The omnibus feedback window closed on 15 October. Here is what Brussels heard about the product passport, and what it did not

On 15 October 2026 at 23:59 Brussels time the feedback period on COM(2026)565 closed. The proposal, adopted by the Commission on 24 June and published for comment on 20 August, amends the energy labelling regulation (EU) 2017/1369 and the tyre labelling regulation (EU) 2020/740. It is the file that some manufacturers hoped would soften the digital product passport, and it is the file that instead wrote the link between EPREL and the passport registry into a legal text. The window is shut; the proposal is with the European Parliament and the Council. Here is the balance.

The count

When we checked the Commission register of initiatives on 22 September, entry 16872 showed six responses, five weeks into an eight-week window. When the window closed at 23:59 on 15 October, the count stood at 40, and 25 of them arrived in the last two days. By type: 22 business associations, 6 companies (Amazon, Tata Consultancy Services and DPPera among them), 4 EU citizens, 3 NGOs, 2 consumer organisations, 2 public authorities and 1 other. Nineteen came from Belgium, where the European associations have their offices; two came from Poland, Employers of Poland and us. In the response texts, EPREL is mentioned in 18, the word "passport" in 10 and the once-only principle in 8; 28 responses also attached a document, which we did not count.

For scale: the call for evidence that preceded this proposal, open from 12 February to 12 March 2026, collected 58 responses. The three ESPR passport acts we counted in August collected 901 between them; the battery access act had zero until its draft appeared on 19 October 2026, and 13 by 26 October. Feedback on a legislative proposal is a different instrument from feedback on a draft act: it goes to the Parliament and the Council as a summary, it does not bind the Commission, and it is usually thinner. The numbers here are consistent with that.

What the file says about the passport, unchanged

Nothing in the feedback period changes the text; only the co-legislators can do that. So the three points we described in August are still the three points:

• Register once. Products for which EPREL already offers information equivalent to what an ESPR delegated act would require do not have to be registered again in the passport registry. EPREL's administrative part and its model-level data get interlinked with item-level information in the registry.
• Integration becomes a duty. A new paragraph 13 in Article 12 of the energy labelling regulation: where Union law provides for it, the Commission shall ensure integration between EPREL and the central part of the registry established under Article 13 of Regulation (EU) 2024/1781.
• One identity check. A second identity verification is not to be required unless additional passport requirements need verifying.

And the sentence that decides the waiting strategy is also unchanged: the ecodesign regulation is not part of this omnibus, because its implementation is still at a very early stage. The February call for evidence had announced a narrow change to ESPR, an extension of the transitional mechanism for energy-related products under Article 79(1)(a)(i). The June proposal dropped it. Anyone who wrote in asking for ESPR to be reopened was writing to the wrong file.

What the window could not do

It is worth being precise about what public feedback on a proposal is, because the phrase gets used as if it were a vote.

The Commission collects the responses, publishes them on the Have Your Say portal, and forwards a summary to the Parliament and the Council. It does not amend its own proposal in response. Changes come from the committee report in Parliament, from the Council working party, and from the trilogue between them. The feedback is one input to the rapporteur's file, next to the industry associations that will lobby the committee directly.

So the honest reading of 40 responses is not that nobody cares about EPREL. Most came from associations with offices in Brussels, which will also take their case to the Parliament committee directly; the feedback is where they put their position on record.

What happens next, and when

The proposal now follows the ordinary legislative procedure. The Parliament assigns a lead committee and a rapporteur; the Council works in a preparatory body under the rotating presidency. There is no statutory deadline for either. For a technical file of this size, a first reading agreement within a year is a normal expectation and nothing more than that.

Three things to watch, in order of how much they would change for a passport builder:

• Whether Article 12(13) survives as a duty on the Commission, or is softened into an aspiration. If it survives, the model-level EPREL record becomes the anchor for energy-labelled products, and the passport is the item-level layer on top.
• Whether anyone reopens the ESPR exclusion. The Commission chose not to; a committee amendment could. That would be the first real test of the "Brussels will soften it" theory, and the place to look is the amendments table, not the press.
• Whether the model-level, item-level wording stays. It is the same distinction that decides whether you publish one passport per product line or one per unit, and it is currently written into a legislative proposal rather than only into a standard.

What did change in the meantime

The omnibus has stood still since June; the passport around it has not. Over the summer and early autumn, the Commission issued version 2.0 of the battery passport data point guidance, the recycled content methodology went out for feedback and closed with 70 responses, the packaging labelling act entered the register with a missed deadline behind it, and the first ESPR product delegated act, for iron and steel, closed its public consultation with 142 responses and is still waiting for a published draft. None of that was slowed by a file that excludes ESPR.

That is the practical answer to the strategy this article series started with. The simplification process is real and it is producing texts. The texts are about labels, registrations and Energy Star. The passport obligations for batteries in February 2027 and for the sectors that follow are being written in parallel, on their own clock.

What this is not

This is not a decision. The proposal is a proposal until the Parliament and the Council adopt it, and it can still change in every article.

This is not a passport act. The file amends two labelling regulations and touches the passport only where EPREL meets the registry. Data fields, access rights and deadlines for product passports are elsewhere.

This is not the end of the feedback trail. Every delegated act under ESPR gets its own four-week window when the draft is published, and those are the ones where a small number of responses has visibly shaped the text.

How to check this yourself

Entry 16872 in the Commission register of initiatives: https://ec.europa.eu/info/law/better-regulation/brpapi/groupInitiatives/16872?language=EN. The JSON lists every publication step with its feedback count; the human-readable page on Have Your Say shows the responses themselves. For the legislative procedure, search the Parliament's Legislative Observatory for the COM number.

What to do this week

• If you sell energy-labelled products, treat your EPREL model record as the future passport anchor. Check that it is complete and that the person who maintains it knows the passport will hang off it.
• If you sell textiles, furniture or anything without an energy label, take nothing from this file. Your dates come from the sector delegated act and the 18-month application period after it.
• If you wrote in, keep your text. The same arguments will be needed, in shorter form, when the sector acts open their own windows.

FAQ

Łukasz Głuch

Builds DPPera, a digital product passport tool for small and medium-sized companies. Reads the delegated acts so you do not have to. Writes about what he checked in the registry, not about what vendors promise.

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