Insights / 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
Last checked against the act text on 2026-10-20. For information only, not legal advice.