Sectors and timing
Paints, lubricants and chemicals have no passport rule yet
The ecodesign priority list names all three and gives no year. They stay inside the ecodesign frame, so a rule can still arrive for them.
No paint, lubricant or chemical product needs a digital product passport in European Union (EU) law today. The European Commission has adopted no rule for any of these three groups, and this site holds no date for one.
This page is short, because no legal text and no published list gives a year for these three groups.
Two mistakes cost money here. The first is to buy a passport system because of a year that no legal text supports. The second is to read the missing date as a permanent exemption. The ecodesign regulation does not exclude these products, so a delegated act can still cover them.
No delegated act covers paints, lubricants or chemicals
The ecodesign regulation is the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781. It came into force on 18 July 2024, and it is in force today.
By itself that regulation makes no product need a passport. Article 9 makes a passport a condition of market access, and it does so only for a product group that a separate rule covers. That separate rule is a delegated act. Each act names the product group, the data and the date. See what is a delegated act.
As at 14 August 2026 the Commission has adopted no delegated act for any product group. A paint, a lubricant and a chemical product are in the same position as every other group. See which products need a passport, and when.
The ecodesign regulation does not exclude them either
Article 1(2) lists the products that the regulation does not reach. The list names food, feed and medicinal products, among others. See what the ecodesign regulation excludes.
Paints, lubricants and chemicals are absent from that list. So the regulation can reach them later. Only the absence of a delegated act keeps them out today.
The priority list names them, and the list carries no year
GS1 in Europe, an industry body, publishes a list of prioritised product categories for the ecodesign regulation. That list names paints, lubricants and chemicals as three separate categories. It also names iron and steel, aluminium, textiles, furniture, tyres, detergents, some energy-related products and electronics.
Two cautions go with it. The industry body attributes the list to Article 18(5) of the regulation, and this site has not read that article in the Official Journal. A place on the list is also not a date. See priority categories.
The Commission publishes a second list, of indicative adoption years. That list names iron and steel, textiles, aluminium, tyres, furniture, and information and communication technology. It gives no year for paints, for lubricants or for chemicals.
The first ecodesign passport cannot apply before about mid 2028
A delegated act does not apply on the day the Commission adopts it. The Parliament and the Council get time to object first. Then a transition period runs before the act applies.
| Step | What the source says | Status |
|---|---|---|
| Ecodesign regulation in force | 18 July 2024 | In force |
| First indicative adoption, iron and steel | Q4 2026 | Indicative, not adopted |
| Scrutiny by Parliament and Council | 2 months, extendable by 2 months | In force, Article 72(6) |
| Transition period | At least 18 months | In force, Article 4(4) |
| Earliest ecodesign passport | About mid 2028, iron and steel | Calculated here |
| Adoption year for paints, lubricants or chemicals | None published | Unknown |
Article 4(4) allows an earlier date in duly justified cases. So read the 18 months as the usual minimum.
The Commission plans iron and steel first. It has adopted no act for that group either. A group with no published adoption year comes after it. How to read the timeline works through the arithmetic step by step.
Detergents take their duty from a different law
A detergent passport comes from Regulation (EU) 2026/405, and not from the ecodesign regulation. See detergents.
The priority list names detergents beside paints, lubricants and chemicals, as a separate category. So the list tells you nothing about which law reaches your product.
Classify your product before you plan any work. This site cannot say where a solvent cleaner, a paint stripper or an industrial degreaser falls. Ask for the definition article in each regulation, and get the answer in writing.
Three things this page does not know
Read this section before you spend money.
- The plan. This site cannot say that the Commission has scheduled work on any of the three groups.
- The year. No source behind this site gives an adoption year for paints, for lubricants or for chemicals.
- The data. No source here names a single field that such a passport would hold.
A guess would look the same on this page as a checked fact. You would then build a system on it.
New Zealand guidance does not name these products
This site searched for New Zealand material on 16 August 2026, in fifteen separate searches, and read 104 separate pages. The Ministry of Foreign Affairs and Trade wrote the substantial government account, in a market report of October 2025. See what New Zealand agencies have said.
That category timeline names steel, textiles and apparel, tyres, aluminium, furniture and mattresses. Paints, lubricants and chemicals are absent from it.
No other New Zealand government publication covers passports. So if you make a marine antifouling paint or a hydraulic lubricant, you find nothing useful in New Zealand. See what New Zealand agencies have said.
Your packaging and your customer reach you before any passport rule does
Warning: the missing passport date does not free you from other EU rules. Two other demands arrive first.
A paint or a lubricant travels in a can, a drum or a pail. That container is a separate physical good in EU law, under Regulation (EU) 2025/40. The packaging regulation started to apply in August 2026, with phased implementation. See packaging.
Your EU customer makes the second demand. Many chemical products go into somebody else's product, such as a coating on a furniture panel or a lubricant in an e-bike drivetrain. No ecodesign passport duty falls on a component or material supplier. The customer still asks for the data, as a condition of purchase. See New Zealand component and material suppliers.
If you also sell a battery, check the one firm date in this subject. A battery passport starts on 18 February 2027, under Regulation (EU) 2023/1542, which is in force. It covers three categories of battery, and batteries names each one.
Ask for the article number before you buy anything
Warning: a supplier who cannot name the article that sets your date does not have your date.
- Ask which regulation creates the duty for your product.
- Ask which article of that regulation sets the date.
- Ask for the Official Journal reference for that regulation.
- Ask your EU customer which data they need, and when.
- Agree in writing who supplies each item, and who updates it.
Test one further claim when a supplier makes it. The ecodesign regulation names none of GS1, GS1 Digital Link, IEC 61406 or the digital object identifier. It names the ISO/IEC 15459 series in Annex III. See identifier schemes: what is verified.
One task is worth doing whatever the date turns out to be. Find out where you store your product data, and who owns it. Agreeing data duties with your EU importer sets out how to record that in a contract.