Answers / ESPR (Ecodesign)
When Is a Digital Product Passport Required Under ESPR?
Do we need a digital product passport for our products from 2026?
Only once a delegated act for your product group requires one. Under Article 9 of Regulation (EU) 2024/1781 a product needs a digital product passport only where the delegated act under Article 4 for that product group says so, and that act sets the data and the data carrier. The registry rules in Implementing Regulation (EU) 2026/1778, in force since 6 August 2026, organise registration; they do not by themselves require a passport.
What the Act Says
- Article 9(1) and (2)
- A passport is required by the applicable delegated act, which sets its content and level (model, batch or item).
- Article 13(1)
- The Commission had to set up the registry by 19 July 2026.
- Implementing Regulation (EU) 2026/1778
- In force on 6 August 2026, the twentieth day after publication (Article 24).
- Working plan COM(2025) 187
- Indicative adoption years, for example iron and steel 2026, aluminium 2027, motors and drives 2028.
What to Do
- Find your product group in the working plan and its indicative year.
- Start structuring product data now; the passport content comes with the delegated act.
Sources
- Regulation (EU) 2024/1781 (ESPR) (CELEX 32024R1781)
- Implementing Regulation (EU) 2026/1778 (passport registry) (CELEX 32026R1778)
- COM(2025) 187 final, ESPR working plan 2025 to 2030
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