 for DPP service providers, and the first product families (such as cement and concrete) are expected to receive revised standards by the end of 2027. Once those standards are made mandatory, the DPP will apply 18 months later.

The regulatory landscape is complex: construction products are covered by both ESPR and CPR, with CPR taking precedence. The Declaration of Performance and Conformity (DoPC) replaces the old declaration of performance and must soon be available through the DPP. Environmental data will become mandatory in phases: GWP reporting from 2026, core environmental indicators from 2030, the full set of life cycle indicators from 2032. The transition is by product family (Annex VII defines 36). Organizations that already have EPDs compliant with EN 15804 have a solid head start.

Mattresses: delegated act expected in 2029

Mattresses are the third priority group. Flame retardants, VOC emissions and foam recyclability are the key issues.

Products not yet listed

The 2025-2030 Working Plan is not exhaustive. Footwear is under review (study expected in late 2027), and the 2028 mid-term review may add new categories. Eventually, almost all physical products on the EU market will be covered by the ESPR. ESPR basic fields will soon apply to all.

The deadline is not the biggest risk

In the organizations we assist, we still see it too often: the focus is on the date, but the real risk is in the lead time. The real risk isn’t missing the deadline. It’s not starting until competitors are already ready, a tender calls for it, or your largest customer sets it as a procurement requirement.

What organizations can already do today: inventory existing data through the Empact DPP Tool, include DPP in procurement discussions with suppliers, and create a roadmap for obtaining all relevant data.

Want to know what DPP preparation means for your organization? Contact Empact, we’d love to think with you.