--- title: "DPP and EU regulation timeline" description: "A living timeline of the digital product passport and the EU regulations behind it: the battery passport, the ESPR category waves, the GPSR application date and the PPWR milestones, each dated, sourced and anchored." type: "timeline" url: "https://www.conphora.com/research/dpp-timeline/" markdown: "https://www.conphora.com/research/dpp-timeline.md" locale: "en" language: "en" updated: "2026-08-12" author: "Conphora compliance team" publisher: "Conphora" license: "Free to quote with attribution and a link to the page" --- # DPP and EU regulation timeline > A living timeline of the digital product passport and the EU regulations behind it: the battery passport, the ESPR category waves, the GPSR application date and the PPWR milestones, each dated, sourced and anchored. ## 2024-02-18 — Batteries Regulation starts to apply - **Regulation:** Regulation (EU) 2023/1542 (BattR) - **Scope:** All batteries placed on the EU market - **Status:** in-force - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20250731 The Batteries Regulation applies from 18 February 2024 to every battery placed on the EU market, save for provisions with their own dates. Conformity assessment and the duties of manufacturers, importers, distributors and fulfilment providers (Art. 17, Chapter VI) follow on 18 August 2024; producer responsibility (Chapter VIII) on 18 August 2025, when Directive 2006/66/EC is repealed. Article 96(2) sets the general application date and the staggered dates for Article 11 (18 February 2027), Article 17 and Chapter VI (18 August 2024) and Chapter VIII (18 August 2025). Article 95 repeals the Batteries Directive with effect from 18 August 2025. ## 2024-07-18 — Ecodesign for Sustainable Products Regulation in force - **Regulation:** Regulation (EU) 2024/1781 (ESPR) - **Scope:** Framework for physical goods; product rules come by delegated act - **Status:** in-force - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1781 The ESPR entered into force on 18 July 2024, twenty days after publication, and repeals the Ecodesign Directive 2009/125/EC from the same day with transitional provisions. It is the legal basis for the digital product passport, but obligations for a product group only start when the Commission adopts the delegated act for that group. Article 80 sets entry into force on the twentieth day after publication in the Official Journal (28 June 2024). Article 79(1) repeals Directive 2009/125/EC with effect from 18 July 2024, keeping listed articles alive for existing ecodesign measures. ## 2024-12-13 — General Product Safety Regulation applies - **Regulation:** Regulation (EU) 2023/988 (GPSR) - **Scope:** Consumer products; all economic operators and online marketplaces - **Status:** in-force - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0988 From 13 December 2024 the GPSR applies to every consumer product placed or made available on the EU market and repeals Directives 2001/95/EC and 87/357/EEC. Manufacturers, importers, distributors, fulfilment service providers and online marketplaces must meet its safety, responsible-person, traceability, accident-reporting and recall duties. Article 52 sets entry into force on the twentieth day after publication (OJ L 135, 23 May 2023) and application from 13 December 2024; Article 50 repeals the two directives with effect from the same day. ## 2025-02-11 — Packaging Regulation enters into force - **Regulation:** Regulation (EU) 2025/40 (PPWR) - **Scope:** All packaging placed on the EU market and packaging waste - **Status:** in-force - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040 Regulation (EU) 2025/40 on packaging and packaging waste entered into force on 11 February 2025, twenty days after publication in the Official Journal on 22 January 2025. Its obligations apply from 12 August 2026, with later dates for harmonised labelling (2028), recyclability, recycled content, format restrictions and re-use (2030). ## 2025-07-31 — Battery due diligence postponed to 2027 - **Regulation:** Regulation (EU) 2025/1561 (BattR) - **Scope:** Economic operators placing batteries on the market - **Status:** in-force - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1561 Regulation (EU) 2025/1561 entered into force on 31 July 2025, the day after publication, and replaced the dates in Article 48 of the Batteries Regulation: battery due diligence obligations now apply from 18 August 2027 instead of 18 August 2025, and the Commission's due diligence guidelines are due by 26 July 2026 instead of 18 February 2025. ## 2025-12-26 — EUDR postponed again and simplified - **Regulation:** Regulation (EU) 2025/2650 (EUDR) - **Scope:** Operators and traders of cattle, cocoa, coffee, palm oil, rubber, soya, wood - **Status:** in-force - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2650 Regulation (EU) 2025/2650 entered into force on 26 December 2025, three days after publication. It moves the EUDR application dates to 30 December 2026 and 30 June 2027, adds the downstream-operator role and a one-time simplified declaration for micro or small primary operators, and orders a Commission simplification review by 30 April 2026. This is the second postponement: Regulation (EU) 2024/3234 (in force 26 December 2024) had first moved the dates to 30 December 2025 and 30 June 2026. The Commission delivered the simplification review as report COM(2026) 191 on 4 May 2026, without a legislative proposal, together with a draft delegated act on the product scope. ## 2026-01-01 — Toy Safety Regulation enters into force - **Regulation:** Regulation (EU) 2025/2509 (TSR) - **Scope:** Toys for children under 14; manufacturers, importers, distributors - **Status:** in-force - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2509 The Toy Safety Regulation entered into force on 1 January 2026, twenty days after publication on 12 December 2025. From that date only Articles 28 to 44 (notified bodies) and 49 to 55 (delegated and implementing acts, committee, confidentiality, penalties) apply; the product requirements, including the toy digital product passport, apply from 1 August 2030. ## 2026-07-19 — Commission sets up the DPP registry - **Regulation:** Regulation (EU) 2024/1781 (ESPR) - **Scope:** European Commission; unique identifiers of every digital product passport - **Status:** in-force - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1781 By 19 July 2026 the Commission had to set up the digital registry that stores at least the unique identifiers of digital product passports (Art. 13(1) ESPR). The registry is the backbone of every ESPR passport and also receives the unique identifier of each battery passport, which the operator must upload under Art. 77(10) of the Batteries Regulation. ## 2026-08-12 — Packaging Regulation applies - **Regulation:** Regulation (EU) 2025/40 (PPWR) - **Scope:** Manufacturers, importers, distributors and fillers of packaging - **Status:** in-force - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040 From 12 August 2026 the PPWR applies and Directive 94/62/EC is repealed, save for listed provisions that live on for a transition. Packaging placed on the market must meet the regulation's requirements and conformity rules; the dated obligations on harmonised labelling (2028), recyclability, recycled content, format restrictions and re-use (2030) follow. Article 71: the regulation applies from 12 August 2026, except Article 67(5), which applies from 12 February 2029. Article 70(1) repeals Directive 94/62/EC from 12 August 2026 with exceptions running to 31 December 2028 and 31 December 2029. ## 2026-12-09 — New Product Liability Directive applies - **Regulation:** Directive (EU) 2024/2853 (PLD) - **Scope:** Products placed on the market or put into service from this date - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L2853 Member States must bring the laws implementing Directive (EU) 2024/2853 into force by 9 December 2026. Directive 85/374/EEC is repealed with effect from the same day but continues to apply to products placed on the market or put into service before it, so the new liability regime covers products placed on the market from 9 December 2026. ## 2026-12-30 — EUDR applies to large and medium operators - **Regulation:** Regulation (EU) 2023/1115 (EUDR) - **Scope:** Operators, downstream operators and traders, except micro and small operators - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 From 30 December 2026 Articles 3 to 13, 16 to 24, 26, 31 and 32 of the Deforestation Regulation apply: relevant products may only be placed on the EU market or exported if they are deforestation-free, legally produced and covered by a due diligence statement. The EU Timber Regulation (EU) No 995/2010 is repealed the same day. Article 38(2) as amended by Regulation (EU) 2025/2650. Micro and small operators established by 31 December 2024 get until 30 June 2027 (Art. 38(3)), except for products already covered by the EU Timber Regulation. Regulation (EU) No 995/2010 keeps applying until 31 December 2029 to timber produced before 29 June 2023 (Art. 37(2)). ## 2026 — Ecodesign rules for iron and steel - **Regulation:** Regulation (EU) 2024/1781 (delegated act under the ESPR working plan) (ESPR) - **Scope:** Iron and steel as intermediate products - **Status:** proposed - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187 The Commission's ESPR working plan 2025-2030 (16 April 2025) gives 2026 as the indicative year for adopting the delegated act on iron and steel. Requirements, possibly limited to information requirements and a digital product passport, apply only once that act is in force, normally after a transition period. Indicative timing, not a legal deadline. The working plan lists iron and steel with an "indicative timeline for adoption" of 2026. The Commission may revise the plan at its mid-term review in 2028, and Article 5(6) ESPR lets it regulate product groups outside the plan at any time. ## 2027-02-18 — Battery passport becomes mandatory - **Regulation:** Regulation (EU) 2023/1542 (BattR) - **Scope:** LMT batteries, industrial batteries above 2 kWh, electric vehicle batteries - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20250731 From 18 February 2027 each LMT battery, industrial battery above 2 kWh and electric vehicle battery placed on the market or put into service must have an electronic battery passport (Art. 77). From the same day every battery must carry a QR code (Art. 13(6)), and the passport's unique identifier must be uploaded to the ESPR registry. The battery passport is the first mandatory digital product passport in EU product law. It holds the information listed in Annex XIII on the battery model and the individual battery; the QR code gives access to the passport for the batteries in scope and to the labelling information for all other batteries. ## 2027-02-18 — Portable batteries must be removable and replaceable - **Regulation:** Regulation (EU) 2023/1542 (BattR) - **Scope:** Products incorporating portable batteries or LMT batteries - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20250731 From 18 February 2027 anyone placing on the market a product with a portable battery must ensure the battery is readily removable and replaceable by the end-user with commercially available tools, with removal instructions permanently available online. LMT batteries, including individual cells, must be readily removable and replaceable by an independent professional (Art. 11). Article 11 applies from 18 February 2027 under Article 96(2)(a). Article 11(2) allows listed product types to be designed so that only independent professionals can replace the battery. ## 2027-06-30 — EUDR applies to micro and small operators - **Regulation:** Regulation (EU) 2023/1115 (EUDR) - **Scope:** Operators that are natural persons or micro or small undertakings - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226 From 30 June 2027 the EUDR obligations apply to operators that are natural persons or micro or small undertakings established by 31 December 2024, except for products already covered by the annex to the EU Timber Regulation, which fall under the 30 December 2026 date. Micro or small primary operators may use the one-time simplified declaration. ## 2027-08-18 — Battery due diligence obligations apply - **Regulation:** Regulation (EU) 2023/1542 (BattR) - **Scope:** Economic operators placing batteries on the market or into service - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20250731 From 18 August 2027 economic operators placing batteries on the market or putting them into service must set up and implement battery due diligence policies (Art. 48 to 50 and 52), have them verified and periodically audited by a notified body, and keep the documentation for ten years after the last battery under the policy was placed on the market. The date was moved from 18 August 2025 to 18 August 2027 by Regulation (EU) 2025/1561. The Commission's guidelines on due diligence are due by 26 July 2026 (Art. 48(5)). Article 47 sets the thresholds for which operators are covered. ## 2027-12-30 — EUDR product scope update applies - **Regulation:** Regulation (EU) 2023/1115, Annex I (Commission delegated act) (EUDR) - **Scope:** Products newly added to Annex I, such as soluble coffee - **Status:** proposed - **Source:** https://environment.ec.europa.eu/news/commission-updates-product-scope-and-tools-support-eudr-2026-07-13_en On 13 July 2026 the Commission adopted a delegated act updating Annex I of the EUDR: six product categories leave the scope and three are added (soluble coffee, certain palm-oil derivatives, frozen cattle tongues). According to the Commission, the newly added products become subject to the regulation from 30 December 2027. The act is under scrutiny and not yet published. The delegated act follows the simplification review of 4 May 2026 (COM(2026) 191), in which the Commission made no legislative proposal but published the draft delegated act for feedback. Treat the 2027 date as indicative until the act is published in the Official Journal. ## 2027 — Ecodesign rules for aluminium - **Regulation:** Regulation (EU) 2024/1781 (delegated act under the ESPR working plan) (ESPR) - **Scope:** Aluminium as an intermediate product - **Status:** proposed - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187 The Commission's ESPR working plan 2025-2030 (16 April 2025) gives 2027 as the indicative year for adopting the delegated act on aluminium. Requirements, possibly limited to information requirements and a digital product passport, apply only once that act is in force, normally after a transition period. Indicative timing, not a legal deadline. The working plan lists aluminium with an "indicative timeline for adoption" of 2027. The Commission may revise the plan at its mid-term review in 2028, and Article 5(6) ESPR lets it regulate product groups outside the plan at any time. ## 2027 — Horizontal repairability requirements - **Regulation:** Regulation (EU) 2024/1781 (delegated act under the ESPR working plan) (ESPR) - **Scope:** Horizontal measure across product groups, including ICT products - **Status:** proposed - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187 The Commission's ESPR working plan 2025-2030 (16 April 2025) gives 2027 as the indicative year for adopting the delegated act on horizontal repairability requirements, including a repairability score. Requirements apply only once that act is in force, normally after a transition period. Indicative timing, not a legal deadline. The working plan lists horizontal repairability requirements, including a repairability score with an "indicative timeline for adoption" of 2027. The Commission may revise the plan at its mid-term review in 2028, and Article 5(6) ESPR lets it regulate product groups outside the plan at any time. ## 2027 — Ecodesign rules for textiles and apparel - **Regulation:** Regulation (EU) 2024/1781 (delegated act under the ESPR working plan) (ESPR) - **Scope:** Textiles and apparel, in particular garments - **Status:** proposed - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187 The Commission's ESPR working plan 2025-2030 (16 April 2025) gives 2027 as the indicative year for adopting the delegated act on textiles and apparel. Requirements, expected to include a digital product passport, apply only once that act is in force, normally after a transition period. Indicative timing, not a legal deadline. The working plan lists textiles and apparel with an "indicative timeline for adoption" of 2027. The Commission may revise the plan at its mid-term review in 2028, and Article 5(6) ESPR lets it regulate product groups outside the plan at any time. ## 2027 — Ecodesign rules for tyres - **Regulation:** Regulation (EU) 2024/1781 (delegated act under the ESPR working plan) (ESPR) - **Scope:** Tyres placed on the EU market - **Status:** proposed - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187 The Commission's ESPR working plan 2025-2030 (16 April 2025) gives 2027 as the indicative year for adopting the delegated act on tyres. Requirements, expected to include a digital product passport, apply only once that act is in force, normally after a transition period. Indicative timing, not a legal deadline. The working plan lists tyres with an "indicative timeline for adoption" of 2027. The Commission may revise the plan at its mid-term review in 2028, and Article 5(6) ESPR lets it regulate product groups outside the plan at any time. ## 2028-08-12 — Harmonised packaging labels become mandatory - **Regulation:** Regulation (EU) 2025/40 (PPWR) - **Scope:** All packaging placed on the market; reusable packaging from February 2029 - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040 From 12 August 2028, or 24 months after the Commission's implementing acts on the label format if later, packaging placed on the market must bear a harmonised label on its material composition to help consumers sort waste (Art. 12(1)). Reusable packaging gets its own label from 12 February 2029 (Art. 12(2)); Decision 97/129/EC is repealed from 12 August 2028. ## 2028 — Ecodesign rules for furniture - **Regulation:** Regulation (EU) 2024/1781 (delegated act under the ESPR working plan) (ESPR) - **Scope:** Furniture placed on the EU market - **Status:** proposed - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187 The Commission's ESPR working plan 2025-2030 (16 April 2025) gives 2028 as the indicative year for adopting the delegated act on furniture. Requirements, expected to include a digital product passport, apply only once that act is in force, normally after a transition period. Indicative timing, not a legal deadline. The working plan lists furniture with an "indicative timeline for adoption" of 2028. The Commission may revise the plan at its mid-term review in 2028, and Article 5(6) ESPR lets it regulate product groups outside the plan at any time. ## 2029 — Recycled content rules for electronics - **Regulation:** Regulation (EU) 2024/1781 (delegated act under the ESPR working plan) (ESPR) - **Scope:** Electrical and electronic equipment, including ICT products - **Status:** proposed - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187 The Commission's ESPR working plan 2025-2030 (16 April 2025) gives 2029 as the indicative year for adopting the delegated act on horizontal requirements on recycled content and recyclability of electrical and electronic equipment. Requirements apply only once that act is in force, normally after a transition period. Indicative timing, not a legal deadline. The working plan lists horizontal requirements on recycled content and recyclability of electrical and electronic equipment with an "indicative timeline for adoption" of 2029. The Commission may revise the plan at its mid-term review in 2028, and Article 5(6) ESPR lets it regulate product groups outside the plan at any time. ## 2029 — Ecodesign rules for mattresses - **Regulation:** Regulation (EU) 2024/1781 (delegated act under the ESPR working plan) (ESPR) - **Scope:** Mattresses placed on the EU market - **Status:** proposed - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187 The Commission's ESPR working plan 2025-2030 (16 April 2025) gives 2029 as the indicative year for adopting the delegated act on mattresses. Requirements, expected to include a digital product passport, apply only once that act is in force, normally after a transition period. Indicative timing, not a legal deadline. The working plan lists mattresses with an "indicative timeline for adoption" of 2029. The Commission may revise the plan at its mid-term review in 2028, and Article 5(6) ESPR lets it regulate product groups outside the plan at any time. ## 2030-01-01 — Certain single-use packaging formats banned - **Regulation:** Regulation (EU) 2025/40 (PPWR) - **Scope:** Packaging formats and uses listed in Annex V - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040 From 1 January 2030 economic operators may no longer place on the market packaging in the formats and for the uses listed in Annex V (Art. 25(1)). From the same day the first re-use targets apply to transport and grouped packaging and to beverage sales packaging under Art. 29, with higher indicative targets from 1 January 2040. ## 2030-01-01 — Packaging must be designed for recycling - **Regulation:** Regulation (EU) 2025/40 (PPWR) - **Scope:** All packaging placed on the EU market - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040 From 1 January 2030, or 24 months after the delegated acts on design-for-recycling criteria if that is later, packaging may only be placed on the market if it is recyclable, meaning it reaches performance grade A, B or C under Annex II (Art. 6(2)). The Commission must adopt the criteria and grades by 1 January 2028 (Art. 6(4)). ## 2030-01-01 — Minimum recycled content in plastic packaging - **Regulation:** Regulation (EU) 2025/40 (PPWR) - **Scope:** Plastic parts of packaging placed on the market - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040 By 1 January 2030, or three years after the implementing act on calculation and verification if that is later, any plastic part of packaging placed on the market must contain the minimum percentage of recycled content recovered from post-consumer plastic waste set in Art. 7(1) per packaging type and format. Higher percentages apply from 1 January 2040 (Art. 7(2)). ## 2030-08-01 — Toy Safety Regulation applies; toy passport mandatory - **Regulation:** Regulation (EU) 2025/2509 (TSR) - **Scope:** Toys for children under 14; manufacturers, importers, distributors - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2509 From 1 August 2030 the Toy Safety Regulation applies in full and Directive 2009/48/EC is repealed. Before placing a toy on the market the manufacturer must create a digital product passport for it (Art. 19). Toys placed on the market under the Directive before that date may still be made available; EC type-examination certificates stay valid until 1 February 2031. ## 2031-08-18 — Minimum recycled content in batteries - **Regulation:** Regulation (EU) 2023/1542 (BattR) - **Scope:** Industrial batteries above 2 kWh, electric vehicle and SLI batteries - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20250731 From 18 August 2031 industrial batteries above 2 kWh, electric vehicle and SLI batteries containing cobalt, lead, lithium or nickel must document at least 16 % recycled cobalt, 85 % lead, 6 % lithium and 6 % nickel in active materials. From 18 August 2036 shares rise to 26 %, 85 %, 12 % and 15 %, LMT batteries included. The documentation duty on recycled content starts earlier: from 18 August 2028, or 24 months after the delegated act on the calculation methodology if later (Art. 8(1)), and from 18 August 2033 for LMT batteries. ## 2038-01-01 — Only highly recyclable packaging allowed - **Regulation:** Regulation (EU) 2025/40 (PPWR) - **Scope:** All packaging placed on the EU market - **Status:** adopted - **Source:** https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040 From 1 January 2038 packaging may only be placed on the market if it is recyclable within performance grade A or B as described in Table 3 of Annex II (Art. 6(3)); grade C, still allowed from 2030, is phased out. Innovative packaging may use the derogation in Art. 6(10).