With so many misunderstandings circulating and because the EU DPP is not a generic label but a specific EU obligation that applies only when the EU designates your product group, it is important to separate facts from assumptions and marketing claims.
The EU Digital Product Passport (EU DPP) is increasingly appearing in presentations and articles about the construction and installation sector. It is sometimes suggested that every product sold through a DIY store will soon need a passport. That sounds dramatic, but it does not match how European legislation is currently structured.
This article explains, in the context of the DIY store market:
- What has already been decided, and what has not
- Which product groups will it become genuinely relevant for first.
Are there different types of “product passports” in EU law?
Two separate legal tracks are running in parallel and should not be conflated:
- The EU Digital Product Passport under the ESPR
- The Battery Passport under the Battery Regulation.
What exactly is the EU Digital Product Passport under the ESPR?
The EU DPP is created under the Ecodesign for Sustainable Products Regulation (ESPR). This regulation entered into force on 18 July 2024 and provides the legal basis for product requirements and digital passports per product group.
However, the ESPR does not yet set the detailed DPP content for any product group. The specific requirements will be introduced later through delegated acts, one product group at a time.
What is the battery passport, and does it apply to products sold in a DIY store?
The battery passport comes from a different law: the EU Battery Regulation. It has its own rules and timeline.
From February 2027, a battery passport will be mandatory only for three specific categories:
- Batteries for electric vehicles (EVs), such as electric cars and vans
- LMT (Light Means of Transport) batteries, such as those in e-bikes and e-scooters
- Industrial and stationary batteries above 2 kWh (in practice: battery packs of roughly 8 kg or more)
This means the typical rechargeable batteries used in consumer products sold through a DIY store do not fall under the first battery passport obligation.
Which product groups will get EU DPP requirements first?
The European Commission adopted the first ESPR work programme for 2025–2030 in 2025. This programme sets the first-wave priorities for delegated acts and EU DPP requirements.
The first wave covers:
- Textiles and clothing
- Furniture and mattresses
- Tyres
- Iron and steel
- Aluminium
A crucial detail for manufacturers: iron, steel and aluminium are explicitly labelled as intermediate products in the work programme. This means they are treated as material streams, not as finished end products.
This is a limited list. The work programme does not state that all products sold through a DIY store will require an EU DPP.
Do “iron, steel and aluminium” priorities mean every steel-containing product sold in a DIY shop gets a DPP?
At present, there is no public indication that every end product containing a small amount of steel (for example, a box of screws) will automatically fall under a mandatory EU DPP.
In the ESPR context, preparatory studies by the Joint Research Centre (JRC) are currently underway for iron/steel and for aluminium. These studies aim to support possible future delegated acts.
Their focus is on material streams such as:
- Coils
- Sheets/plates
- Profiles
- Beams
- Reinforcement
The Commission itself emphasises that requirements for intermediate products can strongly affect end products. That is why it is explicitly stated that it must be assessed carefully whether and which end products might be brought in later.
What is still unknown about the EU DPP for steel and aluminium?
Almost everything about the content is still open. No delegated acts for steel or aluminium have been adopted yet, and there are no final public draft texts known to be heading into a vote.
So manufacturers do not yet have definitive answers to questions like:
- Which indicators will be mandatory in the EU DPP
- Whether obligations apply at model level, batch level, or both
- Whether specific Product Carbon Footprint (PCF) methodologies will be mandated
- Whether certain end products with high steel/aluminium content sold through DIY shops will later be explicitly added
In short, the EU has set priorities, but not the detailed rules.
Can EU DPP obligations realistically start in 2026?
No. That timeline does not fit the ESPR process.
There are three required steps:
- Legal basis already in force.
The ESPR has been applied since 18 July 2024, which establishes the framework but not the product-group specifics.
- Delegated acts must be adopted per product group.
Requirements for textiles, furniture, mattresses, tyres, iron/steel chains and aluminium chains are now being drafted. Multiple analyses expect the first delegated acts to be adopted in late 2025 or during 2026.
- A minimum transition period of 18 months follows adoption.
The ESPR requires at least 18 months between adopting a delegated act and its obligations taking effect.
That means:
- Even if a first delegated act were adopted at the beginning of 2026
- Obligations could only apply at the earliest sometime in 2027
- Several independent analyses therefore place the first real-world application in 2027–2028
So claims about mandatory EU DPPs across products in 2026 cannot be correct on timing grounds
Does the EU DPP require manufacturers to publish a
full supply-chain map?
No. This is a common misunderstanding.
The EU DPP is designed to be:
- A standardised set of product information
- Linked to a digital identifier
- Containing only the data fields required by the relevant delegated act
It is not intended to be:
- A complete supply-chain map
- A public list of all suppliers and sub-suppliers
- A chain-mapping tool
Manufacturers will need to gather supply-chain data to calculate indicators such as recycled content or footprint. But that does not mean every supply-chain step is published in the DPP itself.
What is the EU DPP actually meant to achieve for circularity? Slow down the loop and close the loop.
The core purpose is to support the circular economy, not transparency for its own sake. Two circularity principles underpin the DPP:
How does the DPP help to “slow down the loop”?
It supports longer, lower-impact product use through better product information on:
- Expected lifetime and energy use
- Maintenance needs (what, how often, by whom)
- Repairability and repair options
- Reuse possibilities for products and components.
How does the DPP help to “close the loop”?
It supports higher-quality recycling and material reuse by providing information on:
- Material composition
- Presence of critical or hazardous substances
- Suitability for high-value recycling
The strategic goal is to reduce Europe’s dependence on non-renewable primary materials and slow the depletion of natural resources. The EU DPP is a data carrier to support that goal, not an end in itself or a public map of every link in the chain.
What does all this mean right now for manufacturers selling into DIY stores?
Based on the current state of EU policy:
- Not every product sold through a DIY store will get an EU DPP in the first wave
- There is no obligation to publish complete supply-chain maps
- Iron/steel and aluminium are prioritised as intermediate products, but detailed requirements still need to be set in delegated acts
- First realistic EU DPP obligations for prioritised groups are expected between 2027 and 2030, not 2026
This makes the topic important to track closely, but there is currently no legal basis for claims that every DIY store product must have a passport from 2026.
What should manufacturers take away from this today?
The EU DPP will become a major instrument to support a more circular economy through better product information and better material reuse. At the same time, facts and fiction must be kept apart.
Priority product groups remain limited, delegated acts have not yet been adopted, and a transition period of at least 18 months always applies. Until official EU documents set concrete scope and dates, it is wise to be cautious about firm claims on timelines or coverage.
Until a product group has a formal delegated act, there is no EU DPP obligation for that category. Any other “passport” is therefore not an EU DPP regardless of how it is marketed or presented.
