ESPR Sectors in Scope

Batteries Locked

Regulation: Batteries Regulation (EU) 2023/1542 · Key date: 18 February 2027 · Scope: EV batteries, LMT batteries, and industrial batteries over 2 kWh

Mandatory from 18 February 2027

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.

Approximately 90 data fields confirmed in the Batteries Regulation:

• Carbon footprint per kWh of battery lifetime (declaration applies 12 months after the EV methodology act enters into force; it must be accessible via the passport from 18 February 2027)
• Recycled content: cobalt, lithium, nickel, lead
• State of health and remaining capacity
• Capacity, voltage, and cycle life
• Due diligence documentation on raw material sourcing
• General model and cell chemistry information

Watch

• 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

What to do now: 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 expected June 2026.

Full Batteries guide →

Detergents Locked

Regulation: Detergents Regulation (EU) 2026/405 · Key date: 23 September 2029 · Scope: Detergents and surfactants placed on the EU market

Locked: regulation adopted, applies September 2029

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.

Known DPP and digital labelling requirements under Reg. (EU) 2026/405:

• Digital labelling, replacing some mandatory physical label requirements
• Biodegradability data for surfactants
• Dosage information and environmental dosage recommendations
• Safety data sheet links accessible via data carrier

What to do now: 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.

Full Detergents guide →

Iron and Steel Signaled

Regulation: ESPR delegated act (in preparation) · Key date: 2028 to 2029 (estimated compliance) · Scope: Iron and steel products; intermediate goods expected to be addressed first

Signaled: likely the first ESPR delegated act

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.

Expected DPP data requirements (not yet confirmed in an act):

• Embodied carbon and carbon footprint per tonne of product
• Recycled scrap content percentage
• Substances of concern
• Country of origin and production route

Watch

• 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

What to do now: 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.

Full Iron and Steel guide →

Textiles and Apparel Signaled

Regulation: ESPR delegated act (in preparation) + Article 25 destruction ban · Key date: 2028 to 2029 (estimated delegated act compliance) · Scope: Textile products and apparel; footwear is a separate, deferred category

Signaled: consultation closed, draft act in development

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.

Expected DPP data requirements (not yet confirmed in an act):

• Item-level traceability and serialization
• Fiber composition and recycled fiber content
• Microplastics release potential
• Disassembly and recycling instructions
• Chemical substances of concern

Watch

• 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

What to do now: 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.

Full Textiles and Apparel guide →

Aluminium Signaled

Regulation: ESPR delegated act (in preparation) · Key date: 2028 to 2030 (estimated) · Scope: Aluminium products; intermediate goods and semi-finished products expected to be in scope

Signaled: preparatory study and consultation underway

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.

Expected DPP data requirements (not yet confirmed in an act):

• Traceability through the supply chain
• Energy source mix used in smelting
• Recycled content percentage
• Carbon footprint per tonne
• Country of origin

Watch

• No delegated act has been proposed yet. Timeline is indicative. Monitor the Commission's consultation process and Working Plan progress reviews. Signaled

What to do now: 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.

Full Aluminium guide →

Tires Signaled

Regulation: ESPR delegated act (in preparation) · Key date: 2028 to 2030 (estimated) · Scope: Tires placed on the EU market

Signaled: preparatory study in progress

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.

Expected DPP data requirements (not yet confirmed in an act):

• Abrasion data and microplastic particle release potential
• Tire lifetime and wear performance metrics
• Compound composition and chemical substances of concern
• Recyclability and end-of-life information

Watch

• No delegated act proposed yet. Euro 7 tire wear data may create infrastructure synergies. Monitor the preparatory study for scope confirmation. Signaled

What to do now: 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.

Full Tires guide →

Furniture Signaled

Regulation: ESPR delegated act (in preparation) · Key date: 2030 or later (estimated) · Scope: Furniture products placed on the EU market

Signaled: early JRC preparatory study stage

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.

Likely focus areas based on JRC preparatory scope (not confirmed in an act):

• Durability and repairability criteria
• Hazardous adhesives and surface treatments
• Bio-based and recycled material provenance
• Disassembly and end-of-life instructions

Watch

• No consultation or draft act expected before 2027 at the earliest. Compliance would realistically not be required before 2030. Signaled

What to do now: 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.

Full Furniture guide →

Mattresses Signaled

Regulation: ESPR delegated act (in preparation) · Key date: 2030 or later (estimated) · Scope: Mattresses placed on the EU market

Signaled: longest runway in the Working Plan

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.

Likely focus areas based on Working Plan scoping (not confirmed in an act):

• Take-back and reuse information
• Foam and textile separation instructions for recycling
• Flame retardant substance declarations
• Material composition and hazardous substance content

Watch

• No consultation or draft act is expected before 2028. Compliance would realistically not be required before 2030 to 2031. Signaled

What to do now: 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.

Full Mattresses guide →

Footwear Signaled

Regulation: ESPR delegated act (not yet in Working Plan) + Article 25 destruction ban · Key date: Scoping study expected late 2027 · Scope: Footwear placed on the EU market

Signaled: not in first Working Plan; scoping study expected late 2027

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.

Watch

• 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

What to do now: 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.

Full Footwear guide →