Sectors and timing
When an energy-related product needs an EU passport
No passport rule covers an energy-related product today. The old EU ecodesign directive is not fully repealed, and parts of it still apply.
If you export an energy-related product to the EU, no delegated act requires a digital product passport for it yet. An older ecodesign measure can still reach it, and that measure applies now.
The Ecodesign for Sustainable Products Regulation (ESPR) repeals the old ecodesign directive, but not fully. ESPR keeps some articles and annexes of Directive 2009/125/EC in effect for transitional purposes.
So an existing ecodesign measure for an energy-related product can still reach your product. If you assume that the new regulation replaced everything, you can drop a requirement that still applies. Your EU importer will then ask you for evidence that you no longer hold.
The old directive keeps part of its effect
Article 79 of Regulation (EU) 2024/1781 keeps part of the old directive in effect for transitional purposes. The table below gives the parts it keeps.
| Part of Directive 2009/125/EC | What Article 79 keeps |
|---|---|
| Articles | 1, 2, 8(2), 11, 14, 15, 18 and 19 |
| Annexes | I, II, IV, V and VII |
The new regulation entered into force on 18 July 2024. A statement that the old directive lost all effect on that date is wrong.
Two sets of rules can thus reach one product. Check which set reaches yours. Do not assume that the newer rule is the only one. See what law creates the digital product passport.
Your product can carry an ecodesign duty today and no passport duty
An ecodesign measure sets requirements on the product itself. It covers the design of the product, and the information you must give about it.
A digital product passport duty is separate. Under ESPR that duty starts only when the European Commission adopts a delegated act for the product group. As at August 2026 the Commission has adopted no such act for any group. See which products need a passport, and when.
So an energy-related product can carry an ecodesign duty today and carry no passport duty at all. The two duties come from different laws.
The plan names energy-related products, and gives no adoption year
The Commission publishes an indicative programme of product groups. That programme names energy-related products as one of its groups. The programme is a plan, not an adopted law.
The Commission web page on digital product passports puts the group in a window of 2026 to 2029. It gives no single adoption year, and it gives no quarter. One publisher states that window, and no second publisher confirms it here.
A published sector year is the year the Commission expects to adopt a delegated act. It is not a compliance date. Add the scrutiny period. Then add a transition period of at least 18 months. How to read the timeline sets out each step.
The phrase "energy-related products" is loose. This site cannot give you a verified definition of it. A GS1 in Europe page quotes the ESPR priority list in Article 18(5), and the quotation reads "some energy related products". This site has not read that article in the Official Journal, so treat the quotation as a secondary source. See the priority categories.
The word "some" limits the list. The priority list does not reach every product that uses energy.
This page does not list which measures still apply
This site does not know which energy-related product measures continue under Article 79. It does not know when each one will be replaced. The sources behind this site do not record either list.
So this page gives no list of measures and no replacement dates. A page that guessed at them would cost you money. You would pay for work you do not need, or you would drop a requirement too early.
Two steps replace the list:
- Find the measure that covers your product, by its own number.
- Ask the EU operator that places your product on the market. Find out which measure it applies.
If you have no EU office, that operator is usually the EU importer. See who is the economic operator and agreeing data duties with your EU importer.
The energy label is a separate law, and its QR code is not a passport
Many energy-related products also carry an energy label. That label comes from Regulation (EU) 2017/1369, which is a different law again. It applies today, and it does not wait for any passport rule.
Two duties in that regulation matter to an exporter of a household refrigerator or a similar appliance.
| Duty | Source |
|---|---|
| The supplier enters each new model that a delegated act covers in the EU product database. The entry comes before the first unit of the model goes on the market. | Regulation (EU) 2017/1369, Articles 3 and 4 |
| The printed energy label carries a QR code that opens the public part of that database for the model | Regulation (EU) 2017/1369, recital 30 and Article 16(3) point (m) |
The EU product database carries the short name EPREL. Its record covers a model, and a supplier registers the model before the first unit ships.
That QR code is not a digital product passport. It opens one database record for one model. A passport is a structured data set for a product, reached through a data carrier, with its fields set by a delegated act. See what is not a digital product passport.
Check the energy labelling duty separately from the ecodesign duty, because one law does not answer for the other.
Three battery categories need a passport from 18 February 2027
If your product contains a battery, read the battery regulation as well. Regulation (EU) 2023/1542 is in force, and it carries the only passport duty with a fixed date. That date is 18 February 2027.
Three categories are covered:
- each light means of transport (LMT) battery, such as an e-bike battery
- each industrial battery with a capacity greater than 2 kilowatt hours
- each electric vehicle battery
The duty falls on each item. It does not fall on each model. The first category sets no size threshold, so a small e-bike battery is covered. See batteries.
Buy no passport system for this group this year
- Name the ecodesign measure that covers your product. Use its number.
- Ask your EU importer which measure they apply, and which evidence they need.
- Check the energy labelling duty separately. It has its own database.
- Do not buy a passport system for this group this year. No delegated act covers it.
- Monitor the Official Journal for a delegated act that covers your group. Do not act on the published plan.
Warning: do not read step 4 as a reason to wait for everything. A European customer can ask you for product data at any time, as a condition of purchase. That request usually arrives before any deadline.
The Commission programme also names electronics and information technology products. See electronics and information technology. For the wider position of a New Zealand seller, see what this means for New Zealand exporters and what a non-EU exporter must supply.