--- title: "EU Digital Product Passport (DPP) Timeline and Compliance Decision Flow" canonical_url: "https://www.sorena.io/artifacts/eu/digital-product-passport" source_url: "https://www.sorena.io/artifacts/eu/digital-product-passport" author: "Sorena AI" description: "A practical EU Digital Product Passport (DPP) artifact grounded in ESPR (Regulation (EU) 2024/1781): key milestones, current implementation status." published_at: "2026-03-04" updated_at: "2026-03-04" keywords: - "EU Digital Product Passport" - "Digital Product Passport DPP" - "ESPR" - "Ecodesign for Sustainable Products Regulation" - "Regulation (EU) 2024/1781" - "digital product passport requirements" - "DPP data carrier" - "DPP QR code" - "unique product identifier" - "DPP registry" - "DPP web portal" - "customs checks" - "DPP compliance checklist" - "DPP implementation guide" - "DPP architecture" - "DPP data requirements" - "DPP access control" - "Digital Product Passport" - "Traceability" - "Compliance" - "QR code" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU Digital Product Passport (DPP) Timeline and Compliance Decision Flow A practical EU Digital Product Passport (DPP) artifact grounded in ESPR (Regulation (EU) 2024/1781): key milestones, current implementation status. ![EU Digital Product Passport (DPP) artifact preview](https://cdn.sorena.io/cdn-cgi/image/format=auto/cheatsheets/prod/sorena-ai-eu-espr-dpp-timeline-small.jpg?v=cheatsheets%2Fprod) *Digital Product Passport* *Free Resource* ## EU Digital Product Passport Timeline and Decision Flow Use this artifact to scope DPP applicability and responsibilities, then convert ESPR (Regulation (EU) 2024/1781) requirements into a shipped implementation: data carriers (QR/ID), unique identifiers, open standards, access control, registry and customs readiness. The first ESPR working plan was released in April 2025 and the EU registry deadline is 19 July 2026. This is a practical implementation resource, not legal advice. DPP obligations are product-group specific and are defined in delegated acts adopted under ESPR Article 4. Always validate final decisions against primary sources and your product scope. [Get implementation support](/contact.md) ## What you can decide faster - **Applicability**: Is your product group covered by a delegated act, and at what level (model/batch/item)? - **Data + IDs**: What data fields are required (Annex III) and what identifiers/data carriers you need. - **Architecture**: How to implement open standards, access control, registry integration and audit evidence. By Sorena AI | Updated Mar 2026 | No signup required ### Quick scan *DPP* - **Timeline view**: Track the April 2025 working-plan rollout and the July 2026 registry deadline. - **Decision flow**: Scope roles, obligations and technical requirements. - **Topic guides**: Deep dives: requirements, data, carriers, architecture, audit. Use the artifact + topic guides to build an audit-ready DPP implementation that avoids vendor lock-in, aligns to the current ESPR rollout, and supports customs and market-surveillance needs. | Value | Metric | | --- | --- | | ESPR | Legal basis | | 9-15 | Core DPP articles | | Annex III | Data fields | | Registry | EU system | **Key highlights:** Scope first | Data carrier (QR/ID) | Unique identifiers | Open standards | Access control | Audit evidence ## Topic Guides - [DPP Applicability Test (ESPR Scoping) | EU Digital Product Passport](/artifacts/eu/digital-product-passport/applicability-test.md): A step-by-step applicability test for the EU Digital Product Passport (DPP): whether your product group is covered by an ESPR delegated act. - [DPP Architecture & Integration (Open Standards, Registry, APIs) | EU Digital Product Passport](/artifacts/eu/digital-product-passport/architecture-and-integration.md): An advanced architecture guide for EU Digital Product Passport (DPP): product-centric identifiers and resolvers. - [DPP Data Carriers, Access Control & UX | QR Code, Identifier, Public vs Restricted Views](/artifacts/eu/digital-product-passport/data-carriers-access-control-and-ux.md): A deep guide to DPP data carriers and UX under ESPR 2024/1781: physical data carrier requirements (Article 10), persistent unique product identifiers. - [DPP Data Governance RACI Template | EU Digital Product Passport](/artifacts/eu/digital-product-passport/dpp-data-governance-raci-template.md): Copy/paste-ready governance templates for EU Digital Product Passport (DPP): RACI by Annex III field. - [DPP Data Requirements & Fields (Annex III) | EU Digital Product Passport](/artifacts/eu/digital-product-passport/data-requirements-and-fields.md): A practitioner guide to EU DPP data requirements under ESPR (Regulation (EU) 2024/1781): what data fields can be required (Annex III). - [DPP Governance, Verification & Audit Readiness | EU Digital Product Passport](/artifacts/eu/digital-product-passport/governance-verification-and-audit.md): An audit-readiness guide for EU Digital Product Passport (DPP): how to prove DPP data is accurate, complete and up to date (Article 9). - [DPP Implementation Playbook & Vendor Selection | EU Digital Product Passport](/artifacts/eu/digital-product-passport/implementation-playbook-and-vendor-selection.md): A practical playbook for implementing EU Digital Product Passport (DPP): program steps, roles, supplier onboarding, data model and identifiers. - [DPP QR Code Implementation Guide | Data Carrier + Identifier Design](/artifacts/eu/digital-product-passport/dpp-qr-code-implementation-guide.md): A practical implementation guide for using QR codes (and other data carriers) for EU Digital Product Passports: what ESPR requires (Article 10). - [DPP vs Traditional Product Passports (Labels, PDFs, EPREL) | EU Digital Product Passport](/artifacts/eu/digital-product-passport/dpp-vs-traditional-product-passports.md): A deep comparison of the EU Digital Product Passport (DPP) vs traditional product information approaches: physical labels, PDFs/manuals. - [ESPR / DPP Penalties & Fines | EU Digital Product Passport Enforcement](/artifacts/eu/digital-product-passport/penalties-and-fines.md): How penalties work for EU Digital Product Passport obligations under ESPR (Regulation (EU) 2024/1781): Member States set effective. - [EU Digital Product Passport (DPP) Checklist | Audit-Ready Implementation Steps](/artifacts/eu/digital-product-passport/checklist.md): An audit-ready DPP checklist for ESPR 2024/1781: delegated act scoping, model/batch/item granularity, Annex III data mapping, data carriers (QR/ID). - [EU Digital Product Passport (DPP) Compliance Guide | Implementation Playbook](/artifacts/eu/digital-product-passport/compliance.md): A practical compliance guide for EU Digital Product Passport (DPP) under ESPR 2024/1781: how to scope delegated acts, implement Articles 9-15 requirements. - [EU Digital Product Passport (DPP) Deadlines & Compliance Calendar | ESPR 2024/1781](/artifacts/eu/digital-product-passport/deadlines-and-compliance-calendar.md): A calendar-ready timeline for EU Digital Product Passport (DPP) under ESPR (Regulation (EU) 2024/1781): entry into force (18 Jul 2024). - [EU Digital Product Passport (DPP) FAQ | ESPR 2024/1781](/artifacts/eu/digital-product-passport/faq.md): Answers to the most searched EU DPP questions: is DPP mandatory, which products are in scope, model vs batch vs item, what data is required (Annex III). - [EU Digital Product Passport (DPP) Requirements | ESPR Articles 9-15 + Annex III](/artifacts/eu/digital-product-passport/requirements.md): A detailed, execution-ready breakdown of EU Digital Product Passport (DPP) requirements under ESPR (Regulation (EU) 2024/1781): availability (Article 9). - [What Is a Digital Product Passport (DPP)? | EU ESPR 2024/1781](/artifacts/eu/digital-product-passport/what-is-a-dpp.md): A deep explainer of the EU Digital Product Passport (DPP) under ESPR (Regulation (EU) 2024/1781): definition, who uses it, what data it contains (Annex III). ## Key milestones for Digital Product Passport *Timeline* Use timeline milestones to sequence policy, engineering, supplier onboarding, registry readiness, and assurance work. ## How to operationalize Digital Product Passport *Decision Flow* Use the decision flow to turn applicability and requirement questions into clear actions, owners and evidence deliverables. *Next step* ## Turn EU Digital Product Passport Timeline and Decision Flow into an ESG delivery workflow EU Digital Product Passport Timeline and Decision Flow should be the shared entry point for your team. Route execution into ESG Compliance for live work and into SSOT when the artifact needs deeper research, evidence governance, or supporting analysis. - Start from EU Digital Product Passport Timeline and Decision Flow and route the work by entity, product, team, or control owner. - Use ESG Compliance to manage cross team sustainability work, reporting, and evidence from one workflow. - Use SSOT to keep documents, evidence, and control records in one governed system. - Move from artifact reading to accountable execution without rebuilding the guidance in separate files. - [Open ESG Compliance](/solutions/esg-compliance.md): Manage cross team sustainability work, reporting, and evidence from one workflow for EU Digital Product Passport Timeline and Decision Flow. - [Open SSOT](/solutions/ssot.md): Keep documents, evidence, and control records in one governed system from the same artifact. - **Download decision flow**: Share scope logic internally. - **Download timeline**: Coordinate milestones across teams. - [Talk through EU Digital Product Passport Timeline and Decision Flow](/contact.md): Review your current process, evidence model, and next steps for EU Digital Product Passport Timeline and Decision Flow. ## Decision Steps ### STEP 1: Are you placing a physical product on the EU market? *Reference: Art. 1(1), Art. 1(2), Art. 4* - ESPR applies to physical goods placed on the EU market or put into service, including components and intermediate products. - Some product categories are excluded (for example, food and feed, medicinal products, living organisms, products of human origin, and certain vehicles for aspects already addressed by sector-specific Union law). - If yes, continue to check whether your product is excluded. If no, ESPR does not apply to that product placement. - **NO** Out of Scope - **YES** Is your product excluded from ESPR scope? ### STEP 2: Is your product excluded from ESPR scope? *Reference: Art. 1(2)* - Check if your product is food/feed, medicinal product, living organism, or a vehicle for which sector-specific EU law already sets requirements. - If yes, ESPR does not apply. - If no, continue to check if a product-specific delegated act has been adopted. - **YES** Out of Scope - **NO** Has a delegated act setting ecodesign requirements been adopted for your product group? ### STEP 3: Has a delegated act setting ecodesign requirements been adopted for your product group? *Reference: Art. 4, Art. 18(3)* - The Commission sets ecodesign requirements by delegated acts for specific product groups (or horizontally for product groups with similar characteristics). - The delegated act will specify the requirements, dates of application, and (where relevant) conformity assessment, markings, and information tools like the DPP and labels. - If yes, your product must comply with the delegated act. If no, ESPR product-specific requirements are not yet in force for that product group, but some general obligations may still apply (for example, rules on unsold consumer products). - **YES** Ecodesign requirements apply to your product - **NO** General ESPR obligations apply even without delegated act ### TRACK 1: Ecodesign requirements apply to your product *Reference: Art. 4, Art. 5(8), Art. 6, Art. 7* - Your product must comply with the performance requirements and information requirements set out in the delegated act, where relevant to your product group. - The delegated act will also specify how compliance is assessed (conformity assessment procedure) and how conformity is indicated (CE marking or alternative conformity marking). - Economic operator obligations apply based on your role (manufacturer, importer, distributor, dealer, etc.). - -> What is your role as an economic operator? ### STEP 5: What is your role as an economic operator? - Manufacturer (and in some cases importers or distributors are treated as manufacturers). - Authorised representative (appointed by a manufacturer via written mandate). - Importer (placing product from a third country on the EU market for the first time). - Distributor (making a product available on the market after it has been placed by manufacturer or importer). - Dealer (offering product for sale, hire or hire purchase, or displaying to customers/installers). - Fulfilment service provider (warehousing, packaging, addressing, dispatching). - Provider of an online marketplace (and in-scope online search engine obligations). - Each role has specific obligations. - -> Does the delegated act require a Digital Product Passport (DPP)? ### STEP 6: Does the delegated act require a Digital Product Passport (DPP)? *Reference: Art. 9, Art. 10, Art. 11* - If a DPP is required, the product can only be placed on the market or put into service if a DPP is available in accordance with the delegated act and the essential requirements in the Regulation. - The delegated act will specify the DPP data, data carrier(s), accessibility before purchase (including distance selling), access rights, and who can create or update the passport. - Some product groups can be exempted from the DPP requirement where technical specifications are not available or where another Union law provides a comparable digital information system. - **YES** Does the delegated act require product labels? - **NO** Does the delegated act require product labels? ### STEP 7: Does the delegated act require product labels? *Reference: Art. 16, Art. 32* - Where information requirements indicate that information is to be included in a label, the delegated act will specify label content, layout and display requirements (including distance selling). - If labels are required, economic operators must provide labels and dealers must display them as required by the delegated act. - **YES** Does the delegated act set performance requirements? - **NO** Does the delegated act set performance requirements? ### STEP 8: Does the delegated act set performance requirements? *Reference: Art. 5, Art. 6* - Performance requirements set minimum or maximum levels for one or more product parameters in Annex I, to improve relevant product aspects. - If yes, ensure the product meets the performance requirements before placing it on the market or putting it into service. - **YES** Does the delegated act set information requirements? - **NO** Does the delegated act set information requirements? ### STEP 9: Does the delegated act set information requirements? *Reference: Art. 7* - Information requirements specify product information to be made available (e.g., environmental footprint, durability, repair instructions). - Information can be provided via DPP, label, product manual, website, or other means as specified in delegated act. - If yes, ensure required information is made available in the specified manner. - **YES** What conformity assessment procedure applies? - **NO** What conformity assessment procedure applies? ### STEP 10: What conformity assessment procedure applies? *Reference: Art. 4(5), Art. 43* - Conformity assessment procedures range from internal production control (Module A) to more stringent modules involving notified bodies. - The delegated act specifies the applicable conformity assessment module for the product group. - Some modules involve notified bodies, depending on the module specified in the delegated act. - -> ESPR Ecodesign Requirements Apply (Full Compliance) ### TRACK 2: General ESPR obligations apply even without delegated act *Reference: Art. 23, Art. 24, Art. 25* - If no delegated act applies to your product group, ESPR product-specific ecodesign requirements are not yet in force for that product group. - However, Chapter VI sets rules on preventing and (for certain products) prohibiting the destruction of unsold consumer products, and on disclosing information about discarded unsold consumer products. - -> Does the destruction ban apply to your product? ### STEP 11: Does the destruction ban apply to your product? *Reference: Art. 23, Art. 24, Art. 25, Annex VII* - If you discard unsold consumer products (directly or via a third party), you may have a disclosure obligation. - From 19 July 2026, destruction of unsold consumer products listed in Annex VII is prohibited (subject to exemptions). - Micro and small enterprises are exempt from the prohibition, and the prohibition applies to medium-sized enterprises from 19 July 2030. - **YES** General ESPR Obligations Apply - **NO** General ESPR Obligations Apply ## Reference Information ### Products In Scope (Overview) - ESPR sets a framework for ecodesign requirements for physical products placed on the EU market or put into service, including components and intermediate products. - Product-specific requirements apply only when the Commission adopts a delegated act for a product group (and the delegated act will set dates of application). - Ecodesign requirements can include performance requirements and information requirements. - Information requirements can be delivered through tools like the digital product passport and (where applicable) labels. ### Key Exclusions - Food and feed as defined in Regulation (EC) No 178/2002. - Medicinal products (Directive 2001/83/EC) and veterinary medicinal products (Regulation (EU) 2019/6). - Living plants, animals and micro-organisms; products of human origin; products of plants and animals relating directly to their future reproduction. - Vehicles (Regulations (EU) No 167/2013, No 168/2013, 2018/858) for aspects already addressed by sector-specific Union law. ### Authorised Representative Obligations - A manufacturer may appoint an authorised representative by written mandate (Art. 28(1)). - The mandate cannot cover the manufacturer's obligations in Art. 27(1) or the drawing up of technical documentation (Art. 28(1)). - Keep the EU declaration of conformity and technical documentation available to market surveillance authorities for 10 years (unless a delegated act sets a different period) (Art. 28(2)(a)). - Cooperate with competent national authorities and provide information and documentation within 15 days upon a reasoned request (Art. 28(2)(b)-(c)). - Terminate the mandate if the manufacturer acts contrary to its obligations (Art. 28(2)(d)). ### Manufacturer Obligations - For products covered by a delegated act: ensure the product is designed and manufactured in accordance with performance requirements and accompanied by required information (Art. 27(1)(a)-(b)). - Ensure a digital product passport is available where required, including a back-up copy via a digital product passport service provider (Art. 27(1)(c), Art. 10(4)). - Carry out the conformity assessment procedure specified in the delegated act and draw up technical documentation (Art. 27(2)). - Draw up the EU declaration of conformity and affix the CE marking (or the alternative conformity marking specified in the delegated act, if applicable) (Art. 27(2), Art. 44, Art. 46, Art. 4(6)(d)). - Keep technical documentation and the EU declaration of conformity for 10 years (unless the delegated act specifies a different period) (Art. 27(3)). - Ensure products bear an identifier (type, batch, serial number, or equivalent) (Art. 27(5)). - Provide manufacturer name and contact details on the product/packaging and, where applicable, on the public part of the DPP (Art. 27(6)). - Provide digital instructions (plus paper safety information) and keep digital instructions accessible online for at least 10 years (Art. 27(7)). - If you believe a product is non-compliant, take corrective action (including withdrawal/recall where appropriate) and inform market surveillance authorities (Art. 27(8)). ### Importer Obligations - For products covered by a delegated act: place on the market only products that comply with the applicable delegated act (Art. 29(1)). - Before placing a product on the market: ensure conformity assessment and technical documentation are done, required information is provided, and a DPP is available where required (Art. 29(2)(a)-(c)). - Ensure the product bears the CE marking (where applicable) or the alternative conformity marking specified in the delegated act, and the manufacturer has complied with identification and contact details requirements (Art. 29(2), Art. 45, Art. 46, Art. 27(5)-(6)). - Provide importer name and contact details on the product/packaging and, where applicable, on the public part of the DPP (Art. 29(3)). - Ensure digital instructions accompany the product (Art. 29(4)). - Ensure storage and transport conditions do not jeopardise compliance (Art. 29(5)). - If you believe a product is non-compliant, take corrective action (including withdrawal/recall where appropriate) and inform market surveillance authorities (Art. 29(6)). - Keep a copy of the EU declaration of conformity and ensure technical documentation can be made available for 10 years (unless the delegated act specifies a different period) (Art. 29(7)). - Provide information and documentation on request within 15 days and cooperate with authorities (Art. 29(8)). ### Distributor Obligations - For products covered by a delegated act: act with due care in relation to the requirements in the applicable delegated acts (Art. 30(1)). - Before making a product available: verify CE marking (or alternative conformity marking), and where relevant that the product is labelled or linked to a DPP, and that required documents and digital instructions are provided (Art. 30(2)). - Verify that the manufacturer and importer have complied with required identification and contact details obligations (Art. 30(2)(c), Art. 27(5)-(6), Art. 29(3)). - If you believe a product is not in conformity, do not make it available until it is brought into conformity (Art. 30(3)). - Ensure storage and transport conditions do not jeopardise compliance (Art. 30(3)). - If you believe a product you made available is non-compliant, ensure corrective action is taken (withdraw/recall where appropriate) and inform market surveillance authorities (Art. 30(4)). - Provide information and documentation on request within 15 days and cooperate with authorities (Art. 30(5)). ### Dealer Obligations - Ensure customers and potential customers can access the information required by the delegated act, including in the event of distance selling (Art. 31(1)). - Where a DPP is required, ensure it is easily accessible for customers and potential customers, including in the event of distance selling (Art. 31(2), Art. 9(2)(e)). - Where labels are required: display labels visibly, reference label information in visual advertisements and technical promotional material, and do not display other labels/marks that mislead or confuse customers (Art. 31(3)). ### Fulfilment Service Provider Obligations - For products covered by a delegated act that you handle: ensure that conditions during warehousing, packaging, addressing or dispatching do not jeopardise compliance with that delegated act (Art. 33). - In some cases of non-compliance, fulfilment service providers can be liable for consumer damage (Art. 76(c)). ### Online Marketplace Provider Obligations - General obligations under Regulation (EU) 2022/2065 apply for the purposes of ESPR (Art. 35(1)). - Cooperate with market surveillance authorities, at their request and in specific cases, to eliminate or mitigate the non-compliance of products offered online through your services (Art. 35(1)). - Market surveillance authorities can order removal of content referring to non-compliant products offered for sale online (Art. 35(2)). - Establish a single contact point for direct communication with market surveillance authorities (Art. 35(3)). ### Distance Selling: Product Offer Information - When selling a product covered by a delegated act through distance selling, ensure the product offer clearly and visibly includes manufacturer identity and contact details (Art. 36(1)(a)). - If the manufacturer is not established in the Union, include the EU-based economic operator required under Regulation (EU) 2019/1020 (Art. 36(1)(b)). - Include product identification information, including a picture, type, and other product identifier (Art. 36(1)(c)). - Maintain supply chain traceability information (who supplied you; who you supplied; quantities and exact models) for 10 years and provide it within 15 days upon request (Art. 36(2)). ### Digital Product Passport (DPP) Requirements - If a DPP is required, the product can only be placed on the market or put into service if a DPP is available; DPP data must be accurate, complete and up to date (Art. 9(1)). - The delegated act will specify DPP content and operational requirements (data carriers, layout/positioning, level, accessibility before purchase, access rights, who can create/update data, and availability period) (Art. 9(2)). - The DPP must comply with essential requirements, including a data carrier connected to a persistent unique product identifier; interoperable/open standards; machine-readable, structured and searchable data; and no customer personal data without explicit consent (Art. 10(1)). - The economic operator placing the product on the market must provide dealers and providers of online marketplaces with a digital copy of the data carrier or unique product identifier (or a link) and, upon request, do so within 5 working days (Art. 10(3)). - The economic operator must make a back-up copy of the DPP available through a digital product passport service provider (Art. 10(4)). - Technical design and operation requirements include interoperability, access by stakeholders based on rights, integrity/security, and availability for the period set in the delegated act (Art. 11). - The Commission must set up a DPP registry by 19 July 2026, and the economic operator placing the product on the market uploads required data to the registry (Art. 13(1), Art. 13(4)). ### Label Requirements - Where a delegated act requires a label under Art. 16, the delegated act will specify label content, layout, and how it must be displayed to customers (including distance selling) (Art. 16(1)). - Labels can include data carriers or other means to allow customers to access additional information, including access to the DPP where appropriate (Art. 16(4)). - If a delegated act requires a label, economic operators placing products on the market must ensure each unit is accompanied by printed labels, provide labels to dealers within 5 working days upon request, and keep technical documentation to support label accuracy (Art. 32(1)). - Dealers must display labels and reference label information in advertisements and promotional material, and must not display other labels/marks that mislead or confuse customers about the ESPR label information (Art. 31(3), Art. 32(2)). - Products with labels that mislead or confuse customers by mimicking ESPR labels must not be placed on the market or put into service (Art. 17). ### Performance Requirements (Examples) - Performance requirements aim to improve relevant product aspects such as durability, reliability, reusability, upgradability, repairability, and maintenance/refurbishment (Art. 5(1)(a)-(f)). - They can address substances of concern, energy and water use, resource use, recycled content, remanufacturing, recyclability and material recovery (Art. 5(1)(g)-(n)). - They can address environmental impacts, including carbon footprint and environmental footprint, and expected generation of waste (Art. 5(1)(o)-(p)). - Delegated acts can also include measures to prevent premature obsolescence (Art. 5(2)). ### Information Requirements (Examples) - Information requirements can include information on product performance (for example, repairability score, durability score, carbon footprint or environmental footprint) (Art. 7(2)(b)(i)). - They can include customer and other actor information on installation, use, maintenance and repair, and end-of-life handling (Art. 7(2)(b)(ii)-(iv)). - Where appropriate, the Commission can determine classes of performance to help customers compare products (Art. 7(4)). - Information requirements must enable tracking substances of concern throughout the product life cycle, subject to thresholds and exemptions set in delegated acts (Art. 7(5)-(6)). - Required information is made available in the manner specified by the delegated act; where a DPP is available, required information is provided in the DPP and may also be provided via product, packaging, label, documentation, or a free access website/app (Art. 7(7)). ### Conformity Assessment and CE Marking - For products covered by a delegated act, the manufacturer must carry out the conformity assessment procedure specified in that delegated act and draw up technical documentation (Art. 27(2)). - The manufacturer draws up an EU declaration of conformity (Art. 44) and affixes the CE marking (Art. 46), unless the delegated act specifies an alternative conformity marking (Art. 4(6)(d)). - Conformity assessment modules are selected from Annex IV (Module A) or modules in Decision No 768/2008/EC, as specified in delegated acts (Art. 4(5)). - Tests, measurements and calculations for compliance use harmonised standards or other reliable methods specified in delegated acts (Art. 39), and harmonised standards can provide presumption of conformity (Art. 41). - Keep technical documentation and the EU declaration of conformity for 10 years (unless the delegated act specifies a different period) (Art. 27(3), Art. 29(7)). ### Destruction of Unsold Products: Ban and Disclosure - Economic operators must take reasonable measures to prevent the need to destroy unsold consumer products (Art. 23). - Economic operators that discard unsold consumer products (directly or via a third party) must disclose annual information on their website (number/weight, reasons, treatment route proportions, and measures taken/planned) (Art. 24(1)). - The disclosure obligation does not apply to micro and small enterprises and applies to medium-sized enterprises from 19 July 2030 (Art. 24(1)). - From 19 July 2026, destruction of unsold consumer products listed in Annex VII is prohibited, subject to exemptions; micro and small enterprises are exempt and medium-sized enterprises are included from 19 July 2030 (Art. 25(1)). - Economic operators not subject to the prohibition must not destroy products supplied to them to circumvent the prohibition (Art. 25(2)). - The Commission can amend Annex VII and set derogations by delegated acts, and set disclosure format and verification details by implementing acts (Art. 24(3), Art. 25(3)-(5)). - By 19 July 2027 and every 36 months thereafter, the Commission must publish consolidated information on the destruction of unsold consumer products (Art. 26). ### Green Public Procurement (GPP) - Contracting authorities and contracting entities must award public contracts that comply with minimum requirements set under ESPR for products covered by delegated acts (Art. 65(1)). - The Commission can set those minimum requirements by implementing acts (technical specifications, award criteria, contract performance conditions or targets) (Art. 65(3)). - GPP requirements can reference highest classes of performance, carbon footprint, recycled content, or other sustainability parameters. - Where appropriate, award criteria can have a minimum weighting of between 15% and 30%, and targets can require at least 50% procurement of the most environmentally sustainable products (Art. 65(3)). ### Market Surveillance and Enforcement - Regulation (EU) 2019/1020 on market surveillance applies, and Member States plan checks and priorities as part of their national market surveillance strategy (Art. 66(1)). - For high-risk categories, checks can include physical and laboratory checks; authorities can recover testing costs from the responsible economic operator in case of non-compliance (Art. 66(3)). - Market surveillance authorities record penalty information in the EU information system (Art. 67(1)). - The Commission publishes a report every four years; the first report must be published by 19 July 2028 (Art. 67(3)). - ADCO supports coordination, identifies common priorities, and helps define Union support and guidance (Art. 68). ### Penalties and Sanctions - Member States must lay down and implement penalties for infringements of ESPR; penalties must be effective, proportionate and dissuasive, and Member States notify the Commission of their rules and measures (Art. 74(1)). - Penalty setting must consider factors such as nature/gravity/duration, intent, financial situation, economic benefit, and environmental damage (Art. 74(2)). - Member States must at least be able to impose fines and time-limited exclusion from public procurement procedures (Art. 74(3)). ### SME Support and Proportionality - The Commission must ensure initiatives that help SMEs integrate environmental sustainability in their value chain (Art. 22(1)). - When adopting delegated acts under Art. 4, the Commission should, where appropriate, accompany them with digital tools and guidelines addressing SME specificities (Art. 22(2)). - Member States must take measures to help SMEs comply with ecodesign requirements, including one-stop shops or similar mechanisms (Art. 22(3)). - Micro and small enterprises are exempt from the unsold consumer products disclosure obligation and the destruction prohibition; the disclosure and prohibition apply to medium-sized enterprises from 19 July 2030 (Art. 24(1), Art. 25(1)). ### Prohibition of Circumvention - Economic operators must not engage in behaviour that undermines compliance with ESPR (Art. 40(1)). - Products covered by a delegated act must not be designed to alter behaviour during testing to reach a more favourable result for regulated parameters (Art. 40(2)). - Economic operators must not prescribe test-specific instructions that alter product behaviour to reach a more favourable test result (Art. 40(3)). - Products covered by a delegated act must not be designed to worsen performance shortly after being put into service (Art. 40(4)). - Software or firmware updates must not worsen performance beyond acceptable margins specified in the delegated act in a way that makes the product non-compliant (with narrow, consent-based exception described in the Regulation) (Art. 40(5)). ## Possible Outcomes ### [RESULT] ESPR Ecodesign Requirements Apply (Full Compliance) Product-specific delegated act adopted - Comply with all performance requirements (durability, recyclability, energy efficiency, recycled content, etc.) set in delegated act. - Fulfill all information requirements (DPP, labels, classes of performance, substance tracking) as specified. - Carry out conformity assessment; affix CE marking where required. - Ensure economic operator obligations are met based on your role (manufacturer/importer/distributor/dealer). - Keep technical documentation and declaration of conformity for 10 years. ### [RESULT] General ESPR Obligations Apply No product-specific delegated act yet - No product-specific ecodesign requirements yet, but general obligations apply. - If you discard unsold consumer products, you may have website disclosure obligations (Art. 24) and, for products listed in Annex VII, a destruction prohibition from 19 July 2026 (Art. 25). - Monitor Commission working plan for upcoming delegated acts covering your product group. ### [RESULT] Out of Scope ESPR does not apply - This decision map is not applicable if you are not placing a physical product on the EU market or putting it into service. - ESPR also excludes certain product categories (for example, food and feed, medicinal products, living organisms, products of human origin, and certain vehicles for aspects already addressed by sector-specific Union law). - Check if other EU regulations apply to your product (e.g., sector-specific ecodesign rules, product safety regulations). ## ESPR Timeline | Date | Event | Reference | | --- | --- | --- | | 2024-06-28 | ESPR published in Official Journal (OJ L) | Reg. (EU) 2024/1781 | | 2024-07-18 | ESPR enters into force (20 days after publication) | Art. 80 | | 2025-04-16 | Commission adopted the first ESPR and Energy Labelling Working Plan (2025-30) | Commission implementation timeline | | 2026-02-09 | Commission adopted delegated and implementing acts on destruction of unsold consumer products | Commission implementation timeline | | 2026-07-19 | Commission must set up the digital product passport registry by this date | Art. 13(1) | | 2026-07-19 | Destruction prohibition for unsold consumer products listed in Annex VII applies from this date (subject to exemptions) | Art. 25(1) | | 2027-07-19 | Commission must publish consolidated information on the destruction of unsold consumer products by this date | Art. 26 | | 2028-07-19 | First Commission market surveillance report must be published by this date | Art. 67(3) | | 2028-07-19 | Commission must evaluate potential benefits of social sustainability requirements by this date | Art. 75(4) | | 2030-07-19 | Commission must evaluate ESPR and publish its findings by this date | Art. 75(2) | ## Compliance Timeline | Date | Event | Category | Reference | | --- | --- | --- | --- | | 2019-12-11 | European Green Deal adopted | Policy & Strategy | | | 2020-03-11 | New Circular Economy Action Plan adopted | Policy & Strategy | | | 2020-09-14 | Sustainable Products Initiative roadmap and consultation opens | Policy & Strategy | | | 2022-03-30 | Commission adopts ESPR proposal | Legislation | | | 2022-06-22 | Sustainable Products Initiative roadmap and consultation closes | Policy & Strategy | | | 2022-11-22 | EESC opinion published (OJ C 443) | Legislation | | | 2023-01-31 | Public consultation on new product priorities opens | Policy & Strategy | | | 2023-05-12 | Public consultation on new product priorities closes | Policy & Strategy | | | 2023-12-05 | Provisional agreement welcomed | Legislation | | | 2024-03-01 | CIRPASS DPP use cases report (D2.2) published (version 2.0) | Digital Product Passport | | | 2024-03-28 | CIRPASS DPP recommendations deliverable (v1.2) delivered | Digital Product Passport | | | 2024-04-23 | European Parliament position (23 April 2024) | Legislation | | | 2024-05-01 | CIRPASS DPP system roadmap published (D3.4) | Digital Product Passport | | | 2024-06-13 | ESPR Regulation (EU) 2024/1781 dated | Legislation | | | 2024-06-24 | Public call for participation: CWA 18186 DPP workshop | Standards & Guidance | | | 2024-06-28 | ESPR published in the Official Journal | Legislation | | | 2024-07-18 | ESPR enters into force | Legislation | | | 2024-07-19 | Commission news published on ESPR adoption | Legislation | | | 2024-10-01 | Ecodesign Forum established (Oct/Nov 2024) | Implementation | | | 2024-10-17 | Fit for Future Platform Opinion adopted (2024/4) | Digital Product Passport | | | 2025-02-19 | First Ecodesign Forum meeting (19-20 Feb 2025) | Implementation | | | 2025-04-09 | Commission launches consultation on the Digital Product Passport | Digital Product Passport | | | 2025-04-16 | First ESPR & Energy Labelling Working Plan adopted and published | Implementation | | | 2025-05-05 | CWA 18186:2025 approved | Standards & Guidance | | | 2025-05-13 | Final text of CWA 18186 submitted to CEN for publication | Standards & Guidance | | | 2025-07-25 | Impact assessment on the Digital Product Passport published | Digital Product Passport | | | 2025-08-27 | Deadline to respond to DPP impact assessment surveys | Digital Product Passport | | | 2026-02-09 | Delegated and implementing acts on unsold consumer products adopted | Implementation | | | 2026-07-19 | Prohibition starts: destruction of certain unsold consumer products | Implementation | | | 2030-07-19 | Additional obligations apply to medium-sized enterprises | Implementation | | **Event details:** - **2019-12-11 - European Green Deal adopted**: European Green Deal adopted (Commission timeline item). - **2020-03-11 - New Circular Economy Action Plan adopted**: Adoption of the New Circular Economy Action Plan (CEAP) (Commission timeline item). - **2020-09-14 - Sustainable Products Initiative roadmap and consultation opens**: Public consultation and roadmap for the Sustainable Products Initiative opens (Commission timeline item: 14 September 2020 to 22 June 2022). - **2022-03-30 - Commission adopts ESPR proposal**: Adoption of the ESPR proposal as part of the Sustainable Products Initiative (Commission timeline item). - **2022-06-22 - Sustainable Products Initiative roadmap and consultation closes**: Public consultation and roadmap for the Sustainable Products Initiative closes (Commission timeline item: 14 September 2020 to 22 June 2022). - **2022-11-22 - EESC opinion published (OJ C 443)**: Official Journal reference for the opinion of the European Economic and Social Committee: OJ C 443, 22.11.2022, p. 123. - **2023-01-31 - Public consultation on new product priorities opens**: Open Public Consultation on new product priorities for ESPR opens (Commission timeline item: 31 January 2023 to 12 May 2023). - **2023-05-12 - Public consultation on new product priorities closes**: Open Public Consultation on new product priorities for ESPR closes (Commission timeline item: 31 January 2023 to 12 May 2023). - **2023-12-05 - Provisional agreement welcomed**: Commission welcomes provisional agreement for more sustainable, repairable and circular products (Commission timeline item). - **2024-03-01 - CIRPASS DPP use cases report (D2.2) published (version 2.0)**: CIRPASS deliverable D2.2 cover shows March 2024 as the document date (Version 2.0). - **2024-03-28 - CIRPASS DPP recommendations deliverable (v1.2) delivered**: CIRPASS recommendations deliverable (Version 1.2, May 2024) lists an actual delivery date of 28 March 2024. - **2024-04-23 - European Parliament position (23 April 2024)**: Position of the European Parliament of 23 April 2024 (referenced in Regulation (EU) 2024/1781). - **2024-05-01 - CIRPASS DPP system roadmap published (D3.4)**: CIRPASS project results page links a DPP system roadmap published in May 2024. - **2024-06-13 - ESPR Regulation (EU) 2024/1781 dated**: Regulation (EU) 2024/1781 is dated 13 June 2024. - **2024-06-24 - Public call for participation: CWA 18186 DPP workshop**: Public call for participation made for the CEN Workshop "Guidelines to create a Digital Product Passport" (CWA 18186:2025). - **2024-06-28 - ESPR published in the Official Journal**: Published in the Official Journal (OJ L) on 28.6.2024. - **2024-07-18 - ESPR enters into force**: Regulation (EU) 2024/1781 enters into force on the twentieth day following its publication in the Official Journal (20 days after 28.6.2024). - **2024-07-19 - Commission news published on ESPR adoption**: Commission news page published 19 July 2024: "New law to make products on the EU market more sustainable". - **2024-10-01 - Ecodesign Forum established (Oct/Nov 2024)**: Establishment of the Ecodesign Forum and publication of call for membership applications (Commission timeline item: October/November 2024; date shown here as 2024-10-01 as a month-level placeholder). - **2024-10-17 - Fit for Future Platform Opinion adopted (2024/4)**: Fit for Future Platform Opinion referenced in Commission material on QR codes on products / Digital Product Passports; adoption date listed as 17 October 2024. - **2025-02-19 - First Ecodesign Forum meeting (19-20 Feb 2025)**: First Ecodesign Forum meeting held on 19-20 February 2025 (Commission timeline item). - **2025-04-09 - Commission launches consultation on the Digital Product Passport**: Commission news page URL indicates publication date 9 April 2025 for a consultation on the Digital Product Passport. - **2025-04-16 - First ESPR & Energy Labelling Working Plan adopted and published**: Adoption and publication of the first ESPR and Energy Labelling Working Plan (Commission timeline item). - **2025-05-05 - CWA 18186:2025 approved**: CWA 18186:2025 approved by the CEN Workshop "Guidelines to create a Digital Product Passport". - **2025-05-13 - Final text of CWA 18186 submitted to CEN for publication**: CWA 18186 timeline metadata notes the final text was provided to CEN for publication on 13 May 2025. - **2025-07-25 - Impact assessment on the Digital Product Passport published**: European Commission publishes the call to take part in its impact assessment on the Digital Product Passport (publication date in the article URL). - **2025-08-27 - Deadline to respond to DPP impact assessment surveys**: Please respond by 27 August to one of the surveys (as stated on the impact assessment page). - **2026-02-09 - Delegated and implementing acts on unsold consumer products adopted**: Adoption of implementing and delegated acts on destruction of unsold consumer products (Commission ESPR timeline item dated 9 February 2026). - **2026-07-19 - Prohibition starts: destruction of certain unsold consumer products**: From 19 July 2026, the destruction of unsold consumer products listed in Annex VII is prohibited. - **2030-07-19 - Additional obligations apply to medium-sized enterprises**: Certain obligations apply to medium-sized enterprises from 19 July 2030 (as specified in Regulation (EU) 2024/1781 document status). --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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