Which Products Need a Digital Product Passport? By Sector

A buyer at a German retailer sends a short email. From next year, it says, every product we list will need a digital product passport. Please confirm yours.

You make kitchen knives. Or face cream. Or industrial pumps. And you have no idea if the rule even applies to you.

That is the question almost everyone asks first. Not "what is a digital product passport", but "do I need one, and when?" This guide answers it sector by sector.

At a glance:

• A digital product passport only becomes compulsory for a product when a law for that product group says so. Most products have no such law yet.
• Batteries come first: EV, industrial and light-transport batteries need a passport from 18 February 2027.
• Iron and steel, construction products and packaging follow, with the Commission pointing to 2028.
• Textiles, tyres, aluminium and ICT products are pencilled in for 2029. Detergents apply from 23 September 2029 and toys from 1 August 2030. Vehicles get their own passport from 1 September 2032.
• Food, feed and medicines sit outside the ecodesign law altogether. Cosmetics have no passport rule today.

How a product ends up needing a passport

The digital product passport comes from the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, or ESPR. It has been in force since 18 July 2024.

But the ESPR on its own requires nothing from your product. It is a frame. The real duties arrive later, one product group at a time, in a delegated act. That act names the product, the data the passport must carry and the date it starts.

The ESPR also gives companies time. A delegated act applies at least 18 months after it enters into force. So a rule adopted in late 2027 bites in 2029 at the earliest.

A few other laws create their own passports. The Batteries Regulation, the new Toy Safety Regulation, the new Detergents Regulation and the Construction Products Regulation each bring one in for their own goods.

So the honest answer to "do I need one?" is: check whether a law for your product group exists, and when it applies. Our plain guide to the digital product passport covers what the passport itself holds.

The sector table

The Commission set out its order of work in the ESPR working plan, adopted on 16 April 2025. In June 2026 its DG GROW team showed an updated timeline for when passports become mandatory, in its Introduction to the Digital Product Passport presentation.

Four dates are fixed in law: batteries, detergents, toys and vehicles. Every other date below is the Commission's plan, and plans move.

Three questions to find out where you stand

1. Is your product food, feed, a medicine or a vehicle? Food, feed and medicines sit outside the ESPR and have no passport. Vehicles have their own passport from 1 September 2032.
2. Is it a battery, a toy, a detergent or a construction product? Then a law for your product already exists. Your passport follows its dates in the table above.
3. Is it textiles, tyres, steel, aluminium, furniture, a mattress or an ICT product? Then it is on the ESPR priority list. You have until the delegated act plus 18 months. Start collecting supplier data now.

If you answered no three times, no passport rule covers your product today. Cosmetics usually end up here for now. Check the working plan once a year.

Batteries: the first real deadline

If you place EV batteries, industrial batteries above 2 kWh or batteries for light means of transport such as e-bikes on the EU market, the passport is not a plan. It is law. From 18 February 2027, each battery needs its own passport, opened by a QR code on the battery.

That is under four months away. The data behind it, such as carbon footprint, material origin and recycled content, has to come from suppliers. That is the slow part. Our battery passport guide walks through who owes it and what goes in it.

Iron, steel and aluminium: the passports that travel

Steel and aluminium are intermediate products. Few consumers buy a steel coil. But almost everything else is made from them.

The Commission opened a call for evidence on the steel act in May 2026, with feedback due by 12 August 2026. It expects to adopt the act in Q4 2026. As of today, it has not yet been adopted.

There is a live argument about how far it reaches. The engineering industry body Orgalim has asked the Commission to keep the steel passport to intermediate products and not extend it to the machines and parts made from steel. Watch that closely if you build anything out of metal.

Textiles, apparel and footwear

Textiles are the biggest consumer group on the list. The Commission expects the textile act in Q3 to Q4 2027, with passports mandatory from 2029.

Footwear is not part of that first textile act. It has its own study first. But one textile rule already applies today. Since 19 July 2026, large companies may not destroy unsold clothing and footwear under the ESPR.

We cover the textile details in what the textile passport will require and the textile DPP timeline.

Photo by Hugo Clément on Unsplash

Toys: the passport replaces a document you already have

Toys get a passport through their own law, not the ESPR. The new Toy Safety Regulation, Regulation (EU) 2025/2509, was published on 12 December 2025 and applies from 1 August 2030.

Here the passport does a specific job. It replaces the EU declaration of conformity. By creating the passport, the manufacturer declares that the toy complies. So for toy makers, the passport is not extra paperwork on top. It becomes the paperwork.

Electronics, construction, packaging, detergents and vehicles

Electronics and ICT. There is no single electronics act yet. The Commission plans horizontal rules on repairability for 2027 and points to 2029 for ICT passports.

Construction products. The revised Construction Products Regulation brings its own passport. The Commission's timeline points to 2028.

Packaging. The Commission lists packaging among the 2028 passport groups. Our PPWR timeline covers the packaging rules that already have dates.

Detergents. The new Detergents Regulation, Regulation (EU) 2026/405, has been in force since 22 March 2026. It makes a passport mandatory for detergents, and for surfactants sold directly to end users, from 23 September 2029.

Vehicles. Vehicles are outside the ESPR. They get their own digital circularity vehicle passport under the End-of-Life Vehicles Regulation, Regulation (EU) 2026/1738, which has been in force since 13 August 2026. The passport applies to new vehicles from 1 September 2032.

Furniture, mattresses and tyres

These three are on the ESPR priority list. Tyres come first, with the act expected in Q3 to Q4 2027 and passports from 2029. The furniture act is expected in 2028 and the mattress act in 2029. Neither has a mandatory date yet, because the 18-month clock only starts once each act is adopted.

Food, cosmetics, machinery: the "not yet" and "not at all" group

Food and drink: not at all. The ESPR does not apply to food, feed, medicines, veterinary medicines, living plants and animals, products of human origin or vehicles. The Irish government's ESPR briefing lists the exclusions plainly. If you sell coffee, cocoa or chocolate, your EU traceability rule is the deforestation regulation, and our EUDR guide covers that.

Cosmetics: not today. No passport rule exists for cosmetics. The EU agreed changes to the cosmetics rules in 2026 as part of a chemicals simplification package. It covers labelling and ingredient rules, not a passport. The Commission has also been evaluating the wider Cosmetics Regulation, so this could change. It has not yet.

Machinery: not as its own group. Machinery is not on the passport timeline as a product group. But machine makers will still meet passports, through the steel and aluminium they buy and possibly through the steel act itself.

What to do if your sector is on the list

Start with the data, not the software. Every passport is built from information that sits with your suppliers: material, origin, recycled content, substances. Collecting it takes months, because it means asking dozens of companies for the same facts.

That is the step Bindu is built for. Each supplier gets its own workspace connected to its own systems, so nobody hands over their ERP. Missing data is collected over email or WhatsApp by AI, so nobody chases it by hand. When your product group's act lands, the passport is built from data you already hold.

If you are not on the list yet, you still have something to do. Check your products against the working plan once a year. Our guide to what the ESPR is explains how new groups get added. For what has actually been adopted so far, see our digital product passport news page.

See how it works at getbindu.com.

FAQ

Which products need a digital product passport first? Batteries. EV batteries, industrial batteries above 2 kWh and batteries for light means of transport need a passport from 18 February 2027, under the Batteries Regulation (EU) 2023/1542.

Source: EUR-Lex: Regulation (EU) 2023/1542

Do food products need a digital product passport? No. The ESPR, Regulation (EU) 2024/1781, does not apply to food, feed, medicines, veterinary medicines, living plants and animals, products of human origin or vehicles.

Source: EUR-Lex: Regulation (EU) 2024/1781

Do cosmetics need a digital product passport? Not today. No passport rule exists for cosmetics. The 2026 chemicals simplification package changed cosmetics labelling and ingredient rules, not passports. The Commission has also been evaluating the wider Cosmetics Regulation.

Source: EU Chemicals Platform: co-legislators agreement on chemicals, cosmetics and fertilisers

When do textiles need a digital product passport? The Commission expects to adopt the textile delegated act in Q3 to Q4 2027, with passports mandatory from 2029. Footwear is not part of the first textile act.

Source: European Commission: ESPR and Energy Labelling Working Plan 2025-2030

Do toys need a digital product passport? Yes. The Toy Safety Regulation (EU) 2025/2509 requires a passport for each toy, and it replaces the EU declaration of conformity. The regulation applies from 1 August 2030.

Source: EUR-Lex: Regulation (EU) 2025/2509

How long do companies get after a passport rule is adopted? At least 18 months. Under the ESPR, a delegated act applies no sooner than 18 months after it enters into force, so a rule adopted in late 2027 applies in 2029 at the earliest.

Source: EUR-Lex: Regulation (EU) 2024/1781

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This article reflects the official position as of 2 November 2026. Product rules under the ESPR are still being adopted, so dates can move. For anything after that date, check the European Commission's digital product passport page and the regulation texts on EUR-Lex. This is general information, not legal advice.