Passport deadlines
Batteries first, on 18 February 2027, in the Battery Regulation. Textile act expected 2027, obligation from 2029. Every other product group has its own act and its own clock.
As of 21 October 2026. This guide is general information, not legal advice.
The Ecodesign for Sustainable Products Regulation has been in force since 18 July 2024. On its own it makes nobody issue a passport. It is a framework: for each product group, a delegated act sets the passport's contents, the data carrier on the product, and the day the passport becomes required. Until that act is published, the group has no passport obligation. So there is no single date, only a date per group, each given as it stood on the as-of date shown above.
Batteries
The first hard deadline comes from the Battery Regulation, Regulation (EU) 2023/1542, which requires a battery passport from 18 February 2027 for electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh. The date sits in the regulation itself and does not wait for any further act. It reaches companies that only import or install batteries, not just the ones that make them. Whether a given battery needs a full passport or only a QR code depends on its type, as reported. One act is still missing: the implementing act on who may read the restricted parts of a battery passport was due on 18 August 2026 and, as reported, has not been adopted. The 2027 date does not depend on it.
Textiles
The Commission's working plan lists the textile delegated act for adoption in the third to fourth quarter of 2027. After adoption comes a transition of at least eighteen months before the obligation applies. Put together, the timeline reads: textile act expected 2027, obligation from 2029. Two points remain open: whether a textile passport will be per model, per batch or per item, and the exact day, which cannot be fixed until the act is adopted. A different and older rule already applies to textiles: the ban on destroying unsold apparel, clothing accessories and footwear for large companies, since 19 July 2026, as reported.
Footwear
Shoes have no passport date. The Commission's working plan for 2025 to 2030, adopted on 16 April 2025, leaves footwear out of its priority groups and treats it as a category of its own, apart from textiles, because the materials, the uses and the supply chains differ. It orders a study on footwear under the ecodesign regulation, due by the end of 2027. As reported, that study will decide whether footwear joins the next plan, for 2030 to 2035, the earliest point at which a footwear act, and with it a passport, could follow. A shoe brand still has rules to follow today: the material label of the Footwear Labelling Directive, 94/11/EC, and the ban on destroying unsold footwear described above. From 17 April 2028, every member state must also run a producer responsibility scheme for textile and footwear products under Directive (EU) 2025/1892, and a brand placing shoes on a national market pays into that scheme.
The other groups
The Commission's working plan gives indicative adoption years, and they are years for the act, not for the obligation: iron and steel in 2026; textiles and apparel, tyres, aluminium and ICT in 2027; furniture in 2028; mattresses and energy-related products in 2029. Those years are reported from the plan, not from published acts. Construction products run under a separate regulation, in force since January 2025, which introduces a mandatory passport for listed products, as reported.
A delegated act is the moment a framework becomes a deadline; until it is published, a product group has a plan but no date.
Registry, customs and standards
Parts of the system are already in place whatever your product group. The EU DPP Registry has been live since 20 July 2026; it is an index of passports, not a store of them, and The EU DPP Registry explains who registers and the data it holds. Customs will check electronically, before releasing an imported product into free circulation, that it has a valid registered passport and that the commodity code was provided, once the product's group is covered. And the passport standards are there, eight published by CEN-CENELEC, six cited in the Official Journal, two awaiting citation, so the technical shape of a passport is no longer a guess; The passport standards lists them.
Preparation before the act
The act will set the fields and the data carrier. Your identifiers, your supplier data and your packaging are yours to sort out, and they take the longest. The data a passport is expected to hold, listed in Passport contents, mostly sits with suppliers in spec sheets, so the collection starts long before the obligation. Your identifiers can be put in order now, and GTIN, SGTIN or batch explains the choices. The choice between model, batch and item identity can be made on your own terms now, and changed later if the act asks for more.
On Next Horizon the passport is built from the shipping you already do: the identifier is allocated at the purchase order, and each later event (receipt, label, delivery, return) is written to the item's record. That is how we keep a passport complete without running a separate project; the law itself asks for less. Item-level serialisation, event logs and tiered access are our method for building a passport, never a legal requirement; the law asks for the data, in an open, interoperable format, reachable from the product.
Questions we get asked.
Is there any passport obligation for clothing today?
No. The textile delegated act is expected in 2027 and the obligation from 2029. Clothing today falls under the ban on destroying unsold goods for large companies, as reported, the packaging regulation, and the rules on claims reported to apply since 27 September 2026.
Do shoes need a passport?
No act requires one and none is announced, since footwear sits outside the 2025 to 2030 working plan. The data a shoe passport would carry, the material of each part and its recycled content, is close to the data producer responsibility schemes use to set fees, and France's scheme already adjusts footwear fees for certifications and for features that hinder recycling, as reported. Collecting it now serves the fees and any future passport at once.
We sell into France from outside the EU. Does this reach us?
Yes. ESPR covers products placed on the EU market, wherever the company is based, and the Registry's customs check is designed for imports.
Our products have no battery. Why does everyone mention February 2027?
Because it is the first passport deadline that is written in a published regulation, so it is the date people can point to. It does not reach a fashion or furniture brand.
Do we have to serialise every item to comply?
Not as a general rule. For textiles, the level of uniqueness, model, batch or item, is not set yet. Serialising each item is how we build a passport that stays complete through returns and repairs. If your group's act asks only for model or batch identity, that level is all you need.
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