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This update highlights a key challenge for companies preparing for the Digital Product Passport: aligning two timelines that move in parallel.
On one side, the European Union is progressing with the regulatory framework. The adoption of the delegated act defining the Digital Product Passport Registry is expected in the second quarter of 2026, followed by sector-specific delegated acts, including fashion and textiles, expected in 2027.
On the other side, companies must follow their own operational timeline. Implementing the Digital Product Passport requires defining scope, mapping product data, establishing governance, integrating internal systems, and validating processes before large-scale rollout.
These activities require time. The transition window currently indicated for compliance is approximately 18 months from the adoption of the sector-specific delegated act.
The graphic illustrates why waiting for formal regulatory adoption does not create more time for preparation. Companies that begin structuring data and systems early are the ones that will be able to align with regulatory timelines without compressing implementation into the final months.
The introduction of the Digital Product Passport under the ESPR shifts compliance from documentation to structured product data management. Companies are required to manage product-level information across systems, supply chains, and customer-facing channels.
This requires aligning data, systems, and responsibilities across functions such as IT, product, compliance, and supply chain, while integrating existing infrastructures like ERP, PLM, and e-commerce platforms.
The ESPR timeline makes it clear that the Digital Product Passport will become a requirement for accessing the European market. Delaying preparation concentrates complex activities such as data structuring, system integration, and internal alignment into a limited timeframe.
Starting early allows companies to build a structured and scalable foundation, reducing operational risks and ensuring higher data quality over time.
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