DPP categories come from two different laws. Almost nobody separates them
Almost every list of "industries covered by DPP" you will find at a vendor is copied from one document: the ESPR working plan. It is a good document and a bad list, because in the EU the digital product passport arises from two independent sources of law, each with its own scope, its own dates and its own logic. Here are both, side by side, with one sentence from the Commission that nobody quotes.
Three steps that must not be confused
Before you look at any deadline table, it helps to know that every category goes through the same three stages, and only the last one matters for your production.
- The legal framework. ESPR has applied since 18 July 2024 and the central DPP registry has been live since 20 July 2026. That is done and it is not your deadline. This is where most trade coverage goes wrong.
- The delegated act. The Commission adopts detailed rules for your category: what data, what granularity, what carrier. The dates in both tables below describe this step.
- Enforcement. At least eighteen months after the delegated act. This is the date that matters for production and for labels. Your real deadline is the act plus the transition period, never the act alone.
Source one: the ESPR working plan 2025-2030
The working plan adopted on 16 April 2025 sends ten product groups into the pipeline. The dates below are indicative dates for adoption of the act, given by the Commission itself in its digital product passport FAQ.
- Iron and steel - act expected in the fourth quarter of 2026, consultation closed 12 August 2026. Obligations around 2028.
- Energy-related products - acts spread across 2026-2029, group by group. The most frequently omitted entry on the whole list, and it covers household appliances and lighting among others.
- Textiles, particularly apparel - act expected in 2027. It has sat in the register of initiatives since 18 December 2025 without reaching a feedback stage. Obligations around 2028-2029.
- Tyres - act expected in 2027, obligations around 2028-2029.
- Aluminium - act expected in 2027, obligations around 2028-2029.
- Furniture - act expected in 2028, obligations around 2029-2030.
- Mattresses - act expected in 2029, obligations around 2030-2031.
- ICT products - act expected in 2029, obligations around 2030-2031. The second entry missing from most lists.
- Footwear - excluded for now, study due by the end of 2027, decision in the next cycle.
- Chemicals - excluded from the first working plan.
The Commission sentence no vendor quotes
In its FAQ the Commission states plainly that the presence of a product group in the working plan does not automatically mean a passport obligation. It means referral to a study and an impact assessment, which will then determine whether a DPP is the right instrument for that category and what the compliance date will be.
That sentence is inconvenient for anyone selling passports, so it disappears from the slide deck. We repeat it, even though it would be more convenient to present the table above as a list of deadlines. A list of study referrals and a list of obligations are not the same document and not the same conversation with a board.
Source two: sectoral regulations
This is the part you will not find in vendor material, because it spoils the simple story that ESPR equals DPP. Several regulations introduce their own passports, outside ESPR and independently of the working plan. The state of play below comes from the sectoral legislation table in the Commission FAQ, dated January 2026.
- Batteries, regulation (EU) 2023/1542. First mandatory passports from 18 February 2027. The only certain date in the whole landscape and the only one that comes from an adopted rule rather than a plan.
- Construction products, the construction products regulation. Passport eighteen months after a future delegated act.
- Critical raw materials, CRMA. Passport data around the end of 2028.
- Packaging, PPWR. From August 2028 or later.
- Toys. The regulation applies from 1 August 2030, while the passport delegations apply from 1 January 2026. Two different dates, and confusing them is a common error.
- Detergents. The act is awaiting signature.
Both lists together give sixteen entries. A typical vendor list has four or eight, because it was produced by copying the ESPR table and dropping everything with a different legal basis.
A third possibility: you are on neither list
Most products sold in Poland have no passport deadline and may never have one. 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, and anyone claiming otherwise is selling fear.
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", and nobody honest will tell a coffee roaster that regulation will eventually catch up with them.
We write this because it is information nobody will pay us for. A QR code with a product page can still make commercial sense and takes about a minute to build. Just do not call it a compliance passport and do not sell it against a deadline that will not arrive.
How to check this yourself
Every entry on both lists can be verified in the Commission public register of initiatives. The query looks like this:
https://ec.europa.eu/info/law/better-regulation/brpapi/searchInitiatives?text=ecodesign&size=10&language=EN
Two things in the response matter: the stage the act has reached and the number of responses collected. This is the primary source, maintained by the Commission itself. Intermediary blogs copy it late and without the stage, which is why "consultation open" and "act adopted" look identical in their coverage. It is how we check every date in our deadline calendar.
What to do with this in practice
- Check both lists, not one. If your product is packaged, contains critical raw materials or is a toy, your legal basis may be entirely different from ESPR even when your product category also sits in the working plan.
- Count from the act, not from today. Add at least eighteen months of transition to every act adoption date. Only that number belongs in an investment plan.
- Do not plan from a single vendor table. Ask for the source of every date. If there is no initiative reference and no pointer to a Commission document, it is not a regulatory calendar, it is sales material.
FAQ
How many categories have a passport deadline today?
Ten groups in the ESPR working plan and six entries from sectoral regulations, sixteen in total. Only one of them, batteries, has a certain date coming from an adopted rule.
Why do different sources give different numbers of industries?
Because most of them cite only the ESPR working plan and omit the sectoral regulations. Many also drop energy-related products and ICT products, which are in the plan but rarely discussed.
Does presence in the working plan mean my product will get a passport?
No. The Commission states plainly that it means referral to a study and an impact assessment, which will then determine whether a passport is the right instrument for that category.
My product falls into two categories at once. Which one applies?
If the product is covered by a sectoral regulation with its own passport, that regulation governs the data scope for it. Where bases overlap, wait for the delegated act for your group, because only that defines the fields.
Will food eventually get a passport?
Not under ESPR. Food and feed are excluded from the scope of the regulation outright, in article 1(2).