Which products need a Digital Product Passport?

Two products are legally committed to a Digital Product Passport with a fixed date: certain batteries, and — via a separate registry act — toys, detergents and construction products. A longer list of product groups, including textiles, furniture and tyres, has been named as a priority for future rulemaking, but none of them has an adopted obligation yet. Confusing the two lists is the single most common mistake on pages that try to answer this question, so this post keeps them apart.

If you make or import a product and want the direct answer, use the checker below. If you want the reasoning, read on.

The short answer

As of July 2026, a Digital Product Passport is a live legal obligation for:

• LMT, industrial (>2 kWh) and EV batteries, from 18 February 2027, under Article 77(1) of Regulation (EU) 2023/1542 — the Batteries Regulation.
• Products already named in the DPP registry's own scope article — the infrastructure that batteries plug into. Article 1 of Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 (OJ L, 2026/1778, 17.7.2026; CELEX 32026R1778) lists: (a) products covered by delegated acts adopted under Article 4 of Regulation (EU) 2024/1781 of 13 June 2024 (OJ L, 2024/1781, 28.6.2024; CELEX 32024R1781) — the ESPR; (b) batteries under Article 77 of the Batteries Regulation; (c) construction products under Article 76 of Regulation (EU) 2024/3110; (d) toys; (e) detergents.

Everything else — textiles, furniture, tyres, mattresses, iron and steel, aluminium — is a named priority for future rulemaking, not a product with a passport duty today. That distinction is the whole point of this post, so it's worth being precise about why.

Two different ways a product ends up in scope

Batteries and the registry's Article 1 list get there differently, and it matters which route applies to you.

Batteries are in scope by name, written directly into the Batteries Regulation itself. Article 77(1) is unconditional: it names the three battery categories and sets the date. There is no further delegated act standing between the text and the obligation — 18 February 2027 is fixed.

Toys, detergents and construction products are in the registry's scope article, but the registry is infrastructure, not the substantive rulebook. Impl. Reg. (EU) 2026/1778 sets up how the DPP registry works — identifiers, access, national administrators — for products that are, or will be, covered elsewhere. Toys and detergents still need their own Article 4 delegated act under the ESPR to define what data their passports must actually carry; construction products depend on Article 76 of Regulation (EU) 2024/3110. Being named in the registry's scope is a strong signal, not a finished obligation in itself.

Everything else reaches the DPP only through an Article 4 delegated act. Regulation (EU) 2024/1781 is a framework regulation — it does not itself impose passport requirements on any product. Article 4 empowers the Commission to adopt, product group by product group, delegated acts that set the ecodesign and information requirements, including whether and how a DPP applies. Until that act exists for your product group, the ESPR does not reach you yet.

1. 18 February 2027Due

   Battery passport obligation begins

   LMT, industrial (>2 kWh) and EV batteries. Article 77(1), Regulation (EU) 2023/1542.

2. 2026 (indicative)Expected

   Iron and steel — earliest ESPR working-plan delegated act

   Named a priority in COM(2025) 187 final. No Article 4 delegated act adopted as of July 2026.

3. 2027 (indicative)Expected

   Textiles/apparel, tyres, aluminium

   Named priorities in the same working plan. No delegated acts adopted.

4. 2028 (indicative)Expected

   Furniture

   Named priority, indicative date only.

5. 2029 (indicative)Expected

   Mattresses

   Named priority, indicative date only.

Where the working-plan dates come from — and why they're not obligations

The European Commission adopted the Ecodesign and Energy Labelling Working Plan 2025–2030 — COM(2025) 187 final of 16 April 2025 (CELEX 52025DC0187) — under Article 18 of Regulation (EU) 2024/1781, which requires the Commission to set out "a list of product groups which are to be prioritised for the setting of ecodesign requirements and the estimated timelines for their setting." That plan names four final-product priorities (textiles and apparel, furniture, tyres, mattresses) and two intermediate-product priorities (iron and steel, aluminium), with indicative delegated-act years running from 2026 (iron and steel) through 2029 (mattresses).

This is the trap worth naming explicitly: a product group appearing in a working plan reads, at a glance, like a scope announcement. It isn't. Treat the working plan as a forecast of where delegated acts are heading and treat "delegated act adopted" as the only event that actually starts a clock.

How to place your own product

1. Check if you make batteries. If any product you place on the market is an LMT, industrial (>2 kWh) or EV battery, you have a fixed date: 18 February 2027. Our battery categories page breaks down exactly where each battery type sits.
2. Check Article 1 of Impl. Reg. (EU) 2026/1778. If your product is a toy, a detergent, or a construction product under Article 76 of Regulation (EU) 2024/3110, the registry already treats you as in scope — but confirm whether the product-specific delegated act (for toys and detergents) has been adopted before treating the obligation as live.
3. Check the ESPR working plan. If your product group is named as a priority, you have a useful early signal and an indicative year, not a deadline. Start scoping — supplier data collection and identifier schemes take quarters to build regardless of when the obligation formally lands — but don't publish a fixed compliance date to customers until an Article 4 delegated act actually exists.
4. If none of the above applies, there is currently no signal that your product will need a DPP. That can change with each working-plan update, so it's worth rechecking rather than assuming permanence.

For the fixed battery timeline and every other verified date in this Regulation, see the compliance timeline. For the wider DPP framework this all sits inside, see what a Digital Product Passport actually is and how the ESPR creates the legal basis for it.