Your Compliance Timeline

Now — 2026

CBAM financial obligations for iron & steel importers are live from January 2026. Battery QR-code labelling has been mandatory since August 2024. The ESPR delegated act for iron & steel is expected to be adopted this year; textiles follows later, expected Q3–Q4 2027 — start collecting supplier data now. The Battery DPP deadline of 18 February 2027 is the next hard enforcement date.

18 February 2027 — Battery DPP

The EU's first confirmed DPP deadline. All industrial batteries (>2 kWh), EV batteries, and light means of transport (LMT) batteries placed on the EU market must carry a digital product passport accessible via QR code, under Regulation (EU) 2023/1542. Annex XIII data — carbon footprint, recycled content, state of health, responsible sourcing — must be published and verifiable.

2027 — 2029 — Iron/Steel, Electronics & Textiles

Iron & steel ESPR requirements and smartphone repairability DPPs are expected first, following the 2026 delegated act adoption. Textiles and apparel DPP enforcement follows later, expected ~18 months after the textiles delegated act (adopted Q3–Q4 2027). Products without a compliant DPP cannot be placed on the EU market.

2028 — 2030 — Remaining Categories

Furniture (mandatory 2028), laptops and electronics recycled content (2029 est.), mattresses (2029), and construction products complete the ESPR Working Plan 2025–2030. Retroactive compliance is not possible.

Iron & steel importers: CBAM financial obligations are live from January 2026. Your DPP and your CBAM declaration share the same data record on PassportLab.See how →
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Common Questions

Regulatory & Technical Insights

Critical information for Importers and Private Label brands regarding the ESPR DPP mandate.

212 Days Until Battery DPP Enforcement

The EU DPP Registry Is Live.
Is Your Product Data Ready?

From 18 February 2027, batteries placed on the EU market require a Digital Product Passport, ready to register the moment the battery category opens in the EU registry. Iron & steel CBAM obligations are live today. For all other categories, the clock is running — the obligation falls on you as the importer, not your manufacturer.

We built the technical compliance guide for importers, private label brands, and industrial operators who need to understand exactly what the EU registry requires — and how verifiable infrastructure makes the difference between a blocked shipment and a market-ready product.

Inside this report
  • The 3-layer verifiable infrastructure architecture behind a compliant DPP
  • How CBAM and ESPR delegated acts converge into one compliance obligation
  • Actor-specific data access: what customs sees, what competitors never will
  • A structured implementation roadmap: from data gap report to a registry-ready DPP

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The Verifiable Infrastructure Protocol — Technical Compliance Guide for EU Importers · PassportLab.io · July 2026