The Digital Product Passport is no longer a future concept. It’s a regulatory reality. For businesses in batteries, textiles, and construction, the next three years will define who leads and who scrambles to catch up.
The Regulatory Landscape: What’s Actually Confirmed
The EU has moved from policy discussions to concrete legislation. Here’s what we know for certain:
Batteries are first in line. The EU Battery Regulation (2023/1542) mandates Digital Product Passports from February 18, 2027 for all EV batteries, industrial batteries over 2kWh, and light transport batteries placed on the EU market. This isn’t pending. It’s law.
Textiles follow under the Ecodesign for Sustainable Products Regulation (ESPR). The European Commission is expected to adopt the delegated act for apparel in late 2026 or early 2027, with DPP requirements becoming mandatory approximately 18 months later. That puts us at mid-2028.
Construction products operate under their own framework. The revised Construction Products Regulation entered into force in January 2025, with most provisions applying from January 2026. GWP (Global Warming Potential) declarations are already required for certain products, and Member States can enforce penalties from January 2027. DPP infrastructure is expected by 2026/2027, with mandatory passports following 18 months after.
The pattern is clear: the timeline isn’t shifting right. It’s accelerating as regulations move from draft to enforcement.
The Strategic Question: Opportunity or Compliance Burden?
Every regulation creates two types of companies: those who see it as a cost to minimize, and those who see it as a competitive advantage to capture.
The compliance-focused mindset leads to last-minute scrambles, expensive consultants, and systems that check boxes but add no business value. The strategic mindset asks different questions: How can DPP data improve our operations? What market positions can we claim by moving early? Which customers will reward transparency?
Early movers in sustainability reporting have already seen the answer. Companies with robust environmental data don’t just avoid penalties. They win contracts, command price premiums, and build customer loyalty that’s difficult for competitors to replicate.
What This Means for SMBs
Here’s the uncomfortable truth: most DPP solutions on the market are built for enterprises with dedicated compliance teams and seven-figure budgets. Small and medium businesses face a genuine problem. The regulatory requirements are the same, but the resources aren’t.
This creates both risk and opportunity. The risk is obvious: non-compliance means losing EU market access entirely. The opportunity is less obvious but more interesting: SMBs that solve the DPP challenge early will have a genuine advantage over larger, slower-moving competitors still running their compliance decisions through committee.
The key is finding solutions that match your reality. Systems that work with your existing processes rather than requiring you to rebuild everything around them.
What to Do Now
If you’re in batteries, textiles, or construction, the window for comfortable preparation is closing. Here’s a realistic timeline:
2026 should be your year for systems and processes. Map your data sources, identify gaps, and implement the technical infrastructure needed to generate and manage product passports. Waiting until requirements are “final” means starting when your competitors are finishing.
2027 will separate the prepared from the panicked. Battery companies will face their first mandatory deadline. Textile and construction businesses should be running pilot projects, working out the operational kinks before requirements become binding.
2028 brings textiles into mandatory territory, with construction products following as harmonized standards are updated. By this point, DPP should be a routine part of your operations, not a crisis project.
A Note on Uncertainty
We want to be direct about what we don’t know. Specific data requirements for some product categories are still being finalized through delegated acts. Implementation details for the EU’s central DPP registry are still emerging. Timelines could shift slightly as the Commission works through technical specifications.
What won’t change is the direction. The EU has committed to product transparency as a cornerstone of the Green Deal. Whether your specific deadline is six months earlier or later than current projections, the fundamental requirement is coming.
Working with the Right Partner
At DPPA, we’ve built our platform specifically for this moment. Our approach is hands-on and agile. We’ve had a working product since before many competitors started their PowerPoint decks, and it evolves continuously as requirements clarify.
We designed DPPA to simplify DPP for small and medium businesses while scaling seamlessly for larger operations. Security is foundational, not an afterthought. As members of Standard Norway’s national DPP standardization committee and participants in EU regulatory discussions, we’re not just following the regulations. We’re helping shape them.
Our network includes Microsoft, Innovation Norway, and Standard Norway. We’re small enough to move fast and give you direct access to expertise, but connected enough to keep you ahead of what’s coming.
To sum it up, we don’t have unlimited resources or all the answers, but we are confident in the quality of what we are building. We are two founders who know exactly what we are creating and only promise what we can deliver… It’s all about building a long-term partnership, not just providing a service.
Ready to talk about what DPP means for your specific business? Contact us to start the conversation.