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Digital Product Passport requirements under ESPR are defined progressively through delegated acts, with timelines and scope varying by product group.
This article reflects the current status and is updated as new regulatory developments are released. Last updated: April 2026
The Ecodesign for Sustainable Products Regulation (ESPR) defines the framework for Digital Product Passports.
But it does not define how they apply to specific products.
Delegated acts define how those requirements apply to specific products, setting the scope, data requirements, and conditions for implementation across sectors.
While ESPR is now in force, most delegated acts are still under development.
This is where the current uncertainty sits, as implementation continues to take shape over time.
This article provides a clear view of their role, current status, and what to expect next.
What are ESPR delegated acts
Delegated acts are the mechanism through which the European Commission defines how a regulation applies to specific products and requirements.
Under ESPR, they establish product-specific requirements, including:
- which products require a Digital Product Passport
- what information must be provided
- how performance and sustainability criteria are assessed
Rather than introducing new legislation, delegated acts build on existing regulation to define how it is applied in practice.
How delegated acts evolved
Delegated acts have been central to ESPR from its early development, but their scope and rollout have evolved over time.
Initial discussions focused on extending ecodesign requirements beyond energy-related products, with limited clarity on how Digital Product Passports would be implemented.
Over time, this developed into a broader framework covering product performance and product information, with the Digital Product Passport positioned as a central mechanism for making that information accessible.
The publication of the ESPR Working Plan 2025–2030 marks a shift from concept to implementation.
It defines priority product groups and confirms that requirements will be introduced progressively through delegated acts, rather than all at once.
Current status of ESPR delegated acts
Delegated acts under the Ecodesign for Sustainable Products Regulation (ESPR) are not yet fully defined. What exists today is a structured rollout plan, rather than a complete set of requirements.
The European Commission has published the ESPR Working Plan 2025–2030, which identifies the first priority product groups for which delegated acts will be developed: steel and aluminium, textiles (with a focus on apparel), furniture, tyres, mattresses, as well as a number of energy-related products continuing from previous ecodesign and energy labelling work.
In parallel, the Working Plan introduces horizontal requirements that will cut across product groups. These include measures on repairability, such as the introduction of a repairability score, and requirements related to the recyclability of electrical and electronic equipment.
For each product group, delegated acts are expected to define performance and product information requirements, including whether a Digital Product Passport applies and what information it must contain.
Where relevant, this information will be made available through the Digital Product Passport, or through EPREL for energy-related products subject to energy labelling.
At this stage, most delegated acts are still under development. According to the European Commission, they are being prepared through preparatory studies, impact assessments, and stakeholder consultation processes, including the Ecodesign Forum, before formal adoption.
The Working Plan does not define requirements itself, but sets the priority product groups and timeline for the development of delegated acts.
Timeline of delegated acts under ESPR
Delegated acts under ESPR are being introduced progressively, following a phased regulatory timeline.
2024: adoption of the Ecodesign for Sustainable Products Regulation (ESPR), establishing the legal framework for product-level requirements and Digital Product Passports
2025: publication of the ESPR Working Plan 2025–2030, defining priority product groups and confirming the progressive rollout of delegated acts
From 2026 onwards, delegated acts are expected to be introduced progressively, with different timelines depending on the product group:
- 2026: first delegated acts expected for initial product groups, including iron and steel, where technical definitions and data structures are more advanced
- 2027: expansion to textiles and apparel, alongside early implementation phases for product-level Digital Product Passport requirements
- 2027–2028: delegated acts expected for furniture, tyres, and mattresses, reflecting more complex product structures and supply chains
- 2027 onwards: progressive implementation of Digital Product Passport obligations, depending on product category and regulatory scope
- 2028–2030: further rollout across additional product groups and alignment with broader ecodesign and energy labelling frameworks
These timelines are indicative and depend on the outcome of preparatory studies, standardisation work, and regulatory adoption processes.
What delegated acts will define
Delegated acts define how ESPR requirements apply in practice at product level.
What changes from one delegated act to another is the level of specificity.
Each product group is defined through a specific set of data points, calculation methods, and conditions that reflect how that product is manufactured, used, and circulated.
This is where differences across sectors become visible.
Requirements for textiles, for example, will not mirror those for electronics or furniture, because the underlying materials, supply chains, and environmental impacts are fundamentally different.
In practice, compliance is no longer defined at a general level, but through product-specific configurations that need to be maintained over time.
How delegated acts are structured
Each delegated act includes:
- the scope, defining which products are covered
- product-specific requirements, including performance and sustainability criteria
- data requirements, specifying what information must be provided at product level
- methods and metrics, used to calculate and verify compliance
- obligations for economic operators, assigning responsibilities across the value chain
These elements are typically detailed in annexes, where parameters, thresholds, and calculation rules are specified.
This is where requirements become measurable and directly applicable.
Delegated acts beyond product categories
Delegated acts related to DPP are not limited to defining requirements for product groups.
They are also used to establish the technical and operational components that enable Digital Product Passports to function. This includes:
- the EU DPP Registry, defining how products are registered, referenced, and made accessible across the system
- data carriers, such as QR codes or NFC, specifying how the passport is accessed from the physical product
- technical standards and interoperability requirements, including how data is structured, exchanged, and accessed across systems
- requirements for DPP service providers, including how third-party platforms manage, process, and make product data available
These elements are defined through dedicated delegated acts and implementing legislation, and form the infrastructure that enables Digital Product Passports to function across the EU market.
What this means for companies
As delegated acts are introduced, compliance shifts to product-level implementation.
Information can no longer be created on request. It needs to exist as structured, product-level data maintained over time.
This affects how companies manage:
- product data, defined consistently across systems
- supply chain information, traceable and linked to the product
- internal responsibilities, with multiple teams contributing to the same dataset
Requirements will not apply uniformly.
Each product category will be subject to a specific set of rules, requiring different data, calculations, and verification methods.
Compliance is no longer a reporting exercise.
It becomes an operational system integrated into how products are developed, sourced, and managed.
Delegated Acts beyond ESPR
Beyond ESPR, delegated acts are used across multiple EU regulations with different roles.
Under the Batteries Regulation (EU) 2023/1542, they define requirements on sustainability, performance, labelling, and the battery passport.
Under the Construction Products Regulation, they define harmonised technical specifications and performance requirements.
In sectors such as toys or chemicals, product requirements are defined through other legal instruments, with a more limited use of delegated acts.
What to monitor next
Delegated acts will define how Digital Product Passport requirements apply in practice, but they will not be introduced all at once.
Each product group will follow its own timeline, with requirements developed, published, and enforced progressively.
This means that the regulatory landscape will continue to evolve, with new obligations introduced over time.
For companies, the challenge is not only to understand the framework, but to stay aligned as requirements become more specific and product-level implementation is defined.
Tracking these developments is critical, as each delegated act introduces new requirements that directly impact how products are managed and brought to market.
👉 Explore Renoon’s DPP Newstracker to stay aligned with Digital Product Passport delegated acts and understand how they apply to your products.
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