Which Sectors Will Be Required to Adopt the DPP First — and When?
This is the question I hear most often in meetings with C-level executives. And I understand why: it sounds like a simple question with a simple answer. A list, a few dates, and you can plan accordingly. The problem is that this is also the wrong question. Or rather: it is the right question, but only if asked in the right way.
The Regulatory Landscape: Who Is Already In, and Who Is Next
Let’s start with the facts. The ESPR Regulation (EU 2024/1781) has not made the Digital Product Passport (DPP) immediately mandatory for all sectors. It works in layers: a multi-year Working Plan sets priorities, and for each product category a specific Delegated Act defines the requirements, traceability obligations, and DPP compliance rules, and triggers a minimum 18-month transition period before the obligation becomes effective.
One sector has already moved beyond uncertainty: batteries. The Batteries Regulation (EU 2023/1542) — separate from ESPR but fully aligned with the European circular economy strategy — has already set a clear date: from February 18, 2027, all electric vehicle batteries, industrial batteries above 2 kWh, and batteries for light means of transport placed on the European market must be accompanied by a digital passport.
This is not a proposal or a draft: it is binding European legislation with a defined deadline. Batteries are the testing ground for the entire DPP ecosystem — the first regulated DPP in the EU, already operational in its core technical requirements.
For other sectors, the Working Plan 2025–2030 (COM(2025) 187 final, adopted on April 16, 2025) has identified priority categories: textiles and apparel, furniture, tires, iron and steel, and aluminum. For each of these, Delegated Acts are expected, with indicative timelines between 2027 and 2030.
“Indicative” is the key word: exact dates depend on the progress of preparatory studies and stakeholder engagement across the European manufacturing ecosystem. For most of these sectors, definitive deadlines do not yet exist.
The Wrong Question — and the Right One
So far, this is the informational answer. But there is a point that rarely emerges in official presentations on the Digital Product Passport (DPP), and yet completely changes how a manager should interpret this situation.
The question “when does the obligation start for my sector?” assumes that regulation is the reference point. But in most cases, regulation comes last. The market moves first, especially in supply chain traceability, sustainability reporting, and digital product data management.
We are already seeing this happen. Large buyers — automotive, luxury, large-scale retail — are rewriting their procurement specifications, requiring structured, traceable, and verifiable sustainability data from their suppliers. BMW through Catena-X, Kering through ZDHC standards, IKEA through its qualification requirements: they are not waiting for Delegated Acts or formal DPP compliance deadlines. They are building data infrastructures that will become the only way to remain in the value chain tomorrow. A supplier that cannot respond to these requests does not fail an audit — it loses the contract.
The chemical sector is a particularly instructive example. It is not part of the first regulatory wave — the ESPR Working Plan places it later. And yet it is a critical input for nearly all sectors already under pressure: textiles, automotive, furniture, batteries. Companies producing chemical auxiliaries, dyes, adhesives, and coatings are already being asked today for granular sustainability data by their direct customers.
The Delegated Act will come later. The customer request for transparent product data and supply chain visibility has already arrived.
The Right Countdown for DPP Implementation
There is another aspect that many underestimate: the 18-month transition period guaranteed by regulation between the publication of a Delegated Act and the effective obligation is not a comfortable buffer. It is the minimum time required to analyze your data, redesign information collection processes across the value chain, align with suppliers, implement digital traceability systems, and select the right technological architecture for DPP implementation.
Those who wait for the Delegated Act to be published before taking action are already behind.
The right question, therefore, is not “when will I be required to comply?” It is: “how long do I need to be ready — and when should I start counting?”
Knowing which regulatory wave your sector belongs to is the starting point, not the finish line. The real countdown does not begin with the Delegated Act: it begins when your key customer asks you for structured sustainability data, interoperable product information, carbon footprint metrics, recycled content verification, or Digital Product Passport integration.
