In brief
- Only one date is certain today: the battery passport, mandatory from 18 February 2027 for industrial batteries, electric vehicle batteries and light means of transport batteries.
- Everything else sits in delegated acts: the first product groups are expected from 2026, textiles around 2027, each applying roughly eighteen months after adoption. Slippage of six to twelve months is normal in this field.
- Waiting for your date is the trap: the passport calls for data per product, composition, origin, repairability, that most catalogues simply do not hold, and that has to be collected from suppliers, slowly.
- The work is the same work other rules already demanded: product safety, environmental claims, customs. Four regulations, one single data project.
The digital product passport is the most trailed and the most badly dated obligation in European retail: a code on every product, opening onto its data on composition, origin, repairability and recycling. The question we get is always the same, “when does it hit me?”, and the honest answer has two halves: your date is probably not set, and it is the wrong place to start.
What has a date, and what does not
| Products | State of the timetable | What it means for you |
|---|---|---|
| Batteries, industrial, EV, light means of transport | Dated and certain: passport mandatory from 18 February 2027 under the Batteries Regulation | If you sell affected battery products, your project has already started at your suppliers |
| Iron, steel and the first groups in the working plan | Delegated acts expected from 2026 | Industry first, but it sets the formats everyone after them will inherit |
| Textiles, clothing, footwear | Delegated act expected around 2027, applying roughly eighteen months later, so realistically 2028 to 2029 | The preparation window is open, and it is exactly the right size for a supplier data project |
| Furniture, tyres, mattresses and the rest | Staggered behind, 2027 to 2029 | Same logic, more time |
The mistake that costs the most Reading “the date is not set” as “nothing to do”. The DPP is a data problem before it is a barcode problem: exact composition, origin per component, repairability, end of life instructions, per line item. That data sits with your suppliers, and product safety already showed what that means: getting it is a negotiation measured in months, not an integration measured in days. Eighteen months between the delegated act and the application date sounds generous; it is exactly the length of the supplier project, with nothing to spare.
The same job, for the fourth time
Look at what recent rules have already asked of you. General product safety: manufacturer, address, warnings, per line item and on the listing. Environmental claims: precise, provable facts instead of adjectives. Customs: tariff classification and origin per product. The passport adds detailed composition, repairability and end of life.
Four regulations, one underlying requirement: know exactly what you sell, and hold it in structured fields rather than free text. A brand that handled the first three properly has done half the passport without realising it. A brand that put its mandatory notices in PDFs and its compositions in the free description will do the whole thing again, every time a new text lands.
How to go about it, without rushing and without waiting
- Place yourself on the timetable. Batteries: dated, February 2027, and it is now. Textiles: the window is open, the pace is yours. Other sectors: keep watch, no urgency.
- Take stock of your product data. Across thirty line items: full composition? origin per component? end of life instructions? The share of gaps tells you the size of the project, exactly as it did for product safety.
- Build the request into your supplier orders. The cheapest lever there is: every new line item arrives with its data, contractually. Older stock catches up in waves, starting with what will still be selling in two years.
- Structure it in the shop, not in a separate file. Fields per attribute, translatable, exportable: what feeds the listing today will feed the passport tomorrow, and the marketplaces in between.
- Do not sign anything sold as “DPP compliant” today. The exact formats will come from the delegated acts; a tool sold as compliant before the texts exist is selling a promise. The data is the only no regret investment.
A thirty minute self diagnosis: take ten line items and try to fill in four lines for each, exact composition, origin, repairability, end of life. Your score out of forty is your state of readiness, and it will not improve on its own.
The options, and what they are worth
| Approach | What it gets you | Who it suits |
|---|---|---|
| Collect from suppliers as orders go out | The lowest marginal cost there is: the data arrives with the product, and existing stock fills in by waves | Everyone, starting with the next order |
| Structured fields in the shop | Enter once, use several times: listing, safety, claims, customs, passport. This is the investment that pays back four times over | Catalogues beyond a few hundred line items |
| Wait for your sector’s delegated act | Sensible for the technical formats, ruinous for the data: eighteen months will not fill an empty catalogue | For the technical side only, never for the data |
| Buy a full “DPP solution” today | The formats are not fixed: you are buying a promise and a dependency. Data first, tooling once the texts are out | Nobody before the delegated acts, batteries aside |
The tooling
On PrestaShop, we deploy for our clients the module published by Datafirefly Limited, our agency’s sister company: Digital Product Passport puts the passport’s structured fields into the shop and exposes them per product, so you can start collecting without waiting for the final formats. One-off purchase · 12 months of updates.
Method beats tooling, and on this subject more than any other: the regulatory formats are not settled, the data is. A module lays down fields in an hour; filling them from your suppliers is the actual project, and it is what decides whether your sector finds you ready or scrambling.
The bigger picture
The DPP is not one more constraint, it is the destination all the recent constraints were stages towards: the product listing becomes a product file, verifiable, structured, portable. Brands that see this early turn each obligation into a head start on the next; the others redo the same job every eighteen months, in a hurry.
This is the thread running through our e-commerce and marketplaces expertise: product data has become an asset in the same way stock is. And this is exactly the sort of moving deadline our compliance calendar tracks: dates go in when the texts fix them, with an alert to start in time.
Sources
The verifiable claims in this article link to their primary source, accessed on 12 August 2026. We do not cite a source we have not read.
- Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, Chapter III, digital product passport. Open
- Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries, Article 77(1), battery passport from 18 February 2027. Open
FAQ
I sell textiles: what is my exact date?
It does not exist yet: the textiles delegated act is expected around 2027, applying roughly eighteen months after adoption, so realistically 2028 to 2029. That is a window, not a date, and it is exactly the size of the supplier collection project. One French textile rule, on the other hand, already has a date: from 1 October 2026, any environmental score shown on a garment requires you to display the official environmental cost as well, and that calculation draws on the same composition and origin data.
I resell, I do not manufacture: does it still apply to me?
The passport falls first on whoever places the product on the market, but you will have to display and link that data, and your marketplaces will ask you for it just as they did for product safety. Your lever is contractual: require the data from your suppliers now.
QR code, chip, which carrier?
The data carrier will be set by delegated act, product group by product group; the battery passport runs through a code on the battery. It is the simplest and the latest part of the job: a code is printed in weeks, data is collected over years.
Can the dates still slip?
Yes, and they already have: the first acts planned for late 2025 are now expected during 2026, and this field slips by six to twelve months. All the more reason not to pin your preparation to a date: data is collected at the pace of your orders, whatever the final deadline turns out to be.
Can Dotsland help?
Yes. Taking stock of your product data, building collection into your supplier orders, structuring the fields in the shop, and watching the delegated acts for your sector. It is one of the projects within our e-commerce and marketplaces expertise. Let’s talk, or start with the score out of forty from the self diagnosis.