Three industries told the passport does not concern them. All three have a deadline
A list circulates in the Polish market of industries the digital product passport supposedly will never touch. It usually reads: cosmetics, saunas, household appliances, lighting, toys, coffee. Three entries on that list do have a deadline. We know this well, because we copied the list into our own material and had to walk it back.
Where the list comes from
Not from the law. From the sales material of vendors serving unregulated industries who want to show whose logos they already have. That is reasonable on their part and it is not a lie: a sauna maker really can buy a passport today with no obligation at all. The trouble starts when such a list travels onward and begins to be read as a list of regulatory exemptions.
We checked every entry against the ESPR working plan and the sectoral legislation table in the Commission FAQ. Three turned out to be wrong.
Household appliances: these are energy-related products
The ESPR working plan for 2025-2030 lists energy-related products as a separate group, with acts spread across 2026-2029. Household appliances fall into that category by definition, because they consume energy and have been subject to ecodesign for years.
That means two things at once. First, a washing machine manufacturer is not in the same position as a sauna maker, even though many lists put both in one bucket marked "no deadline". Second, the acts for this group are spread over four years, so a specific subgroup may get its date earlier or later, and the check has to be done per product category rather than per industry.
Lighting: exactly the same story
Lighting is a textbook energy-related product and one of the first categories ecodesign ever covered, well before ESPR. Placing it on a list of industries with no obligation is simply a misreading of the working plan.
It is worth saying plainly for another reason too: lighting manufacturers usually have a better starting position than they think. Much of the data a passport will ask for already exists in their ecodesign documentation and product datasheets.
Toys: their own regulation, their own date
Toys are not in the ESPR working plan, which is why they drop out of every list copied from that document. They do, however, have their own regulation with a passport. The sectoral legislation table in the Commission FAQ gives two dates: the regulation applies from 1 August 2030, while the passport delegations apply from 1 January 2026.
Those two dates get confused, and they mean different things. The first is when the regulation starts applying to products. The second is when the Commission may issue acts concerning the passport. A toy manufacturer told "this does not concern you" is being given false information, just on a different timeline from the ESPR industries.
The detailed scope, meaning which toys and which fields, cannot be stated today because delegated acts will settle it. So we write only what is known and say plainly where our knowledge stops.
What is left on the "no deadline" list
With three wrong entries removed the list gets shorter, but it becomes true. Cosmetics, saunas and spas, interior furnishings are not in the first working plan and have no deadline today. They may enter the next cycle, but nobody knows that today.
One group stands apart, without even that uncertainty. Food and feed are excluded from the scope of ESPR outright, in article 1(2) of the regulation. That is not "not yet", it is "no". Nobody honest will tell a coffee roaster that regulation will eventually catch up with their industry.
We set out both lists in full, the working plan one and the sectoral one, in our piece on where DPP categories come from.
Why we are correcting our own error in public
Because the mistake ran in the worst possible direction. Telling someone they are covered when they are not costs one deal and some embarrassment. Telling someone they are not covered when they are costs them their deadline.
Our entire job is telling a customer what they do not have to do. The exemption list is the single most important sentence in that job, and it has to come from the law or from a Commission document, never from a competitor brochure. That rule has applied here since the day this error surfaced.
How to check your own industry in five minutes
- Start with the energy question. If your product draws electricity, gas or fuel, it is almost certainly an energy-related product and it is in the working plan, even if it has no separate row in any table.
- Check whether you have your own regulation. Toys, construction products, packaging and critical raw materials have passports outside ESPR. If your product falls under one of them, the ESPR working plan is not your table.
- Add eighteen months to every act adoption date. Only that number belongs in a production plan or a conversation with your label supplier.
- Ask your vendor for the source. If a date comes without an initiative reference or a pointer to a Commission document, it is not a regulatory calendar, it is a slide.
FAQ
Do household appliances have a passport deadline already?
The energy-related products group is in the working plan with acts across 2026-2029. The specific date for a specific product category depends on the delegated act for that subgroup, and presence in the plan does not yet automatically create an obligation.
From exactly when do toys need a passport?
The regulation applies from 1 August 2030, while the passport delegations apply from 1 January 2026. The scope of fields will be settled by delegated acts that do not yet exist.
My vendor says my industry is exempt. How do I verify that?
Ask them to point at the provision or the Commission document. Exemption from ESPR follows from article 1(2) and covers food and feed among others. Absence from the working plan is not the same as an exemption.
Are cosmetics definitely without a deadline?
They are not in the first ESPR working plan and have no deadline today. That is not a statutory exemption, though, so the next working plan cycle could change it.
Is a passport worth doing if I have no deadline?
Sometimes, but for a different reason than compliance: instructions and certificates behind the code, proof of origin against cheap imports, fewer repetitive phone calls. If none of those apply to you, do not do it.