With the Omnibus Package, Has Europe Delayed Everything? Does That Include the Digital Product Passport?
Audience: Legal counsel or CFO, manufacturing company, Europe
The short answer is no.
What Europe has delayed concerns sustainability reporting and corporate due diligence obligations. These are requirements related to how a company behaves and what it reports about itself.
Nothing has been postponed regarding the requirements that products themselves must meet, and the Digital Product Passport (DPP) belongs to that second category.
How Many Omnibus Packages Are There, and What Have They Actually Changed?
The first clarification is numerical: there is not just one Omnibus package.
Between January 2025 and June 2026, the European Commission presented twelve Omnibus packages covering different policy areas, including investment, agriculture, defence, chemicals, digital policy, environmental legislation, automotive regulation, food safety, and taxation.
The package that attracted most attention, and which most people simply call the Omnibus, is the first one, focused on sustainability legislation. It changed three things, each with specific dates.
The second wave of companies subject to sustainability reporting is postponed to financial years starting in 2027. The third wave, comprising listed SMEs, moves to 2028. Corporate due diligence obligations are delayed by one year, with the first application beginning in 2028.
The thresholds have also been raised significantly.
For sustainability reporting, the new scope requires more than €450 million in net turnover and more than 1,000 employees, with both criteria applying simultaneously. Many companies that had already begun preparing for compliance now fall outside the scope altogether. These are substantial and meaningful postponements, and companies affected by them were right to take notice. However, they all concern the same family of obligations: what companies must report and demonstrate about their own operations.
What Has Not Changed
The Ecodesign for Sustainable Products Regulation (ESPR), which establishes the framework for the Digital Product Passport, has not undergone a single substantive amendment.
Its official legislative record shows only four linguistic corrections and one implementing act introducing exemptions to the ban on destroying unsold goods.
The two current amendment proposals, one concerning the electronic format of documents and another introduced in September 2026 regarding public procurement, do not postpone or reduce any Digital Product Passport requirements.
The Packaging and Packaging Waste Regulation (PPWR) has not been delayed either and became applicable on 12 August 2026 as originally planned.
Likewise, the battery passport requirement remains scheduled for 18 February 2027. There is, however, one exception that is worth knowing because it is often cited incorrectly.
For batteries, the simplification package did postpone something: supply chain due diligence obligations have been deferred until 18 August 2027. This change is already law. But that obligation concerns how a company manages and monitors its suppliers. It belongs to the same category of company-behavior requirements that have been simplified elsewhere.
The battery passport itself, which is a product requirement, has not been the subject of any proposal for postponement. In fact, while sustainability requirements were being simplified, product legislation continued to expand.
On 8 July 2026, the European Union adopted the Regulation on vehicle circularity requirements and end-of-life vehicles. It was published in the Official Journal on 24 July 2026 and introduces its own Vehicle Circularity Passport.
Anyone claiming that Europe has stepped back from product regulation must explain why a brand-new product passport was adopted during the very same period. A brief note on environmental claims is also helpful because there is widespread confusion. The proposal sometimes described as having been withdrawn has not actually been withdrawn. It is currently stalled in the Council.
Meanwhile, the directive prohibiting greenwashing is a separate piece of legislation altogether. It was not affected by any Omnibus package and has applied since 27 September 2026. I discuss this in more detail in the dedicated Q&A on environmental claims.
What Does “Simplification” Actually Mean in EU Legislation?
This is perhaps the most important takeaway.
In the documents through which the Commission proposes simplification, the Digital Product Passport is not presented as a burden to be removed. Instead, it is presented as a tool that can help simplify compliance. These proposals are not yet law, but they reveal the direction policymakers are taking.
Three examples illustrate the point.
In an environmental proposal published in December 2025, the Commission proposed removing a European database on hazardous substances, arguing that Digital Product Passports would reduce its added value.
In a proposal published in May 2025, the Commission established a rule for products covered by multiple regulations: conformity documentation could be stored within the Digital Product Passport, eliminating the need for separate documentation systems.
In a proposal concerning energy-related products published in June 2026, the Commission introduced the principle of “register once”. Under this approach, companies already registered in the European energy labelling register would not need to register again in the Digital Product Passport registry.
In other words, simplification increasingly means collecting a piece of information once instead of requesting the same data five times in five different formats. And well-structured product data is the mechanism that makes this possible.
The real question, therefore, is not whether the Digital Product Passport has been postponed. The real question is whether it makes sense to prepare now or wait until the delegated act for your product sector is adopted. That is a different discussion, which I address separately in the dedicated Q&A on delegated acts.
Before slowing down because of an Omnibus package, check which family of obligations you are dealing with. If the requirement concerns information your company must disclose about itself, the postponement may genuinely apply to you. If it concerns a requirement that your product must satisfy, none of the twelve Omnibus packages has delayed it by a single day.
