The EU's Ecodesign for Sustainable Products Regulation (ESPR) is the framework law that sets sustainability and information requirements for most physical products sold in the EU. Its purpose is to make products more durable, repairable, and transparent in their environmental impact, shifting the disclosure burden from self-declaration to verified data carried in a Digital Product Passport (DPP). What ESPR requires of your organization depends significantly on where you sit in the supply chain. A raw-material supplier, a manufacturer, a brand owner, and a distributor each face different obligations under the same regulation. This Atlas helps you navigate that: what is confirmed, what is signaled, when it applies, and what your role asks of you. The Atlas will grow as delegated acts are adopted and more product categories enter scope. It is a guide, not legal advice.
The trigger is placing a product on the EU market, not where your company is based. If you sell into the EU directly, online, or through an EU importer or distributor, the DPP and ecodesign duties can reach your products. Our plain-language guide covers the placing-on-the-market trigger, the Authorised Representative and importer mechanics, and who carries the economic-operator duty, with the ESPR articles cited.
Read: Does ESPR apply if we are not EU-incorporated? →Regulation (EU) 2024/1781 entered into force 18 July 2024. It is the framework law. It does not impose product-specific obligations on its own; those come through delegated acts for each product category. Locked
The central EU DPP registry must be operational by 19 July 2026 (ESPR Art. 13). Organizations in regulated product categories should have their registration approach decided and their unique product identifiers and documentation ready by that date. Locked
The Article 25 destruction ban begins applying to large enterprises for unsold apparel and footwear on 19 July 2026. The derogations act C(2026) 659 and disclosure-format act C(2026) 660 are both adopted. Large enterprises must keep five-year records to use any derogation. Locked
Battery passports are mandatory for EV batteries, LMT batteries, and industrial batteries over 2 kWh from 18 February 2027. This is governed by the Batteries Regulation (EU) 2023/1542, not ESPR, but uses the same DPP infrastructure. Locked
The first Working Plan (COM(2025) 187) identifies iron and steel as the likely first category, followed by textiles, tires, and aluminium. Realistic compliance dates for these categories are 2028 to 2029. Signaled
Product carbon footprint and lifecycle assessment data are expected to be required fields in DPPs for most categories. For batteries, carbon footprint per kWh is a stated requirement. For other categories, specific methodologies and thresholds will be set in each delegated act. Signaled
Omnibus IV is a package with two strands relevant here. The batteries stop-the-clock strand was adopted as Regulation (EU) 2025/1561 (18 July 2025): it postponed battery due diligence to 18 August 2027 and did not touch the carbon-footprint declaration. The digitalisation and common-specifications strand (COM(2025) 504 and 503) reached provisional political agreement on 9 June 2026, and the Council's Permanent Representatives Committee (COREPER) confirmed the compromise texts on 26 June 2026; formal adoption is pending and it moves no DPP date. Signaled
Most sector-specific delegated acts are in preparatory or consultation stages. Plan against date ranges, not fixed deadlines, for everything except batteries and the Article 25 destruction ban. Signaled
Six of the eight horizontal DPP standards are cited in the Official Journal. The remaining two, EN 18239 (access rights and security) and EN 18246 (data authentication and integrity), closed their CEN-CENELEC formal vote on 16 July 2026 with publication imminent, but are not yet Commission-cited. Track them if access control or data authentication is central to your build. Signaled
The calculation methodology act for EV battery carbon footprint remains in draft as of June 2026 (draft published 30 April 2024). The declaration applies 12 months after this act enters into force, so its date floats. Do not finalize your reporting approach until this act is adopted. Speculative
Understanding how an EU regulation becomes binding law helps clarify why some obligations in this Atlas are Locked while others remain Signaled.
The Commission proposes legislation and, under ESPR, drafts the delegated acts that activate product-specific requirements. Delegated acts do not require a full legislative process; the Commission adopts them under authority already granted by the parent regulation (ESPR or the Batteries Regulation).
The Council (EU member states) and the European Parliament both have the right to object to a delegated act within a scrutiny period, typically two months. If neither objects, the act is adopted and published in the Official Journal.
Trilogue is the informal negotiation between the Commission, Parliament, and Council used for ordinary legislative procedure; it applies to major regulations like ESPR itself, not to delegated acts. When you see trilogue mentioned in EU news, it typically refers to a framework law, not the product-specific rules.
For ESPR purposes: the framework is Locked: it passed trilogue and is published in the Official Journal. The delegated acts that set your actual product obligations are Signaled until adopted and published. Tracking the delegated act for your specific category is what determines your real compliance deadline.
This hub is provided for informational purposes only and does not constitute legal, regulatory, or compliance advice. EU Ecodesign rules and delegated acts are evolving: deadlines, thresholds, and category scope change as acts are finalized. Verify all obligations against the cited primary sources (EUR-Lex, the European Commission, CEN/CENELEC) and with qualified legal counsel before acting.
ESPR Atlas is built and maintained by Dave Hartter, a packaging and product sustainability advisor with more than 20 years at global manufacturers, most recently as Director of Sustainability at Huber Engineered Materials (J.M. Huber). He builds the programs that connect regulation and customer requirements to real product decisions.
He advises brands, manufacturers, and suppliers on EU Ecodesign and the Digital Product Passport: what ESPR and the Batteries Regulation require, when each obligation lands, and how to turn early DPP readiness into a product and market advantage. ESPR Atlas is the public version of that work, maintained from primary sources. It is independent and not affiliated with any EU institution, standards body, or industry group. For advisory engagements or corrections, reach Dave at info@hartteradvisory.com.
Two distinct ESPR obligations begin on 19 July 2026, and they are often confused. The central EU Digital Product Passport registry must be operational (ESPR Article 13), and the Article 25 ban on destroying unsold apparel and footwear begins applying to large enterprises. This tab is an instruction manual for both: check whether you are affected, read what each obligation actually requires, and follow the how-to-proceed steps. Every date and requirement here is verified against the primary texts listed under Source Documents. It is a guide, not legal advice.
Answer the four questions and the Atlas renders your obligation profile, separating what binds now (including on 19 July 2026) from what binds later, with an evidence label on every date. Size definitions follow Commission Recommendation 2003/361/EC. Orientation only, not legal advice.
By 19 July 2026 the European Commission must have the central DPP registry operational (ESPR Article 13). The registry is an index, not a data warehouse: it stores unique product identifiers, the commodity code for goods placed under the customs procedure for release for free circulation, and battery identifiers under Article 77(3) of the Batteries Regulation. Passport content itself stays with the economic operator or its service provider. There is no per-product registration duty that lands on companies on 19 July 2026. Product passport duties bind category by category as each instrument takes effect, and batteries are first, on 18 February 2027. Locked
The economic operator placing the product on the EU market is responsible for the passport and its registration, even when a third-party service provider performs the registration and lifecycle updates. Manufacturers and own-label brands carry the obligation directly; importers inherit it for goods made outside the EU; distributors must not place products lacking a required passport on the market. Locked
If you are in a regulated category or expect to be, three decisions should be made before the registry opens: who performs registration (in-house versus a service provider); whether you can issue compliant unique product identifiers and GS1 Digital Link data carriers; and whether your EORI records and conformity documentation are ready to link. The registry registration rules are now set by Commission Implementing Regulation (EU) 2026/1778 (published 17 July 2026, in force 6 August 2026). Locked
The implementing regulation that sets the Registry's operating rules, Commission Implementing Regulation (EU) 2026/1778 (consultation ref. Ares(2026)4424976), was adopted 16 July 2026 and published in the Official Journal 17 July 2026. The Commission's central Registry went live to users on 20 July 2026, meeting the 19 July operational deadline; the regulation enters into force 6 August 2026. Locked
From 19 July 2026, ESPR Article 25(1) prohibits the destruction of unsold consumer products listed in Annex VII: apparel and clothing accessories (CN 4203, chapters 61 and 62, and headgear headings 6504 and 6505) and footwear (CN 6401 to 6405). The ban applies to large enterprises from 19 July 2026, applies to medium-sized enterprises from 19 July 2030, and does not apply to micro and small enterprises. Operators not subject to the ban must not destroy unsold products supplied to them for the purpose of circumventing it (Art. 25(2)). Locked
Destruction means the intentional damaging or discarding of a product as waste, with a single exception: discarding for the sole purpose of delivering the product for preparing for reuse (including refurbishment) or remanufacturing (ESPR Art. 2(34)). Under the waste hierarchy that means recycling, energy recovery, and disposal all count as destruction. Sending unsold stock to a recycler does not comply with the ban. Locked
Delegated Regulation C(2026) 659 (adopted 9 February 2026) permits destruction only in specific circumstances: the product is dangerous under the General Product Safety Regulation; it is non-compliant with EU or national law and destruction is required or is the proportionate corrective action; a substantiated intellectual-property infringement, or an expired licence period that makes further transfer an infringement; unsuitability for reuse or remanufacturing because protected or inappropriate labels, logos, or design features cannot be removed; damage, deterioration, or contamination where repair is not technically feasible or cost-effective; design or manufacturing defects where repair is not technically feasible; or the donation route was exhausted without a recipient. For every derogation used, supporting documentation must be kept for five years after destruction and provided electronically within 30 days of an authority request (Art. 3). Locked
Where no other derogation applies, a product may be destroyed only after it was offered for donation and not accepted: either offered directly to at least three suitable social-economy entities located in the EU, or posted on an easily accessible page of the operator's website for at least eight weeks (C(2026) 659, Art. 2(h)). Building donation and redistribution channels now is the practical core of compliance. Locked
Separately from the ban, ESPR Article 24 requires economic operators that discard unsold consumer products to disclose annually, on an easily accessible page of their website: the number and weight discarded per product type or category; the reasons, including any Article 25(5) derogation used; the proportions delivered for preparing for reuse, recycling, other recovery including energy recovery, and disposal; and the measures taken and planned to prevent destruction. The same size ladder applies: micro and small enterprises are exempt, and the duty applies to medium-sized enterprises from 19 July 2030. The first disclosure covers the first full financial year during which ESPR is in force, and supporting documentation must be producible within 30 days. The standardized disclosure format is set by Implementing Regulation C(2026) 660 (adopted 9 February 2026), which applies from about February 2027, twelve months after that act enters into force. Its product delimitation uses the first two CN digits generally and four digits for products in ESPR Annex II, so the disclosure scope is broader than the Annex VII ban scope. Donated products are not discarded and are excluded. Locked
ESPR is in force and the regulatory framework is established. The immediate window is the next 18 months: the DPP registry launches and the Article 25 destruction ban takes effect in July 2026, followed by the battery passport requirement in February 2027. Beyond those, most product-specific delegated acts are still being drafted, which means their category timelines will continue to move as Commission work progresses. Use this timeline to build a preparation strategy grounded in what is confirmed rather than what is anticipated.
Nine sectors are tracked in this Atlas: two with locked regulations (batteries and detergents) and seven in various stages of Working Plan development. Select a sector to see its status, key date, expected DPP data requirements, and what to prepare.
The battery passport is the most mature DPP category, governed by the Batteries Regulation rather than an ESPR delegated act, but using the same DPP infrastructure. The most concrete buildable specification currently available is the AAS / Catena-X guideline published February 2026, with Eclipse Tractus-X as the reference implementation. Readiness is strongest in the automotive and large-cell segment. Smaller producers outside these ecosystems face more fragmented implementation paths.
The EV battery carbon-footprint calculation methodology act remains in draft as of June 2026. It gates real enforcement of the PCF declaration requirement. Do not finalize your carbon-footprint reporting approach until it is adopted. Speculative
Build against the AAS / Catena-X guideline. Confirm your implementation path for unique product identifiers in GS1 Digital Link format. Monitor GBA operational trial results, originally expected June 2026 but not yet confirmed released.
The Detergents Regulation (EU) 2026/405 is a dedicated regulation for this category, not an ESPR delegated act, but uses the same DPP infrastructure. It replaces the previous Detergents Regulation (EC) 648/2004 and introduces digital labelling requirements alongside updated biodegradability and safety data obligations.
Review whether your products fall within the regulation's scope. September 2029 provides planning runway, but formulary data flows and digital labelling infrastructure should be mapped well in advance of the deadline.
Iron and steel is identified in the first Working Plan as the lead category for ESPR delegated acts. Preparatory study and stakeholder consultation are underway. No delegated act has been proposed yet, but this is the category to watch most closely if you are in the steel supply chain.
Delegated act proposal expected 2026 to 2027. Compliance timeline of 2028 to 2029 is indicative and will shift once the act is proposed and adopted. Signaled
Monitor Commission consultation documents for iron and steel. Begin preparing verified embodied-carbon and recycled-content data now. Customers in regulated downstream categories will request this data before your own deadline arrives.
Textiles is among the highest-priority categories in the first Working Plan. Stakeholder consultation has closed and a draft delegated act is in development. Note that large enterprises in apparel are already subject to the Article 25 destruction ban on unsold goods from 19 July 2026, well ahead of the DPP obligation.
Article 25 destruction ban already applies to large enterprises for unsold apparel and footwear from 19 July 2026. This is confirmed law, separate from and earlier than the DPP delegated act. Locked
Delegated act proposal expected late 2026 or early 2027. Compliance timeline of 2028 to 2029 is indicative. Signaled
The JRC's May 2026 preparatory study proposes the DPP content run in four categories (identification, producer information, product information, compliance documentation) with a role-based access model, for products at least 80% textile fibre by weight. This is a preparatory study, not the delegated act itself, and the categories above may change before the act is proposed. Signaled
Verify Article 25 compliance if you are a large enterprise with unsold apparel inventory. Separately, monitor the ESPR delegated act consultation and begin mapping item-level data flows and fiber content tracking against the JRC's four proposed data categories.
Aluminium is in the first Working Plan, with preparatory study and stakeholder consultation underway. Key data challenges are expected around energy mix in smelting (the green versus grey aluminium distinction) and supply-chain traceability from smelter to finished product.
No delegated act has been proposed yet. Timeline is indicative. Monitor the Commission's consultation process and Working Plan progress reviews. Signaled
Begin preparing energy-source and recycled-content data at the smelter or mill level. Customers in downstream regulated categories will request this data upstream before their own compliance deadlines.
Tires are in the first Working Plan. The preparatory study is building on existing Euro 7 tire wear and rolling-resistance data infrastructure, which may reduce the data collection burden for producers already building toward Euro 7 compliance.
No delegated act proposed yet. Euro 7 tire wear data may create infrastructure synergies. Monitor the preparatory study for scope confirmation. Signaled
Monitor Euro 7 implementation alongside the ESPR preparatory study. If you are building Euro 7 data infrastructure, assess how it maps to likely DPP fields to avoid duplicate work.
Furniture is in the first Working Plan at an early JRC (Joint Research Centre) preparatory study stage. No stakeholder consultation has opened yet. This is among the lower-urgency categories in the Working Plan for immediate compliance planning.
No consultation or draft act expected before 2027 at the earliest. Compliance would realistically not be required before 2030. Signaled
No immediate compliance action is required. Monitor the JRC study and Working Plan progress reviews. This is a good category to develop material data infrastructure proactively before the consultation window opens.
Mattresses have the longest runway of the Working Plan priority categories. The preparatory study focuses on challenging end-of-life issues including foam-textile separation and flame retardant declarations. No consultation has opened yet.
No consultation or draft act is expected before 2028. Compliance would realistically not be required before 2030 to 2031. Signaled
No immediate compliance action is required. Use the runway to address take-back logistics and build out flame retardant and substance data if those present supply chain challenges.
Footwear is not included in the first Working Plan. A scoping study is expected by late 2027, after which a delegated act could be developed. However, large enterprises in footwear are already subject to the Article 25 destruction ban on unsold goods from 19 July 2026. This is confirmed law, not a projected obligation.
Article 25 destruction ban applies to large enterprises for unsold footwear from 19 July 2026. Five-year record-keeping is required to use any derogation. Locked
ESPR delegated act for footwear is not in the first Working Plan. Earliest realistic compliance would be 2030 or later. Signaled
Focus on Article 25 compliance if you are a large enterprise with unsold footwear inventory. No ESPR DPP action is required yet. Monitor the scoping study expected in late 2027.
The same rules apply differently depending on where you sit in the value chain. Select your position to see what ESPR and the DPP ask of you. This is an orientation guide, not a compliance checklist.
ESPR does not stand alone. Several related EU regulations share infrastructure, data requirements, and compliance timelines. Understanding how they connect, and where they diverge, determines whether your compliance programme can be built as one integrated effort or must address each separately.
The Ecodesign for Sustainable Products Regulation is the legal foundation for nearly everything else in this Atlas. It does not impose product-specific requirements on its own; those come through delegated acts. What it establishes is the architecture: the DPP framework, the EU registry, economic-operator responsibilities, market surveillance powers, and the authority to adopt delegated acts for each product category. The destruction ban and the DPP registry deadline are both live ESPR provisions that do not require a delegated act.
Any economic operator placing physical products on the EU market once a delegated act for that product category is adopted. Manufacturers, brand owners, importers, and distributors each carry different obligations under the same regulation. Non-EU entities selling into the EU must appoint an EU Authorized Representative (ESPR Art. 28).
ESPR Article 41 is the mechanism behind the Digital Product Passport standards. It says that if you build your passport to a harmonised standard whose reference has been published in the Official Journal, you are presumed to meet the matching ESPR requirements, and authorities must accept that without you proving it another way. On 15 July 2026, Commission Implementing Decision (EU) 2026/1736 cited the first six DPP standards (EN 18216 to 18223:2026) in the Official Journal, so that presumption is now live for the parts of the passport those standards cover: data exchange, unique identifiers, data carriers, storage and persistence, lifecycle APIs, and system interoperability. It is a safe harbour, not the only route: you may comply another way, but then you carry the burden of showing it.
Anyone building or buying a Digital Product Passport: manufacturers and own-label brands that carry the passport obligation, importers who inherit it for goods made outside the EU, and the platforms and service providers they rely on. Nothing here moves a deadline; it changes how confidently you can build ahead of one.
Commission Implementing Regulation (EU) 2026/1778 is the operating rulebook for the central EU Digital Product Passport Registry required under ESPR Article 13. It defines who registers, how identity is verified, what a proof of registration is, and how long data is kept. The Registry is the backbone that ties product passports to a single EU access point. With the rules adopted and the system live from 20 July 2026, economic operators placing products in scope now have a concrete registration path rather than a pending consultation. The Registry remains an index: it stores unique product identifiers and the responsible economic operator, while passport content sits with the manufacturer or its service provider.
Economic operators placing regulated products on the EU market, and the DPP platforms and service providers that register on their behalf. The operator placing the product on the market keeps legal responsibility for registration even when a third party performs it.
The Digital Product Passport is not a separate regulation; it is the mandatory data infrastructure established within ESPR. Every product in a regulated category must carry a data carrier (typically a QR code) resolving to a structured, machine-readable record containing the sustainability and compliance data required by that category's delegated act. The EU DPP Registry stores identifiers and pointers; actual product data sits with the manufacturer or a service provider. The operator placing the product on the market holds legal responsibility for accuracy and registration.
Manufacturers, brand owners, and importers in regulated product categories. The economic operator placing the product on the EU market is legally responsible for the DPP's accuracy and registry registration, even when a third-party service provider handles the operational work.
The Batteries Regulation is the most concrete and implementation-ready DPP obligation in the EU as of 2026. It is a standalone regulation, not an ESPR delegated act, but uses the same DPP registry and data-carrier architecture. The battery passport covers approximately 90 data fields including carbon footprint, recycled content (cobalt, lithium, nickel, lead), state of health, and due-diligence documentation on raw material sourcing. Readiness is strongest in the automotive and large-cell segment (Catena-X, IDTA, GBA ecosystems).
Manufacturers, importers, and distributors of EV batteries, LMT batteries, and industrial batteries over 2 kWh placed on the EU market. Due-diligence obligations (Art. 52) apply to cobalt, lithium, nickel, and natural graphite supply chains. SMEs with net worldwide turnover below €40 million are currently exempt from the due-diligence obligation.
The CRMA is a separate regime from ESPR: its legal basis, scope, and enforcement are independent. However, it shares most of the same underlying supply-chain origin data with the Battery Passport and ESPR DPP obligations. A company in the battery, metals, or clean-tech space may be caught by CRMA independently of any DPP obligation, and the overlapping data requirements mean both can be served by a single supplier-origin dataset. The regulation maintains two material lists: Annex I (17 Strategic Raw Materials, triggers Art. 24) and Annex II (34 Critical Raw Materials, broader economic-importance list).
Article 24: large companies (more than 500 employees AND more than €150m net worldwide turnover) that manufacture a listed strategic technology in the EU, including batteries, hydrogen, renewables, traction motors, heat pumps, data infrastructure, drones, rockets, and robotics. Article 27: any manufacturer whose products contain permanent magnets over 0.2 kg total magnet weight, not limited to large companies.
| Annex I: 17 Strategic Raw Materials | Annex II: Additional 17 CRMs (34 total) | |
|---|---|---|
| Triggers Art. 24 risk assessment | Yes, if large company (500+ employees, €150m+ turnover) making a strategic technology | No |
| Triggers Art. 27 magnet disclosure | Yes, rare earth elements for permanent magnets specifically (Nd, Pr, Tb, Dy, Gd, Sm, Ce) | No |
| Supply-chain mapping priority | Map these first; answers the Art. 24 scope question | Map for completeness; important ahead of the 2027 list review when materials can move to Annex I |
| Drives EU strategic projects and permits | Yes | Yes |
| Battery-chain relevance | High: lithium, cobalt, nickel (battery grade), natural graphite (battery grade), and manganese (battery grade) are all Annex I | Lower directly; relevant for specialty chemicals and defence-adjacent supply chains |
Article 25 of ESPR directly prohibits the destruction of unsold consumer goods. No delegated act is needed; it is live now. The Commission adopted two acts in February 2026, of different classes: C(2026) 659 is a DELEGATED Regulation under Art. 25(5) setting the derogations from the ban, and C(2026) 660 is an IMPLEMENTING Regulation under Art. 24(3) setting the format for public disclosure of any goods that are destroyed. Currently scoped to apparel, accessories, and footwear. Large enterprises must comply from 19 July 2026; SMEs have until 2030.
Large enterprises (250 or more employees, or exceeding both financial ceilings: more than €50 million annual net turnover and more than €43 million balance sheet, per Recommendation 2003/361/EC) placing unsold apparel, accessories, and footwear on the EU market. Micro and small enterprises are permanently excluded by Art. 25(1); medium-sized enterprises are caught from 19 July 2030. Scope is currently apparel and footwear only.
The Detergents Regulation (EU) 2026/405 replaces the previous Detergents Regulation (EC) 648/2004 and introduces digital labelling requirements alongside updated biodegradability and safety data obligations. It is a standalone regulation, not an ESPR delegated act, but uses the same DPP infrastructure. With a 2029 compliance date there is meaningful planning runway, but formulary data flows and digital labelling infrastructure should be mapped in advance of that deadline.
Manufacturers, importers, and distributors of detergents and surfactants placed on the EU market, including household, institutional, and industrial products. Covers both rinse-off and leave-on products.
Key terms used in ESPR, the DPP framework, and this Atlas. Definitions reflect their meaning in the EU regulatory context.
Primary regulatory documents, official Commission resources, and notable third-party sources. Links open in a new tab. Inclusion of a third-party source is for informational purposes and does not constitute an endorsement.
Delegated regulation setting derogations from the unsold goods destruction ban for apparel and footwear.
Regulation governing all batteries placed on the EU market, including the battery passport requirements (Art. 77).
The foundational CRMA text. In force since 23 May 2024. Sets the Strategic Raw Materials list (Annex I, 17 materials) and the Critical Raw Materials list (Annex II, 34 materials). Articles 24 and 27 contain the direct company obligations for supply-chain risk preparedness and permanent magnet disclosure respectively.
Regulation on detergents and surfactants, applying from 23 September 2029.
The framework regulation. Full text of the Ecodesign for Sustainable Products Regulation as published in the Official Journal.
The first Working Plan identifying priority product groups for ESPR delegated acts, 2025 to 2030.
Omnibus IV regulation strand on digitalisation and common specifications. Provisional political agreement 9 June 2026; COREPER confirmed the compromise texts 26 June 2026; formal adoption pending. Moves no DPP date.
Adopted 18 July 2025. Postponed battery due-diligence obligations to 18 August 2027, with Commission guidance due 26 July 2026. Did not touch the carbon-footprint declaration.
The Commission's official CRMA page, including the SRM and CRM lists, strategic project register, and links to delegated act developments.
The Commission's official ESPR page with news, working documents, and links to delegated act consultations.
The official EU law database. All Locked claims in this Atlas link to EUR-Lex entries.
Commission action plan proposing targeted CRMA amendments including expanded permanent magnet labeling to additional appliance categories and mandatory recycled-content declarations for pre- and post-consumer waste.
Council adopts its position on a Commission proposal amending the CRMA: shifts large-company identification from Member States to the Commission, allows digital product passports to satisfy Article 27 magnet disclosure, and adds magnet-recycling measures. Parliament has not yet adopted its own position; trilogue not started.
Commission hub for DPP implementation guidance, registry developments, and technical documentation.
Preparatory study proposing four DPP data categories for textile apparel (identification, producer information, product information, compliance documentation) and a role-based access model, for products at least 80% textile fibre by weight. Feeds the future textile delegated act; not the act itself.
The joint technical committee for horizontal DPP standards. The first six EN standards (EN 18216 and 18219 to 18223:2026) were published 27 May 2026 and cited in the Official Journal on 15 July 2026; two more (EN 18239 and EN 18246) closed their CEN-CENELEC formal vote on 16 July 2026, publication imminent and OJ citation still pending.
Commission Implementing Decision of 14 July 2026 (in force 15 July 2026) citing EN 18216 to 18223:2026 in the Official Journal. Full readable text. Conformity with these standards is presumed to satisfy ESPR Articles 10 and 11 under Article 41(2).
Published standard for encoding product identifiers and resolver URLs into QR codes and web URIs. The expected data-carrier syntax for ESPR DPPs.
The Digital Battery Passport Use Case Guideline (February 2026). The most concrete buildable specification for battery DPP implementation.
ESPR does not operate in isolation. Two adjacent regimes overlap it directly, and each has its own dedicated Atlas. This Atlas differentiates on synthesis: it orients you across all of them rather than duplicating any single-purpose tool. For technical DPP depth, follow the specialist links below rather than expecting that depth here.
| Regime | What it governs | Where it meets ESPR | Dedicated Atlas |
|---|---|---|---|
| ESPR + DPP Reg (EU) 2024/1781 |
Ecodesign and information requirements, plus the Digital Product Passport, for most physical products, category by category. | This Atlas. The framework the other two connect to. | ESPRAtlas.com |
| EU PPWR Reg (EU) 2025/40 |
Packaging and packaging waste: recyclability, recycled content, reuse, and packaging-specific labelling and QR requirements. | Shares the DPP and data-carrier direction; packaging sits alongside a product's own ESPR passport. Batteries and textiles both generate packaging in scope. | PPWRAtlas.com |
| US packaging EPR State producer-responsibility laws |
Producer responsibility and eco-modulated fees for packaging across a growing set of US states. | The US-market counterpart for brands already mapping EU packaging and product data. Different legal basis, similar data burden. | EPRAtlas.com |
The following organizations publish substantive guidance on ESPR and DPP compliance. They are included because their work is cited in this Atlas's source research or because they are widely referenced by practitioners. Many are service providers or consultancies; their inclusion here acknowledges their contributions to the field, not a referral or recommendation.
EU-funded coordination project running large-scale Digital Product Passport pilots across sectors. The best free reference for cross-sector DPP data requirements and deployment lessons. ESPR Atlas links out to it rather than duplicating its technical depth.
Free technical reference on DPP data carriers, access tiers, and economic-operator obligations, written for teams already building a passport. Deeper on the data model than this Atlas by design; use it once you know your category and dates.
Open-source reference implementation for the Catena-X data ecosystem. Used as the reference application for AAS battery passport deployment.
Industry consortium running operational trials for battery passport implementation. Publishes the Battery Benchmarks and Greenhouse Gas Rulebook. Research from GBA informs the battery depth section of this Atlas.
Develops and maintains the Asset Administration Shell (AAS) standard. The AAS battery passport guideline, published with Catena-X, is cited in this Atlas as the primary technical specification for battery DPP architecture.
Updated monthly. Each entry is dated and labeled. Newly adopted law and category changes are listed first.
The EU Digital Product Passport Registry now has its operating rulebook. Commission Implementing Regulation (EU) 2026/1778, adopted 16 July and published in the Official Journal 17 July 2026, sets the identity verification, registration, proof-of-registration, and data-retention rules for the central Registry required under ESPR Article 13. It enters into force 6 August 2026, and the Registry went live to users on 20 July 2026. This resolves the item the Atlas had been tracking as pending (consultation Ares(2026)4424976). Locked
The Commission has cited the six horizontal DPP standards in the Official Journal. Implementing Decision (EU) 2026/1736 of 14 July 2026, published and in force 15 July 2026, lists EN 18216, EN 18219, EN 18220, EN 18221, EN 18222, and EN 18223:2026. Under ESPR Article 41(2), a digital product passport that conforms to these standards is now presumed to conform with the requirements in Articles 10 and 11 of ESPR. This is the presumption-of-conformity step that had been pending since the six standards were published on 27 May 2026. The two remaining standards, EN 18239 and EN 18246, are not part of this citation. What to do: make these six standards your DPP build specification and require your passport platform or service provider to conform to them in contracts and RFPs; the two uncited standards remain a watch item and no compliance deadline changes. For what each of the six standards governs, see the DPP Standards and Presumption of Conformity deep dive. Locked
On 19 July 2026 two distinct ESPR obligations begin, and they are often confused. The central DPP registry must be operational (Art. 13): it is EU infrastructure, an index of identifiers, not a per-product registration deadline; product passport duties bind category by category, batteries first on 18 February 2027. Separately, the Article 25 destruction ban on unsold apparel and footwear begins applying to large enterprises, with narrow documented derogations under C(2026) 659 and the Article 24 disclosure duty alongside it. A new Preparing for July 19 tab covers both obligations in full, with a four-question self-assessment, how-to-proceed steps, and the primary source documents. Locked
Battery card corrected and expanded after a cross-check against a primary-source-verified EU Batteries Regulation research package (CELEX 32023R1542 read directly). Corrections: the carbon-footprint declaration date is not February 2027; it applies 12 months after the EV methodology act enters into force (statutory anchor 18 Feb 2025, floating), while 18 February 2027 is when the declaration must be accessible via the battery passport. Article 7's three-step ladder (declaration, then performance classes, then a maximum lifecycle threshold gating market access) added to the battery card. Due-diligence dates now cite Reg (EU) 2025/1561 (Omnibus IV batteries strand, adopted 18 July 2025): due diligence 18 August 2027, Commission guidance due 26 July 2026. Omnibus IV digitalisation strand (COM(2025) 504/503) reached provisional political agreement 9 June 2026, adoption pending. Locked
Atlas baseline verified against primary sources. Confirmed: 19 July 2026 registry deadline, 18 February 2027 battery passport, the two Article 25 acts (C(2026) 659 and C(2026) 660), and Detergents Regulation (EU) 2026/405. Locked
EV battery carbon-footprint methodology act remains in draft. The Omnibus IV digitalisation strand (COM(2025) 504) is progressing and moves no DPP date; the adopted batteries strand, Reg (EU) 2025/1561, had already postponed due diligence to 18 August 2027. Signaled
The European Commission consulted industry on the draft Implementing Regulation for the EU Digital Product Passport Registry under ESPR Article 13, with the feedback period closing 27 May 2026 (ref. Ares(2026)4424976). The Registry indexes each product's unique identifier and its economic operator; it does not store passport content. The legal deadline for the Registry to be operational stays 19 July 2026. At the time, the implementing act was not yet adopted; it was adopted on 16 July 2026 as Commission Implementing Regulation (EU) 2026/1778 and the Registry went live to users on 20 July 2026 (see the 17 July 2026 entry). Signaled
CEN and CENELEC published the first six European standards for the Digital Product Passport on 27 May 2026 under Commission Standardisation Request M/604: EN 18216 (data exchange protocols), EN 18219 (unique identifiers), EN 18220 (data carriers), EN 18221 (data storage, archiving and persistence), EN 18222 (lifecycle and search APIs), and EN 18223 (system interoperability). Two further standards, EN 18239 (access rights and security) and EN 18246 (data authentication and integrity), closed their CEN-CENELEC formal vote on 16 July 2026, with final publication imminent and OJ citation still pending (indicative September 2026). Publication of the six gives industry a concrete technical basis to build DPP systems. At publication, citation in the Official Journal to confer presumption of conformity was still pending; it was completed on 14 July 2026 through Implementing Decision (EU) 2026/1736, in force 15 July 2026 (see the 15 July 2026 entry). For what each standard governs, see the DPP Standards and Presumption of Conformity deep dive. Locked
The Joint Research Centre published a preparatory study proposing Digital Product Passport content for textile apparel under the future ESPR delegated act. It applies to textile products at least 80% textile fibre by weight and proposes four data categories: product identification and classification, producer information, product information (fibre composition, mechanical durability, substances of concern, recycled content, environmental footprint), and compliance documentation, with a role-based access model separating public data from data available only to parties with a legitimate interest or to regulators. This is a preparatory study feeding the future delegated act, not the act itself; the Commission proposal is still expected late 2026, with adoption following and realistic compliance around 2028 to 2029. Signaled
The Council of the EU adopted its negotiating position on a Commission proposal amending the Critical Raw Materials Act (Regulation (EU) 2024/1252). The amendment would shift responsibility for identifying large companies in scope of Article 24 from Member States to the Commission, permit a digital product passport to satisfy the Article 27 permanent-magnet disclosure duty, and add measures to increase magnet recycling. Mohammed Chahim (S&D, Netherlands) was appointed European Parliament rapporteur on 10 February 2026; Parliament has not yet adopted its own position, and trilogue has not started. This does not change the CRMA's existing statutory dates (24 May 2027 list review, 1 January 2027 recycling-benchmark delegated acts), which remain Locked. Signaled
ESPR Atlas is an independent intelligence hub tracking the EU Ecodesign for Sustainable Products Regulation and Digital Product Passport framework. It is designed for manufacturers, importers, brands, and supply chain teams navigating a regulation that is still being written. Below: who builds and maintains this hub, the advisory work behind it, and how the data is kept current and trustworthy.
I'm Dave Hartter, a packaging and product sustainability advisor based in Charlotte, NC, with more than 20 years of sustainability, R&D and quality experience inside global manufacturers. I view sustainability as a driver of business performance, not just a reporting requirement: understand the market and regulatory environment, identify the risks and opportunities, and build programs that go beyond compliance to drive business value.
As Director of Sustainability, I led product sustainability at Huber Engineered Materials, a division of J.M. Huber. There, I applied tools such as Life Cycle Assessment and Portfolio Sustainability Assessment to understand the regulatory environment, market trends, and customer requirements to drive sustainability into business decisions and customer messaging. At Newell Brands, I led the development of the packaging sustainability program from the ground up, from developing 2025 goals aligned to internal and external stakeholders to building out the tools, systems and training that delivered measurable results. Sustainability programs are only successful when cross-functional teams are engaged and empowered with the tools and training necessary to deliver on the goals.
Today, I advise manufacturers and packaging suppliers directly. The Atlas hubs are the public side of that work. I built them so teams spend less time getting up to speed and more time delivering results. Connect with me on LinkedIn.
The Atlas provides the information necessary to understand what ESPR and the Digital Product Passport require and when each obligation lands. Companies throughout the value chain can then understand the near and long-term risks and opportunities to their business. Whether your company is just starting to scope its ESPR and DPP obligations or already knows a category deadline is coming and needs a plan to be ready, I can help.
Engagements I can help you with:
If you are working to future-proof your product and packaging portfolio, let's talk: info@hartteradvisory.com
ESPR establishes mandatory sustainability performance requirements for product categories sold in the EU, replacing the original Ecodesign Directive. The Digital Product Passport is the data layer: a machine-readable record that will accompany regulated products through their lifecycle. Both are enforced through delegated acts adopted category by category over several years.
This Atlas tracks: the foundational regulation and its key obligations; sector-specific delegated act status for the nine initial product categories; the DPP registry timeline; and legislative signals from EU institutions and the Omnibus simplification process. The Resources tab lists the primary regulatory texts and organizations whose work informs this Atlas.
This Atlas does not constitute legal, regulatory, or compliance advice. Verify all obligations and deadlines against the cited primary sources and with qualified legal counsel before acting.
| Label | What it means | When it changes |
|---|---|---|
| Locked | In force or published in the Official Journal. | The cited article or regulation is directly applicable EU law. These claims change only if the instrument is amended or repealed. |
| Signaled | Proposed, in a draft act, Working Plan, or official Commission communication. | The direction is set but text may still move. These claims change when the act is adopted or withdrawn. |
| Speculative | Industry expectation or planning assumption. | No binding instrument supports this claim. Use for scenario planning only. |
ESPR Atlas is the public version of Dave Hartter's advisory work, maintained from primary sources: EUR-Lex, European Commission communications and Working Plans, CEN/CENELEC, and the Global Battery Alliance. It is independent and not affiliated with any EU institution, standards body, or industry group.
It is reviewed on a rolling basis: political and policy developments are checked most frequently; category-specific delegated act progress is reviewed quarterly; and the foundational regulatory framework is re-verified semi-annually against primary sources. All updates are reviewed before publishing.
If you spot an error, an outdated claim, or a missing sector, use the button, or reach out at info@hartteradvisory.com. Corrections improve the Atlas for everyone.
ESPR Atlas is one of three regulatory intelligence sites:
Referencing ESPR Atlas in a memo, brief, or AI-assisted answer? Use the citation below. Every claim is dated and evidence-labelled, so cite the verified date alongside the URL.
ESPR Atlas, "EU Ecodesign (ESPR) and Digital Product Passport Intelligence Hub." ESPRAtlas.com. Maintained by Dave Hartter, Sustainability Advisor. Last verified the latest listed date; accessed today.