Which products need a digital product passport, and when

Today only three kinds of battery need a digital product passport in European Union (EU) law. No other product group has a passport duty, and no group can get one until the European Commission writes a rule for it.

The date for those batteries is 18 February 2027, and the law sets it.

Two mistakes cost money here. The first is to buy a passport system two years before any rule reaches your product. The second is to sell an e-bike battery into the EU and miss the date above.

Three kinds of battery need a passport from 18 February 2027

The battery passport does not come from the ecodesign regulation. It comes from the battery regulation, Regulation (EU) 2023/1542, which is in force. Article 77 sets the date.

From 18 February 2027 each of these batteries must have a passport:

• 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 is per battery. Each item carries its own passport and its own identifier. One passport for a model or for a batch is not enough.

Warning: some summaries describe this as a rule for "large batteries". That phrase is wrong and it is dangerous. The light means of transport category has no size threshold, so a small e-bike battery is covered.

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.

Article 13(6) of the same regulation gives every battery a QR code. That code leads to other information, and it is not a passport. So a portable battery carries a QR code, but it carries no passport. Batteries gives the detail, and the battery regulation gives the legal structure.

The ecodesign regulation gives no date by itself

The Ecodesign for Sustainable Products Regulation (ESPR) is the law that can give most other products a passport. It is Regulation (EU) 2024/1781, and it has been in force since 18 July 2024.

ESPR by itself makes no product need a passport. Article 9 makes a passport a condition of market access, but only for a product group that a separate rule covers. That separate rule is a delegated act under Article 4. Each act names the product group, the data and the date.

As at 15 August 2026 the Commission has adopted no delegated act for any product group. So no ESPR passport is mandatory for any product today. See what is a delegated act.

A delegated act usually applies at least 18 months later

Article 4(4) says a delegated act cannot apply earlier than 18 months after it enters into force. The same article allows exceptions in duly justified cases, so treat that period as the usual minimum.

Before the transition period starts, the Parliament and the Council get time to object. How to read the timeline sets out each step in order.

The published sector years are the years the Commission expects to adopt each act. They are not compliance dates, and reading one as a deadline puts your work about two years early.

The sector table: adoption years, then about two more years

Warning: read the middle column as a plan and the right column as the earliest possible outcome. The Commission marks these years as indicative, and no delegated act is adopted for any group below.

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 plans to adopt the iron and steel act first. The earliest possible ESPR passport date is about the middle of 2028, and it belongs to iron and steel.

This site calculates the right column. The Commission publishes the adoption years only. Every row follows the same arithmetic: adoption first, then scrutiny, then a transition period of at least 18 months.

The Commission names no quarter of the year for the last four rows. It gives a year alone, so each of those rows shows two possible years.

The last two rows are new on the Commission web page. The page plans a mattress act in 2029, apart from the furniture act. It plans an act for recycled content in the same year, and it names no product group for that act. Read both rows as one publisher's plan, and read the years as indicative.

Textiles, garments and footwear is the group with the most wrong dates in circulation. If you export a merino jumper, a supplier may tell you to be ready for 2027. That is the year the rule gets written. Why the textile date is not 2027 shows the arithmetic.

The other planned groups have their own pages: aluminium, tyres, furniture and mattresses, and electronics and information technology.

The Commission programme also names energy-related products. The Commission web page puts that group in a window of 2026 to 2029, in its legal basis list. It gives no single adoption year, and one publisher states the window. See energy-related products.

If you sell paint, lubricant or another chemical product, no delegated act covers you, and no adoption year for your group is confirmed here. See paints, lubricants and chemicals.

Four product groups get a passport from a different law

Do not look for these four in the ecodesign programme. Their passport comes from their own regulation.

The toy application date is consistent across the sources. The entry into force date is not, so this site gives none. See toys, detergents and construction products.

Packaging reaches you even if you export food. Your packaging is a separate physical good in EU law, and the food exclusion does not cover it. The Ministry of Foreign Affairs and Trade reports on this point. Where a product also falls under ESPR, the passport should carry the packaging information too. The start date of the packaging labelling article is not confirmed. See packaging.

Some products sit outside ESPR fully

Article 1(2) excludes a list of products. If your product is on the list below, the regulation does not reach it, and no delegated act will reach it later.

• food and feed
• medicinal products and veterinary medicinal products
• living plants, animals and micro-organisms
• products of human origin
• products of plants and animals that relate directly to their future reproduction

Vehicles are excluded only for the product aspects that other EU acts already regulate.

Food includes drink. Article 2 of Regulation (EC) No 178/2002 defines food for the ESPR. That law says food "includes drink, chewing gum and any substance, including water, intentionally incorporated into the food". A carton of Marlborough sauvignon blanc is food. See food and feed are excluded, wine, beer and spirits and medicinal products are excluded.

Warning: the exclusion covers the product, not the company. A business that sells manuka honey and merino jumpers has one excluded product and one that a later rule may cover.

Three groups that people expect to be excluded are not. Cosmetics, tobacco products and medical devices stay inside ESPR scope. Batteries are not on the exclusion list either. See cosmetics and natural health products and ESPR exclusions.

Find your own position in five steps

If a New Zealand page gave you a different category list, see does this reach my product.

1. Find your product group in the two tables above.
2. Check the exclusion list. Food, feed and medicine sit outside ESPR.
3. If you sell one of the three battery categories, prepare for 18 February 2027.
4. If your group has no adopted act, do not buy a passport system this year.
5. Ask your EU importer which data they need, and when.

If you supply a component, no ESPR passport duty falls on you. Your customer still asks for the data, as a condition of purchase. See what a non-EU exporter must supply.

You probably have no EU office. For a battery, the operator that places it on the EU market must keep the passport data accurate. That operator is usually your EU importer, and it asks you for the data. See what this means for New Zealand exporters.