You can tell the Commission what belongs in your product passport. Here is how, and by when

By Łukasz Głuch · 15 September 2026 · DPPera

The rules that will decide what goes into your product passport are not written yet. Most of them are being written now, in delegated and implementing acts, and each one passes through a window in which anyone can send the Commission a comment. Those windows are short, they are announced in a register almost nobody reads, and some of them have been decided by fewer than a hundred responses. This is how the process works, what is open today, and what a submission has to contain to be worth writing.

Why a small manufacturer should care about this at all

The Ecodesign for Sustainable Products Regulation and the battery regulation are framework laws. Neither of them tells you what fields your passport must contain. That detail arrives later, in a delegated act for your product group, and the delegated act is drafted by the Commission with help from consultants, industry associations and whoever bothered to write in.

The numbers are the argument here. As of 1 September 2026, the four acts closest to the passport had collected these totals in the Commission register of initiatives:

• DPP service providers (entry 14382): 178 responses at the call-for-evidence stage, 275 in the open public consultation.
• Iron and steel (entry 17672), the first product act under the ESPR: 84 and 142.
• The DPP registry (entry 16052): 222 on the draft implementing act.
• Access rights to the battery passport (entry 16473): zero, because that window has never opened.

These are decisions about an entire product category across 27 countries, and they are being shaped by response counts in the low hundreds. A single well-argued submission from a company that actually makes the product is not lost in the noise, because there is very little noise.

The four stages, and how long each one lasts

The register itself tells you the length of every window, in a field it reports in weeks. The pattern is consistent across the passport files:

1. Call for evidence - the Commission announces it intends to regulate something and asks what it should know. Typically four weeks.
2. Open public consultation - a structured questionnaire, usually running alongside an impact assessment. Typically twelve weeks.
3. Draft act feedback - the actual draft text is published and you comment on the wording. Typically four weeks. This is the stage with the most leverage and the least time.
4. Legislative proposal feedback - only for proposals going to the Parliament and the Council, not for delegated acts. The energy label omnibus got eight weeks.

Four weeks is the number that matters. If you find out about a draft act when a newsletter tells you, you have already lost half the window. The register is where it appears first.

What is open right now

Two windows were open when this was checked on 1 September 2026.

Sustainability criteria for plastic recycling technologies (entry 19033). Call for evidence, closing 16 September 2026, 60 responses at the time of checking. If you put recycled content figures in a passport, or intend to, the criteria that decide whether a recycling route counts are being drawn here.

The energy label omnibus, COM(2026)565 (entry 16872). Proposal feedback, closing 15 October 2026, zero responses at the time of checking. We wrote about what this document does to the passport in an earlier piece: it wires EPREL into the passport registry and writes a once-only principle into the energy labelling regulation. If entering the same data twice would cost you real money, this is the window in which to say so.

Two more entries appeared in the register on 28 August 2026 and have no window yet, which means their draft-act stage is still ahead: minimum durability values for portable batteries of general use (entry 19132) and green public procurement criteria for apparel textiles (entry 19133). Both are worth a calendar reminder rather than an action today.

How to actually file one

The mechanics are unglamorous and that is the point.

• You need an EU Login account. Free, and the same account works across Commission services.
• Anyone can file. A company, an association, a public body, an individual. A sole trader counts. You declare which you are, and your submission is published with that label attached.
• Submissions are public. Yours will be readable by your competitors, and theirs by you. Reading what has already been filed on your file is, on its own, competitive intelligence you cannot buy.
• You can attach a document. The text box is short; the attachment is where a real argument fits.
• Any official EU language works. Polish is an official EU language.

What makes a submission count

Having read a fair number of them, the ones that read as useful share three things.

They are specific to a product, not to a philosophy. "The burden on SMEs will be too high" is a sentence the Commission has already read several hundred times. "For a run of 400 jackets, collecting supplier declarations for the four fields in Annex X took us 31 hours, and here is the breakdown" is a sentence it has read almost never.

They bring numbers only the filer can have. Batch sizes, supplier response rates, how long a data field actually takes to collect, what a test costs. The Commission has consultants for modelling and no source at all for your operational reality.

They propose wording, not just objections. At the draft act stage you are commenting on a text. Naming the article, quoting the phrase and offering an alternative is worth more than a page of general concern.

One more, learned the hard way: file before the last day. The system closes at 23:59:59 Brussels time on the stated date, and a submission that fails to upload at 23:50 is simply not a submission.

What this is not

• It is not a vote. The Commission is not obliged to follow the majority of responses, and frequently does not. It is obliged to consider them and to publish a summary.
• It is not a way to delay a deadline. Nothing filed in a feedback window moves 18 February 2027 for batteries.
• It is not confidential. Do not put anything in a submission that you would not want a competitor, a customer or a journalist to read.
• It is not the same as lobbying. Feedback is a public, logged, one-directional channel. It is the version of this process available to a company with no budget for anything else.

How to check this yourself

Do not rely on us or on a vendor newsletter for whether a window is open. The Commission register of initiatives is public and machine-readable, and the direct query is:

https://ec.europa.eu/info/law/better-regulation/brpapi/searchInitiatives?text=product+passport&size=10&language=EN

Each result carries an id. Put that id into https://ec.europa.eu/info/law/better-regulation/brpapi/groupInitiatives/<id>?language=EN and you get the stages, the closing dates, the length of each window in weeks and the live response count. The human-readable version of the same thing is the "Have your say" portal.

Watch the counters rather than trusting a single reading. The plastic recycling file moved from 59 to 60 responses during the hour we spent checking it. Any number quoted in an article, including ours, is a snapshot with a date on it.

What to do this week

• Create the EU Login account now, while nothing is urgent. It is the step that turns a four-week window into a three-week one if you leave it until you need it.
• Look up your product group in the register and note which stage it is at. Most groups are still before the first window, which is the best moment to be paying attention.
• If recycled content is part of your story, read entry 19033 before 16 September 2026.
• If double data entry would cost you, read COM(2026)565 before 15 October 2026.

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