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, the most mature DPP category, falls under the Batteries Regulation rather than ESPR but uses the same DPP infrastructure. The AAS / Catena-X guideline (February 2026) is the most concrete buildable specification, with Eclipse Tractus-X as reference implementation. Automotive and large-cell producers are readiest, while smaller producers outside these ecosystems face more fragmented paths.

Annex XIII sets battery passport content in four access tiers (71 data points per the Commission August 2026 guidance):

• Carbon footprint per kWh of battery lifetime (declaration applies 12 months after the EV methodology act enters into force; passport access required 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 had not been adopted by 30 September 2026. It gates PCF declaration enforcement, so hold your carbon-footprint reporting approach until adoption. Speculative

What to do now: Build against the AAS / Catena-X guideline and confirm your unique identifier path under ISO/IEC 15459 (Batteries Regulation Art. 77(3)), while monitoring GBA operational trial results, expected June 2026 and not yet confirmed released.

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, not an ESPR delegated act, using the same DPP infrastructure. Replacing Regulation (EC) 648/2004, it adds digital labeling and updated biodegradability and safety data obligations.

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

• Digital labeling, 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: Check whether your products are in scope; September 2029 leaves runway, but formulary data flows and digital labeling infrastructure should be mapped well before it.

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 leads the first Working Plan for ESPR delegated acts; its public consultation closed on 12 August 2026 and no act has been adopted yet, so steel supply-chain businesses should watch it most closely.

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

• The indicative 2028 to 2029 compliance timeline will shift if adoption slips; the act is not adopted, and the Commission indicates adoption in Q4 2026. Signaled

What to do now: The iron and steel ecodesign act consultation ran 20 May to 12 August 2026, and the Commission is processing feedback; the act, not adopted, and the Commission indicates adoption in Q4 2026, is the only Working Plan category at this stage. Prepare verified embodied-carbon and recycled-content data now, since regulated downstream customers will request it before your deadline.

Full Iron and Steel guide

Textiles and Apparel Signaled

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

Signaled: pre-draft, no draft act published

Textiles is a top-priority first Working Plan category, but no draft delegated act has been published or consulted on, and JRC preparatory studies are the only public material. Large apparel enterprises already face the Article 25 destruction ban on unsold goods from 19 July 2026, well before 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

• The Article 25 destruction ban already applies to large enterprises for unsold apparel and footwear from 19 July 2026, as confirmed law preceding the DPP delegated act. Locked
• Delegated act: not adopted; the Commission plans adoption for Q4 2027 on its DPP timeline. With ESPR Art. 4(4) allowing at least 18 months after entry into force, indicative compliance is unlikely before mid-2029. Signaled
• The JRC May 2026 preparatory study proposes four DPP content categories (identification, producer information, product information, and compliance documentation) with role-based access for products at least 80% textile fiber by weight, subject to change before the delegated act is proposed. Signaled

What to do now: Large enterprises with unsold apparel inventory should verify Article 25 compliance. Separately, monitor the ESPR delegated act consultation and map item-level data flows and fiber content tracking to the four JRC categories.

Full Textiles and Apparel guide

Aluminum Signaled

Regulation: ESPR delegated act (in preparation) · Key date: 2029 to 2030 (estimated) · Scope: Aluminum products; intermediate goods and semi-finished products expected to be in scope

Signaled: preparatory study and consultation underway

Aluminum is in the first Working Plan, with preparatory study and stakeholder consultation underway. Expected data challenges are smelting energy mix (green versus gray aluminum) and smelter-to-product traceability.

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, and the timeline is indicative. Monitor the Commission consultation process and Working Plan progress reviews. Signaled

What to do now: Start preparing energy-source and recycled-content data at smelter or mill level, since regulated downstream customers will request it before their own deadlines.

Full Aluminum guide

Tires Signaled

Regulation: ESPR delegated act (in preparation) · Key date: 2029 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 builds on Euro 7 tire wear and rolling-resistance data infrastructure, which may ease data collection for producers preparing for Euro 7.

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, and map any Euro 7 data infrastructure 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 at an early JRC (Joint Research Centre) preparatory study stage in the first Working Plan, with no stakeholder consultation open, making it lower-urgency 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 is 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, and consider building material data infrastructure before consultation 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, with no consultation open; the preparatory study targets hard end-of-life issues such as foam-textile separation and flame retardant declarations.

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 for take-back logistics and any difficult flame retardant and substance supply chain data.

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 outside the first Working Plan, and a delegated act could follow a scoping study expected by late 2027. Large footwear enterprises already face the confirmed Article 25 destruction ban on unsold goods from 19 July 2026.

Watch

• The Article 25 destruction ban applies to large enterprises for unsold footwear from 19 July 2026, and any derogation requires five-year record-keeping. Locked
• The 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: Large enterprises with unsold footwear inventory should focus on Article 25 compliance; no ESPR DPP action is required yet, but watch the scoping study expected late 2027.

Full Footwear guide