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This policy update highlights a key challenge for companies preparing for Digital Product Passports under the Ecodesign for Sustainable Products Regulation (ESPR): aligning two timelines that run in parallel.
On one side, the European Union is advancing the regulatory framework. The adoption of the Delegated Act defining the Digital Product Passport Registry is expected in early 2026, followed by product-specific delegated acts for sectors such as fashion and textiles in 2027.
On the other side, brands must follow their own operational preparation timeline. Implementing Digital Product Passports requires defining scope, mapping product data, setting governance structures, integrating internal systems, and testing workflows before full deployment.
These steps take time. The transition window currently indicated for compliance is around 18 months after the adoption of the sector-specific delegated act. The graphic illustrates why waiting for final legislative adoption does not create additional preparation time. Instead, companies that start structuring their product data and systems earlier are better positioned to meet regulatory requirements without operational disruption.
Understanding these two timelines — policy and implementation — is essential for building a realistic roadmap toward Digital Product Passport readiness.