Get ready for Digital Product Passports before they're mandatory
Two dates matter most for brands like yours. From 18 February 2027, batteries carry new obligations under their own dedicated regulation, the exact requirement depends on the battery, but it touches almost any catalogue with electronics or powered devices in it. Around the same time, textiles picks up its own detailed rules under the EU’s wider Digital Product Passport framework. Furniture, mattresses, tyres and toys are moving too, on their own slower timetables, worth knowing about even if they’re a smaller part of your range. Expandly gives you one place to hold your product passport data and generate the labelling you need, category by category, as each requirement lands.
- Batteries and textiles have the nearest confirmed dates, both around 2027
- QR codes and data carriers generated straight from your platform data
- Furniture, mattresses, tyres and toys tracked too, on their own slower clocks
- Runs alongside your existing VAT, labelling, EPR and RP setup
Digital Product Passports don’t slot into the onboarding sequence the way VAT, labelling, EPR and Responsible Person do, because DPP requirements arrive by product category on their own regulatory timetable, not on your launch date. We treat it as a track that runs alongside your other Compliance & Tax steps: the product data your passport needs overlaps heavily with what’s already captured for labelling and EPR, so building the record early is largely a data exercise, not a new workstream.
Batteries and textiles are the two to plan around first
Batteries are the more urgent of the two, and the most widely relevant, because a battery hiding inside a product is easy to overlook until the deadline is close. From 18 February 2027, the Batteries Regulation splits into two obligations depending on what you sell. If your catalogue includes larger battery-powered equipment, most likely e-bikes, e-scooters or similar light-means-of-transport products, you’re moving onto the full digital battery passport: a QR code linking to a structured data record covering identification, performance and carbon footprint. If your batteries are the smaller, portable kind, the type inside most consumer electronics, beauty devices and wearables, the same date brings a tightened user-removability requirement instead, not the full passport. Either way, February 2027 is a real date to build towards, not a distant framework milestone.
Textiles is the other track moving on a comparable timeline. It sits inside the EU’s wider Ecodesign for Sustainable Products Regulation, and the Commission’s working plan gives textiles an indicative 2027 date for its detailed delegated act, the fastest-moving of the four product groups named in that framework. Furniture, mattresses and tyres are named in the same framework but on slower, later timetables, and toys pick up a border-screened passport requirement under their own regulation reaching full application in 2030, all worth knowing about, but a smaller part of most of our clients’ catalogues than batteries or textiles.
What doesn’t change track to track is the underlying data. A passport needs accurate, structured product information, material and component detail, and a way to put that information in a customer or regulator’s hands at the point of sale or import, usually a QR code or similar data carrier on the product or its packaging. That’s exactly the kind of record Expandly already builds for your labelling and EPR obligations, so extending it into a full product passport is additive, not a rebuild.
Batteries Regulation: full passport for larger batteries, tightened removability for portable ones
Indicative delegated-act date for textiles, the fastest-moving of ESPR’s priority categories
Furniture, mattresses, tyres and toys follow on slower timetables
What we handle for you
One product passport record, built from data you already hold
You add your product passport key facts, material composition, origin, compliance documentation and the rest, directly into the Expandly platform, drawing on the same product data already used for your labelling and EPR records rather than starting a separate spreadsheet.
QR codes and data carriers, generated and ready to print
Once your passport record is complete, we generate the QR code or equivalent data carrier for each product, so you have the exact artwork to add to your product labelling or packaging when a category’s requirement takes effect.
Category-by-category regulatory monitoring
DPP requirements are landing on different timetables for different product types. We track which categories are confirmed, which are still framework-only, and flag the ones relevant to your catalogue as dates firm up.
Built on the same record as your other compliance obligations
Your product passport data sits alongside your VAT, labelling, EPR and Responsible Person records in one platform, so updating a product once keeps every obligation it touches current, not just the passport.
Batteries and textiles lead, everything else follows
Digital Product Passports aren’t one regulation with one date. Here’s what’s confirmed, what’s framework-only, and what’s still being finalised, weighted towards the tracks most likely to touch our clients’ catalogues.
Batteries
Splits by battery type
Batteries Regulation, Reg (EU) 2023/1542
In force
In force since August 2023. From 18 February 2027: EV, industrial (>2kWh) and light-means-of-transport batteries move to a full digital passport (QR code plus a structured data record). Portable batteries, the type in most consumer electronics, beauty devices and wearables, get a tightened user-removability requirement on the same date rather than the full passport. Expanded labelling lands earlier, from August 2026.
Textiles
Ecodesign for Sustainable Products Regulation, Reg (EU) 2024/1781
In force
Framework live. The Commission’s 2025–2030 working plan gives textiles an indicative 2027 date for its detailed delegated act, the fastest-moving of the four product groups named in ESPR’s first priority wave. This is a date for adopting the detailed rules, not yet a confirmed market compliance deadline.
Furniture, mattresses, tyres & toys
Smaller part of our client base
ESPR (furniture, mattresses, tyres); Toy Safety Regulation, Reg (EU) 2025/2509 (toys)
Watch
Furniture (2028) and mattresses (2029) follow textiles under ESPR’s indicative timetable, tyres tracks alongside textiles at 2027. Toys pick up a border-screened Digital Product Passport under their own regulation, reaching full application in 2030. Worth monitoring if these feature in your range, but a lower priority than batteries or textiles for most of our clients.
This is a fast-moving area of EU regulation. Figures above are cross-checked against external sources, including legal-update coverage from CMS Law and CSA Group, as of 18 August 2026, and are the most far-reaching, currently-confirmed milestones we track. ESPR’s own indicative dates are for delegated-act adoption, not guaranteed market deadlines, and reputable sources don’t fully agree on how far the Feb 2027 battery QR-code requirement extends beyond the larger battery categories, we’ve taken the more conservative reading pending Compliance sign-off. Confirm which tracks apply to your catalogue, and the current state of each date, with our compliance team before setting an internal deadline.
What this looks like for brands like yours
Batteries and textiles touch most of our catalogues first, but every segment has a track worth tracking.
Sports, Fitness & Active Lifestyle brands
Textile apparel and equipment sit in ESPR’s fastest-moving priority category, and any e-bike, e-scooter or similar powered equipment in your range puts you on the full battery passport track from February 2027, not just the portable-battery removability rule.
Health, Wellness & Nutrition brands
Connected devices, scales and similar portable-battery products pick up the tightened removability rule from February 2027, a lighter obligation than the full passport but still a real one to plan around.
Beauty, Personal Care & Cosmetics brands
Battery-powered devices, cleansing brushes, hair tools and similar, fall under the same February 2027 portable-battery removability rule as other electronics, even though beauty isn’t yet in ESPR’s own priority wave.
Home, Garden & Lifestyle brands
Furniture and mattresses are named in ESPR’s priority wave on a slower 2028–2029 timetable, and any powered garden or smart-home equipment brings the February 2027 battery rules into play too.
Technology & Consumer Electronics brands
The segment most exposed to February 2027: portable-battery removability affects almost everything you sell, and larger battery-powered equipment can put you on the full digital passport track instead.
Fashion, Apparel & Accessories brands
Textiles are named explicitly in ESPR’s first priority wave, with 2027 targeted for the detailed rules, the fastest-moving category in the general framework.
Your product passport data lives with everything else you sell
A Digital Product Passport isn’t a document you file once, it’s a live record that has to stay accurate as your products, materials and suppliers change. Expandly holds your passport data as part of the same product record used for labelling, EPR and Responsible Person, so updating a product once keeps every downstream obligation current, including the QR code or data carrier you’ve already put on pack.
As new categories get confirmed dates, whether that’s the battery obligation that applies to your specific products, textiles’ detailed rules, or the rest of ESPR’s priority wave, your existing product data is the starting point, not a fresh capture exercise. That’s the advantage of building the record early rather than waiting for a deadline to force it.
Expandly isn’t a Europe-only add-on. It’s built to be the one platform behind your entire operation, wherever you already sell.
Digital Product Passports are one part of a much bigger platform. Every Expandly customer also gets:
Tax & VAT
Registration and filing handled across every market you connect, on the same product and account data.
Product Compliance & RP
Labelling and Responsible Person requirements managed from the same product record your passport data sits in.
EPR
Extended Producer Responsibility registration and reporting, category by category, alongside your passport track.
Triggers & Alerts
Automatic flags as new DPP dates are confirmed for categories in your catalogue.
Expandly AI
Stock forecasting and opportunity planning, built into the platform.
API
Connect your existing tech stack without a rebuild.
Listings Management
Build your catalogue once and publish it, correctly formatted, to every channel.
Where Digital Product Passports sit in your expansion
Digital Product Passports sit within the Regulations component of the Compliance stage alongside VAT, labelling, EPR and Responsible Person, but the data carrier itself, the QR code or equivalent on your product or packaging, connects forward into Logistics too, since it needs to be right before goods physically move. It also feeds the Reporting Suite and Triggers & Alerts in the Growth stage as new category dates are confirmed.
Two Dates in 2027,
The instinct with any new EU regulation is to wait until there’s one confirmed date to plan against. Digital Product Passports don’t work that way, but batteries and textiles have both moved from framework to firm date faster than furniture, mattresses, tyres or toys, and between the two of them they touch most of our clients’ catalogues in some form. Brands who treat this as a data exercise now, rather than a scramble later, are the ones who’ll find each new deadline a formality.
- Battery obligation identified per product, full passport for larger batteries, removability for portable ones
- Textiles' 2027 delegated act tracked as the detail is confirmed, ahead of the slower ESPR categories
- QR codes and data carriers generated and ready before a category's requirement takes effect
- Furniture, mattresses, tyres and toys monitored too, sized to how much of your range they actually cover
Get the data foundation right early and each new confirmed date becomes a labelling update, not a compliance project.
Full digital passport for larger batteries, tightened removability for portable ones, both from the same date.
Reg (EU) 2023/1542
Indicative date for textiles’ detailed delegated act, the fastest-moving of ESPR’s first priority wave.
Reg (EU) 2024/1781
Passport data built into the same onboarding as VAT, labelling, EPR and Responsible Person.
brands expanded with Expandly
Choose your level of support
Every tier gets full access to building and maintaining your product passport records and generating your data carriers. What changes is who tracks the rollout for you: you monitoring category dates yourself, a success manager flagging what’s confirmed, or a consultant managing your passport data proactively as each track moves.
Expandly Self-Serve
With Email Support
You track category dates and build your own passport records.
- Full access to every service on the platform
- Knowledgebase to work through each track's requirements yourself
- Email support when you get stuck
Expandly Guided
With Account Manager Support
We tell you when a category date firms up, before it’s urgent.
- Success manager tracks confirmed dates across every track relevant to you
- Pointed to exactly which products need updated data and when
- You maintain the records, guided through the process
Expandly VIP
With VIP Consultant Support
We manage your passport data and data carriers, proactively.
- Consultant manages passport records and QR/data carrier generation directly
- Proactive outreach ahead of every confirmed category date
- Monthly reviews plus an annual consultant site visit
Guided and VIP customers get ahead of each new confirmed date because they’re told about it directly, not because the underlying requirement is any different.
All tiers: 36-month term. Base package includes passport record building and data carrier generation for your core catalogue. Additional product volume from £200–£600/month depending on tier. Not sure which tier fits? Talk it through on your strategy call.
Find out which Digital Product Passport tracks apply to you
Book a free discovery call and we’ll map your DPP exposure by category, and get your product data ready before the dates that matter to you are confirmed.
This page is general guidance, not a substitute for advice on your brand’s specific situation. Digital Product Passport requirements vary by product category, are still being confirmed for most categories, and can change, talk to our compliance team about how they apply to you before you make a labelling or launch decision.