Every EU Product Passport Deadline, and Which Ones Are Real

Almost every article about EU product passports gets the same thing wrong: it treats the Ecodesign for Sustainable Products Regulation (ESPR) as a set of deadlines. It is not. ESPR Art. 9(1) makes a passport mandatory only "in accordance with the applicable delegated acts adopted pursuant to Article 4", and as of 19 August 2026 no such delegated act has been adopted for any product.

So the honest map looks nothing like the usual one. Two passport obligations are binding with fixed dates, and neither of them comes from ESPR. Everything else is a working-plan estimate.

The timeline, with sources

Batteries: the only deadline that is close

The EU Battery Regulation (2023/1542) requires a battery passport from 18 February 2027 under Art. 77(1). The scope is narrower than most summaries claim, and getting it right saves real work.

In passport scope:

• Electric vehicle batteries, at any capacity
• LMT batteries: e-bikes, e-scooters and similar light means of transport, at any capacity
• Industrial batteries above 2 kWh (energy storage, backup)

Not in passport scope:

• Portable batteries (the cells in a power tool, a torch or a laptop)
• SLI batteries (the starter battery in a car)
• Both still need a QR code from 18 February 2027 pointing to label information, the declaration of conformity, the due diligence report and the Art. 74(1)(a) to (f) waste information. That is a much lighter job than a passport.

Textiles: no rule, and 2028 was never supportable

Textiles are the category most often sold with a fake deadline. There is no adopted delegated act. The JRC study on DPP content for textile apparel, dated 13 May 2026, is watermarked DRAFT and says its own findings "require validation through extensive stakeholder consultation". Working Plan COM(2025) 187 gives an indicative adoption of 2027, and ESPR Art. 4(4) requires at least 18 months between a delegated act entering into force and applying. That puts the earliest realistic application around mid-2029, and it will move if adoption slips.

What is binding for textile sellers today:

• Fibre names and weight percentages in descending order, and the statement "Contains non-textile parts of animal origin" where applicable: Reg. (EU) No 1007/2011 Arts. 9 and 12
• The ban on destroying unsold apparel, clothing accessories and footwear, for large enterprises, since 19 July 2026: ESPR Art. 25(1)
• Care symbols are not harmonised at EU level. ISO 3758 is voluntary.

Furniture and electronics: the weakest claims in the market

Furniture has no delegated act and no published preparatory study, which is a step further back than textiles. Indicative adoption is 2028, so application lands around 2030. Any furniture passport template being sold today, ours included, is a vendor's reading rather than a legal requirement, and it should be labelled that way.

What is binding for furniture today:

• Formaldehyde emissions at or below 0.062 mg/m3 for furniture and wood-based articles, since 6 August 2026: REACH Annex XVII entry 77 via Reg. (EU) 2023/1464
• EUDR due diligence for wooden furniture from 30 December 2026. Note the micro and small enterprise deferral to 30 June 2027 excludes products in the Annex to Reg. (EU) No 995/2010, which covers several 9403 subheadings, so small makers may be in scope from December 2026.

Electronics is in the same position: no adopted delegated act, no fixed date. The Right to Repair Directive (EU) 2024/1799 had a transposition deadline of 31 July 2026, so what binds you there is your Member State's implementing law, not a passport.

Toys: a real passport, from a regulation nobody expects

The toy passport is genuinely binding and genuinely citable, and it is not an ESPR passport. Regulation (EU) 2025/2509, in force since 1 January 2026, applies from 1 August 2030. Art. 19 requires a model-level passport carrying the 14 Annex VI Part I data points, available for 10 years, with a link to the EU Safety Gate Portal displayed whenever the passport is accessed (Art. 19(11)) and a back-up copy held by a DPP service provider whose reference goes inside the passport (Art. 19(13)). Art. 20 forbids requiring consumer registration or a password and forbids tracking beyond what is strictly necessary.

Toys placed on the market before 1 August 2030 may continue to be made available with no end date, so expect mixed catalogues well into the 2030s.

Can products be blocked at customs today? No

This is the claim to be most sceptical of, including on our own site historically. ESPR Art. 15 customs controls apply only to products covered by an Art. 4 delegated act, and none exists. The registry to EU CSW-CERTEX interconnection that would enable automated verification has an outer deadline calculated at 6 August 2030 under Art. 15(3). DG GROW stated on 27 May 2026 that battery passports do not have to be provided in electronic customs declarations. Until then, handing a registration identifier to customs is a manual step, not an automated gate.

What to actually do now

1. Work out whether any date binds you. If you make EV, LMT or large industrial batteries, February 2027 is six months away and the work is real. If you make toys, 2030 is far off but the data model is already adopted law, so you can build to it. If you sell textiles or furniture, no passport rule applies to you and anyone saying otherwise is selling fear.
2. Fix the obligations that do apply. Fibre labelling, formaldehyde limits, EUDR due diligence statements, the destruction ban and its disclosure format from 2 March 2027. These are unglamorous and enforceable today.
3. Audit your data, not your software. Getting material compositions, manufacturing country and supplier records out of a supply chain takes months. Filling in a form takes an afternoon. The slow part is the part to start now.
4. Check what you claim on the product page. From 27 September 2026 an uncertified sustainability label on a consumer-facing page is an unfair commercial practice. That deadline is five weeks away and it applies to everyone, whatever you sell.