Waiting for Brussels to soften the product passport? The new omnibus says no

By Łukasz Głuch · 29 August 2026 · DPPera

There is a strategy circulating among smaller manufacturers, and it is not a stupid one: wait. Brussels is in a simplification mood, the reasoning goes, so the product passport will be softened or postponed before it ever reaches my shelf. On 20 August 2026 the Commission opened public feedback on exactly the kind of document that theory depends on - a simplification omnibus for product legislation. It contains one sentence about the ecodesign regulation, and that sentence decides the argument.

What the omnibus actually is

The document is COM(2026)565, a proposal the Commission adopted on 24 June 2026 and published for feedback on 20 August 2026. Comments are open until 15 October 2026. It amends two regulations: (EU) 2017/1369 on energy labelling and (EU) 2020/740 on tyre labelling.

The content is a real simplification package, not a cosmetic one. It removes the default rule that every single unit must be accompanied by a printed energy label, while keeping printed labels available on request. It gives dealers 12 months after a rescaling date to sell through units they received with the old label. It repeals the two Energy Star regulations, which became obsolete when the US-EU agreement expired in February 2018. Notably, it stops short of going fully digital on labels, and the reason given is the retail sector being dominated by smaller companies.

So the appetite for simplification is genuine. The question is where it stopped.

The sentence that settles it

On page three, the Commission writes:

"The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR), which repealed and replaced the Ecodesign Directive 2009/125/EC as from 18 July 2024, subject to certain transitional measures, is not part of the present omnibus. Implementation of the ESPR is still in a very early phase."

Read that twice, because it is the Commission declining to simplify its own product passport framework inside its own simplification act. And note the stated reason. It is not that the rules are working beautifully. It is that there is not yet enough of the ESPR in force to be worth simplifying.

That reasoning cuts against the waiting strategy rather than supporting it. "Too early to simplify" is a statement about how much is still coming.

What changed between February and June

This is worth knowing, because it is the part that looks like a reversal and is not quite one.

When the Commission announced this initiative on 12 February 2026, the planned proposal was described as amending three regulations. The third was the ESPR - but only in one narrow respect: extending a transitional mechanism for energy-related products under Article 79(1)(a)(i). Nothing about passports, nothing about obligations.

The proposal adopted in June amends two regulations. Even that narrow ESPR amendment is not in it, and the text does not say where it went. So the honest summary is: the omnibus never aimed at the passport, and by June it had stopped touching the ESPR at all.

It does touch the passport, three times

Here is the part almost nobody has picked up, and it is the useful part. The omnibus does not amend the ESPR, but it does change how the passport will work in practice, because it changes EPREL - the EU database that already holds every energy-labelled model on the market.

1. Register once, not twice. The proposal states that products for which EPREL already offers information equivalent to that required by an ESPR delegated act do not have to be registered again in the registry that will manage the digital product passport. Instead, EPREL's central administrative part and its "model-related" information get interlinked with item-level information in the passport registry.
2. Integration becomes a duty, in writing. A new paragraph is added to Article 12 of the energy labelling regulation: "Where provided for by Union law, the Commission shall ensure the integration between EPREL and the central part of the registry to be established under Article 13 of Regulation (EU) 2024/1781." That is the first time the link between the two systems is written into a legal text rather than described in a slide deck.
3. One identity check, not two. The proposal says a second identity verification should not be required, unless additional requirements need to be verified for the passport. Anyone who has been through identity verification for an EU system will understand why that sentence is worth more than it looks.

Point one hides something that decides your workload. EPREL holds information at model level. The passport registry is described here as holding item level information. That is the same distinction that decides whether you publish one passport for a product line or one per unit, and it is now visible in a legislative proposal rather than only in a standard.

Who should care most

If you make washing machines, fridges, lamps, boilers or anything else carrying an energy label, you are already registered in EPREL. You have already done the data work once. Under this proposal, that work counts - the passport becomes a layer over a registration you already maintain, rather than a second registration standing next to it.

This matters because energy-related products sit on the ESPR working plan. If you have been told your category is unregulated because it is "just appliances", that was wrong, and this document is a reminder of how connected the two systems are about to become.

What this is not

• It is not law. COM(2026)565 is a proposal. It goes to the European Parliament and the Council under the ordinary legislative procedure, and the text can change or fail. Nothing described here is an obligation today.
• It does not move any passport date. The battery passport still applies from 18 February 2027, under a different regulation entirely.
• It does not mean the ESPR will never be simplified. It means this omnibus does not do it, for a stated reason that will expire as more delegated acts arrive.

How to check this yourself

Do not take this from us, and do not take it from a vendor blog. The Commission runs a public register of initiatives, and this one is entry 16872. The proposal itself, its annexes and the impact assessment summary are attached to it in every EU language, including Polish. The feedback period runs to 15 October 2026 and is open to anyone, including a one-person company.

One warning if you go looking on EUR-Lex: as of late August 2026 this proposal did not yet have a CELEX number there. That is normal for a document this fresh, and it is exactly why the register of initiatives, not the law database, is the right place to track what stage something is at.

What to do this week

• If you sell energy-labelled products, open your EPREL registration and look at what is already in it. Under this proposal that data is the part you will not be entering a second time.
• Stop pricing "wait and see" as free. The clearest official signal available says the framework that creates the passport is not being simplified, and the reason given is that it has barely started.
• If the once-only rule matters to your business, say so before 15 October 2026. Consultations on passport files have been decided by very small numbers of responses.

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