ESPR and the Digital Product Passport: Dates and Who Buys

The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781, a framework law that lets the EU set sustainability rules for physical products one group at a time (Regulation (EU) 2024/1781 on EUR-Lex).

The Digital Product Passport (DPP) is one of its tools. It is a digital record of a product, its components and its materials. You open it by scanning a QR code or a similar carrier on the item.

Passports arrive in stages. Certain batteries come first, and apparel textiles, iron and steel, and construction products are expected to follow (European Commission DPP page). For clothing and footwear, two obligations already carry fixed dates: a ban on destroying unsold stock and a standard format for reporting what gets discarded.

I wrote this for B2B suppliers whose customers sit inside those product groups. That includes passport software and product data vendors, testing and life-cycle assessment firms, textile recyclers, and component suppliers to apparel, steel and furniture brands.

Read the first half as a summary of official pages, not legal advice. The rest covers selling into this market: who decides at the buyer, when to reach them and what to write.

What does the ESPR set, and what does the passport do?

ESPR writes the rules for making product rules. The binding requirements come later, in delegated acts. Most acts cover a single product group. Some are horizontal and reach across many products, for example electronic appliances or textiles, with durability and repairability named as priorities.

Its scope covers most physical goods placed on the EU market. Components such as tyres count too, along with intermediate products and the digital content a physical product depends on. Food, feed, medicinal products, and living plants and animals stay outside.

An act can route product information through a website, a label or a passport. The passport's job is to move that information along the value chain and make end-to-end traceability possible.

Who has to produce it depends on how the goods reach the market. A 2026 One Click LCA explainer names the manufacturer, an authorized representative, the importer, a distributor, a dealer or a fulfillment service provider as possible holders of that duty (One Click LCA).

Reading rights differ as well. A 3R Sustainability guide notes that authorities, consumers and recyclers see different parts of the record, which protects commercially sensitive data (3R Sustainability). Both are vendor explainers. The binding detail for each product group sits in its own act.

Content varies by group. The Commission's examples include safety, origin, materials, repairability, environmental performance, and reuse and recycling options. For a supplier, that means no single passport template fits every client. It is also why one generic pitch to "manufacturers" goes nowhere. A steel producer and a furniture brand will face different fields on different dates.

What has the EU already adopted, and when?

Sources for the table: European Sources Online on the signature and publication, the Green Forum ESPR overview, DG Environment on the ban entering application and DG Environment on the February 2026 adoption.

The working plan puts steel and aluminium, textiles with a focus on apparel, furniture, tyres, mattresses and several energy-related products near the front. It also plans horizontal measures: a repairability score and recyclability requirements for electrical and electronic equipment (Commission news on the 2025-2030 working plan). Read it as a queue. A group's obligations begin only when its own act applies.

The destruction ban and the disclosure rule are two obligations with two dates. One stops destruction. The other sets how companies report the unsold consumer products they do discard. Keep them on separate rows in any plan, and in any email you send about them.

Which product groups get a passport first?

Batteries lead: industrial batteries, electric vehicle batteries and batteries for light means of transport (Commission DPP launch note, 17 July 2026). Their passport comes from the Batteries Regulation, a standalone EU law, so its timing follows that law instead of an ESPR delegated act.

TÜV Rheinland's summary of Regulation (EU) 2023/1542 puts the mandatory date at 18 February 2027. That covers rechargeable industrial batteries above 2 kWh and electric vehicle batteries.

Every product group reaches its passport by one of two routes:

Source: the Commission DPP page. The Commission calls these dates indicative and subject to publication. After an ESPR delegated act is adopted, businesses get a transition period of at least 18 months.

Construction products move through the Construction Products Regulation, with a delegated act for construction materials that the Commission DPP page schedules for Q2 2027. If your buyers make construction products, they are a separate list: makers of construction products answer to a different regulation and different titles. Packaging is another standalone route, with its own buyers among PPWR packaging suppliers.

Preparatory work on textiles and steel has started (Green Forum ESPR overview). The binding product-level fields still arrive only with each adopted act.

How do the DPP registry and the data carrier work?

The registry is the EU's index of passports, set up at EU level. Its legal act is Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026, which lays down how the registry under the Ecodesign Regulation (EU) 2024/1781 works. The registry stores each product's unique identifier together with the mandatory registration data the applicable act asks for.

The passport itself sits in a decentralized system run by businesses, with a back-up copy held by an independent DPP service provider. The Commission's DPP page dates the registry going live on 20 July 2026, with a testing environment.

The Commission's flow, simplified:

1. The business gathers the information the applicable EU law requires.
2. It creates the passport and registers it in the registry.
3. The registry generates a unique web address (URI) for that passport.
4. A QR code or another data carrier on the product links the item to its passport.
5. Each person who scans it sees what their role allows: a buyer sees product facts, a recycler sees recycling information, an authority checks compliance.

Once a group's act applies, an EU-made product needs its registry entry before it is placed on the EU market. For imports, customs can check the registration identifier against the registry. For a UK or US exporter, the passport becomes a shipping question too.

The technical standards are close to final: the Commission's timeline lists an implementing decision on six DPP standards in July 2026 and on the remaining two in November 2026.

What does the unsold clothes and shoes ban mean in practice?

The ban covers unsold clothes, clothing accessories and footwear (DG Environment, 17 July 2026).

The size of the problem is an estimate. A March 2024 European Environment Agency briefing, built on available studies, estimated that 4% to 9% of textile products put on the European market are destroyed before use, or 264,000 to 594,000 tonnes, based on 2020 data (EEA briefing).

Unsold stock follows a reuse-first order:

1. Sell it, including at a discount or through alternative markets.
2. If that fails, donate it.
3. Or prepare it for reuse.

Destruction is allowed only when the items are unsafe or damaged, when they are counterfeit or infringe intellectual property rights, or when charities or donation schemes have rejected them.

Using an exemption creates paperwork. Companies must provide proof and publish yearly reports on discarded items. National authorities check compliance and can impose fines, and records stay on file for 5 years.

For a supplier of stock tracking, resale or textile recycling services, that paperwork is the opening. Every large apparel seller now needs a defensible answer to where its unsold stock went, written down and kept for years.

A study of returned apparel in the EU found that 22% to 44% of returned products never reach another consumer. The European Environment Agency notes that a large share of unsold products is exported out of Europe.

Who buys passport and ESPR work, and who decides?

I do not advise on compliance. This part is how I would build a campaign into this market.

The buyer is whoever carries the passport duty for a product group, plus everyone that company pulls in. Neighbouring EU laws build their own buyer lists, such as the EU Cyber Resilience Act and the Data Act. In practice that means brands and manufacturers in the queued groups (apparel, footwear, steel, aluminium, furniture, tyres, batteries) and the importers and distributors who put those goods on the EU market. Large apparel companies already live with the destruction ban, which makes them the most concrete list today.

The decision rarely sits with one title. Passport data touches materials, origin, safety and repair information, and those usually live with different teams. The people I would put on a first list:

1. Head of product compliance or regulatory affairs
2. Sustainability or ESG director
3. Head of product data, product information management (PIM) or master data
4. Supply chain or sourcing director
5. CIO or IT director, when the question is which system runs the passports
6. In apparel, the head of stock planning or retail operations, for the unsold goods side

Treat that list as a draft. Before I write a first message for a client, I look at the deals they have already closed and who actually signed. If your last three passport projects were bought by a supply chain director, that title goes first, whatever the org chart says.

These are finite lists. Every company on them matters, so a bounced email or a careless first line costs more than it would in a market of a million prospects. Every address gets verified before anything goes out, and we keep bounces below 0.5%. Copy cannot rescue a wrong list or a weak sender.

How we build and verify lists like these is in our lists and targeting FAQ.

When should you reach out, and where are the triggers published?

Every step of this rollout is announced in advance. The working plan, the Commission's DPP page, the Green Forum's ESPR pages and DG Environment news all date what comes next. For a seller, each step is a reason to write: a group entering the working plan, an act being adopted, an application date getting close.

The timing math matters more than the trigger. A B2B sale commonly takes half a year to a year. Say you start outreach the day a group's act is adopted and your sales cycle runs 12 months. Against a transition period of at least 18 months, most of that window is gone before your contract is signed.

So I would start when the group first appears in the working plan. That is when a compliance lead still has room for an exploratory call. Close to an application date, their calendar belongs to the deadline.

A simple status log keeps this honest. Give every act that touches your buyers three states (listed in the working plan, adopted, applying), review it each quarter, and let it decide which segment you contact next.

What should the first message say?

Write about one product group and one dated step. A specialist reads your first line and decides whether you know the rules. These are the lines I would cut from a first draft:

Keep the pitch out of the first message. Ask for a short call instead, and explain the service there. A buyer will research you before agreeing to it.

A compliance lead will check your website, your team's profiles and your case studies before agreeing to a call. Put one relevant result in the email, ideally from a client in the same product group, and offer a short call about that group's next date.

Expect modest numbers. Across our campaigns, a reply rate near 1% is typical. At thousands of emails a day it drops toward 0.5%. Somewhere between a tenth and a half of replies turn into booked meetings.

Tightly researched, highly personalized campaigns can reach 15% to 17% replies, and about 75% of those repliers are interested (our own campaign ranges). With a short list of compliance leads, the narrow version is the one worth running. If it does not work at small numbers, more volume will not save it.

Plan follow-ups from the start. One or two messages will not get it done. I plan 5 to 6 touches across email and LinkedIn. Leave real time between them. In our campaigns, the third follow-up is usually what works.

Run LinkedIn outreach next to cold email. Check first whether your buyers are active on LinkedIn, then make sure your profile and case studies hold up when they click through. An ordinary email from a profile full of proof will outpull a brilliant one sent from an empty profile.

When the right buyers are active on LinkedIn, a narrow list can carry a campaign. For one German software development company, 61.9% of our connection requests were accepted and 76.9% of the people who connected replied. Over 6 months, that campaign booked 488 sales calls.

What should suppliers, importers and distributors do now?

If your own products fall into a queued group, the work starts inside the company:

1. Map product families before SKUs. List the families you sell in the EU and match each one to its route in the table above.
2. Name one data owner per information area. Materials, origin, safety and repair data often sit with different teams or suppliers.
3. Decide which system runs your passports, and which independent service provider holds the back-up copy.
4. Add registry registration to the launch process for EU-made products, and check that import paperwork can carry the identifier.
5. If you sell apparel or footwear, log where unsold stock goes, keep exemption proof, and prepare for the standard disclosure format.

What is still unclear?

1. Exact data fields per group. The official pages give examples of what a passport may hold; the binding list for each group comes in its act.
2. Product-by-product timing. Delegated act dates stay indicative until publication.
3. Access rights. The Commission's DPP page still lists an implementing act on battery access rights, planned for Q4 2026.
4. Enforcement beyond the ban. Published enforcement detail so far centers on the destruction ban: national checks and fines.

If you track one row this quarter, track whether your buyers' product group has an adopted act yet.

Supplying a product group that gets a passport and unsure who to contact first? Book a call and I will help you map the buyers.