Sectors and timing
How to read the digital product passport timeline
The years in the EU plan are the dates rules get written, not the dates you must comply. Compliance is about two years later.
The years published in the European plan are not deadlines. They are the years the European Commission expects to write each rule.
Your compliance date comes after two more steps: scrutiny by Parliament and Council, then a transition period of at least 18 months. This page explains the gap, because almost every article on this subject gets it wrong.
Read a plan year as a deadline and you buy a passport system about two years early. Read every year as a plan and you miss 18 February 2027. That date is real, and it covers three kinds of battery.
The three steps between a plan and a deadline
A product group becomes covered in three steps. Skip any one of them and you will get the date wrong.
Step one. The Commission adopts a rule. Each product group needs its own rule, called a delegated act. This is the year the published plan shows.
Step two. Parliament and Council may object. They get two months. Either one can extend it by two more months.
Step three. Companies get time to prepare. Article 4(4) sets 18 months after entry into force as the usual minimum.
Warning: that period is not a hard floor. Article 4(4) permits an earlier date in a duly justified case, for a full act or for some of its requirements. Read the act itself when one arrives for your product.
Only after all three does anything apply to your product.
The textile arithmetic gives 2029, not 2027
The Commission plans to adopt the textile rule in late 2027.
| Step | Time |
|---|---|
| Adoption | Late 2027 |
| Scrutiny by Parliament and Council | Up to 4 months |
| Entry into force | 20 days |
| Transition period | At least 18 months |
| Passport applies | 2029 |
If a supplier gives you 2027 for textiles, that is the first row of this table and not the last. See why the textile date is not 2027.
No ecodesign passport applies before mid 2028, and steel is first
The Commission marks its own timeline as indicative. No rule has been adopted for any of these groups.
| Product group | Indicative adoption | Earliest application |
|---|---|---|
| Iron and steel | Q4 2026 | Mid 2028 |
| Textiles, garments and footwear | Q3 to Q4 2027 | 2029 |
| Aluminium | Q3 to Q4 2027 | 2029 |
| Tyres | Q3 to Q4 2027 | 2029 |
| Furniture | 2028 | 2029 or 2030 |
| Electronics and information technology | 2029 | 2030 or 2031 |
Warning: the transition period of 18 months is the usual minimum. Article 4(4) permits an earlier date in a duly justified case, for a full act or for some of its requirements.
The Commission names a quarter for steel, for textiles, for aluminium and for tyres. It names only a year for furniture and for electronics. So each of those two rows can land in either of two years.
Read the right hand column. The earliest possible date for any ecodesign passport is around the middle of 2028, and that is steel.
18 February 2027 is the one real date, and it is for batteries
Batteries are different. The battery passport does not come from the ecodesign framework. It comes from the battery regulation, which is in force.
From 18 February 2027, three kinds of battery need a passport:
- every light means of transport battery, which means e-bikes and e-scooters
- every industrial battery above 2 kilowatt hours
- every electric vehicle battery
No steps remain, which makes that date fixed.
Be careful with the phrase "large batteries". Some official summaries use it. An e-bike battery is small and it is covered, because the rule sets no size limit for that category.
Be careful with a second wording. The Commission web page on digital product passports writes "certain types of batteries, including". That list is open, and the battery regulation closes it at three categories.
The plan lists adoption years, and the law sets the transition period
Three reasons, and knowing them helps you judge what you read next.
The published plan is a table of years. It is easy to quote, and easy to read as a deadline.
An article of the law sets the transition period, and the plan does not. A writer who reads only the plan never sees it.
A supplier who sells passport software has no reason to correct you, because an early deadline sells more software.
You usually have about two years, but a delegated act can set a shorter period
If your product group has no adopted rule, you usually have about two years after the rule appears. Article 4(4) permits a shorter period in a duly justified case, so read the act rather than trusting the usual minimum. Monitor the rule, not the plan.
That is not a reason to do nothing. Your European customer can ask you for product data at any time, as a condition of purchase, with no law involved. That request usually arrives well before any deadline.
The useful work is the same either way. Find out where you keep your product data, and who owns it.