CirculeID

Solutions

Start with the product group the deadline reaches first

Digital Product Passports arrive category by category, through delegated acts, each with its own data requirements and its own lead time. Find yours, and what a passport for it has to contain.

Batteries
February 2027
ESPR groups
Phased 2026–2030
Lead time
≈18 months

Definition

Which products will need a Digital Product Passport?

Digital Product Passports become mandatory product group by product group under the EU Ecodesign for Sustainable Products Regulation, phased from 2026 to 2030. Batteries above 2 kWh are covered separately from February 2027. Iron and steel, textiles, electronics and furniture are among the earliest groups expected to be addressed.

Each group is defined by its own delegated act under the ESPR, which sets the fields that group must carry and allows roughly eighteen months before enforcement. Batteries are governed by the EU Battery Regulation and already have a fixed date.

By product group

What each category has to prove

The same passport model, with a different required field set per group. These are the categories where the requirement is clearest today.
Product groups, the instrument that covers them, and the data each one turns on
Product groupInstrumentThe data it turns on
Batteries and EVBattery Regulation (EU) 2023/1542Chemistry, state of health, recycled content, carbon footprint, due diligence
Textiles and apparelESPR (EU) 2024/1781Fibre composition, sourcing, durability, repair and take-back routes
Electronics and ICTESPR, WEEE 2012/19/EU, RoHSSubstances of concern, spare parts, repairability, recovery instructions
Luxury goodsESPR (EU) 2024/1781Provenance, authenticity, materials, and identity that survives resale
Furniture and timberESPR, EUDR (EU) 2023/1115Plot-level geolocation for timber, durability, disassembly and material recovery
Cosmetics and packagingPPWR (EU) 2025/40Ingredient transparency, packaging recyclability and recycled-content thresholds

Answers

Frequently asked questions

Which product group needs a Digital Product Passport first?

Batteries are first with a fixed date: the EU Battery Regulation (EU) 2023/1542 requires a battery passport for LMT, EV and industrial batteries above 2 kWh from February 2027. Under the ESPR (EU) 2024/1781, iron and steel are expected to be the first product group covered by a delegated act, with textiles among the early priorities.

Does a Digital Product Passport differ by industry?

The data model does not; the required fields do. Every passport shares the same identity, event and credential layers, and each delegated act specifies which fields that product group must carry. That is why CirculeID maps your data to a CIRPASS-aligned model rather than to a per-industry form that a new act would invalidate.

We sell outside the EU. Does this apply to us?

It applies to products placed on the EU market, regardless of where they are made or where the company is domiciled. A manufacturer in another region supplying an EU brand is generally the party holding the data the passport needs, which is why suppliers are usually brought into a passport programme early.

Who is responsible for the passport in a supply chain?

The economic operator placing the product on the EU market is responsible, which is normally the brand or importer. Suppliers contribute evidence rather than owning the passport, and CirculeID signs each contribution as a Verifiable Credential so the responsible party can show where every claim came from.

Next step

Find out which of your products are in scope

Send us one product group. We will tell you which instrument reaches it, when, and which fields your existing data already covers.

Index