The question a store asks is not what a Digital Product Passport is. It is when. And the answer circulates in a misleading shape: a single number, 2027, applied to everyone.
Four things are in fact moving in parallel, at four speeds. The framework regulation, which is in force. The EU registry, which is open. The technical standards, which are published. And the sector delegated acts, of which exactly one is dated and the textile one does not yet exist.
Running them together is what produces either needless panic or a missed deadline.
Layer 1: the framework regulation, in force
Regulation (EU) 2024/1781 on ecodesign for sustainable products entered into force in July 2024. It creates the Digital Product Passport, sets its principles in article 10, and provides that no product falls under it until a delegated act names that product.
That is the part people misread. The regulation is applicable law, but it obliges nobody to publish anything today. It installs the machinery.
Its first working plan, adopted on 16 April 2025, names the priority families: textiles and apparel, furniture, mattresses, tyres, iron and steel, aluminium.
Layer 2: the EU registry, open since July 2026
The central registry has been operational since 20 July 2026, test environment included. It was created by Implementing Regulation (EU) 2026/1778 of 16 July 2026, in force since 6 August.
What it holds is deliberately thin: the product's unique identifier, the commodity code, a reference to wherever the passport is hosted, and a timestamp. The passport data itself stays with the operator placing the product on the market.
Registration assumes a verified economic operator identity in the eIDAS sense, valid for up to three years. There is nothing to do at this stage if your sector has no delegated act yet.
Layer 3: the technical standards, published in May 2026
This is the least discussed and most concrete step forward. The joint technical committee of CEN and CENELEC published six European standards on 27 May 2026, describing how a passport works:
| Standard | Subject |
|---|---|
| EN 18216 | Data exchange protocols |
| EN 18219 | Unique identifiers |
| EN 18220 | Data carriers |
| EN 18221 | Storage and persistence |
| EN 18222 | Interfaces, lifecycle, searchability |
| EN 18223 | Interoperability between systems |
The six were cited in the Official Journal by Implementing Decision (EU) 2026/1736 of 14 July 2026, which gives them presumption of conformity with articles 10 and 11 of the regulation. Two further texts, on access rights and on authentication, were in formal vote until 16 July 2026; their publication is not confirmed as of this article.
The practical consequence: how a passport is identified, carried by a code and kept over time is not going to move much now. What stays open is the list of data per sector.
Layer 4: the delegated acts, only one is dated
This is where the calendars separate.
Batteries come first, under a different law. The battery passport becomes mandatory on 18 February 2027 for electric vehicle, light means of transport and industrial batteries above 2 kWh. It sits under the 2023/1542 battery regulation, not under ESPR. That single date is the source of the "2027" everyone repeats. The implementing act on access rights that was meant to accompany it in August 2026 was not adopted on time, and now appears in the fourth quarter of 2026.
Everything else follows the Commission's indicative calendar, which covers adoption of the acts, not their application:
| Product family | Target adoption |
|---|---|
| Iron and steel | Q4 2026 |
| Textiles and apparel, aluminium, tyres | Q3 and Q4 2027 |
| Furniture | 2028 |
| Mattresses | 2029 |
Textiles have no published draft. What exists is a preparatory study from the Joint Research Centre, released on 15 May 2026 and opened for consultation. It proposes a scope of products containing at least 80 percent textile fibres by weight, and three data levels: model, batch and item. It excludes fibres, yarns and fabrics sold as such, e-textiles, protective equipment, medical devices and toys. Where footwear lands is still unsettled.
Between the adoption of a delegated act and its application, the regulation allows a delay, generally around eighteen months. For textiles, that points to application around 2029.
Four claims you will meet that are wrong
"It is mandatory for everyone in 2027." No. In February 2027 it is mandatory for three categories of batteries. No other product is affected on that date.
"Textiles start with the spring-summer 2028 collection." That date comes from software vendors, not from a text. The official calendar targets adoption in late 2027, so application considerably later.
"Companies below a certain threshold will be exempt." There is no size-based exemption for the passport. The only carve-out of that kind in the regulation concerns the ban on destroying unsold goods, and it is a different obligation.
"You have to buy GS1 codes." The regulation names no identifier vendor. Its annex III points at the ISO/IEC 15459 family, which several approaches satisfy. A sector delegated act may narrow it further, and the textile one is not written.
If your store is outside the EU
The obligation follows the product, not the seller. ESPR applies to products placed on the EU market, whoever places them there and wherever they were made. A store in the United Kingdom, Switzerland or the United States shipping to customers in the European Union is inside the scope for those products.
That has two consequences worth stating plainly. Being registered outside the Union is not an exemption, and no delegated act has been drafted that way. And the party carrying the obligation is the one placing the product on the market, which depends on how the goods reach the buyer: a direct shipment to a consumer, a European distributor and a marketplace are not the same arrangement. That one is worth checking against your own setup rather than assuming.
In practice today the answer is the same as for a store inside the Union. Nothing is due, and the preparation is identical. It is worth knowing now because a store that files the passport under somebody else's regulation is the one that finds out late.
National rules are not the passport
If you sell into France, three separate texts ask for product data, and they share neither scope nor calendar. Reading them as one is how stores end up preparing for a deadline that does not apply to them.
The AGEC product sheet. Since 1 January 2023, article 13 of the French AGEC law requires an online sheet carrying geographic traceability, meaning the countries of weaving or knitting, dyeing or printing, and making up, plus a microfibre warning above 50 percent synthetic content, the share of recycled material, and the presence of hazardous substances. It applies above turnover and volume thresholds that have been lowered every year, and stands at 10 million euros and 10,000 units since 2025.
The environmental cost display, previously called the eco-score. The French scheme came into force on 1 October 2025 and is voluntary. It runs on the public Ecobalyse calculator and covers eleven clothing categories, footwear excluded. Since October 2026 a third party may publish a score for a brand that has not, using unfavourable default values.
The European passport, which is mandatory for no textile product yet.
The three overlap in what they ask for: composition, origin, production stages. That is an argument for organising this data once and properly, rather than three times in three formats.
What this changes for a WooCommerce store
Nothing is due today. That is the good news, and it is also the trap: the deadline looks distant, while the useful work is slow.
That work is not regulatory, it is housekeeping. Lifting composition out of descriptions into attributes. Deciding that a passport matches a reference rather than an individual item. Publishing at an address that will survive a rebuild, because a code printed on a label has to answer for the whole life of the garment.
None of those three decisions depends on a delegated act. They hold whatever the final text says, and they are exactly what takes time when you start the week before a deadline. The rest, meaning the precise list of fields, then drops into a structure that is already clean.
The concrete starting point is described in the passport seen from WooCommerce.
Sources
- Regulation (EU) 2024/1781 (ESPR)
- The Commission's Digital Product Passport page, which carries the indicative calendar
- Implementing Regulation (EU) 2026/1778 creating the registry
- CEN and CENELEC on the published DPP standards
- ESPR implementation work, including the textile preparatory study
This page is dated. Delegated acts move, and the date at the top of the article says when it was last checked.