ESPR Atlas: EU Ecodesign & Digital Product Passport Guide

Proposal COM(2026) 590 of 9 September 2026, procedure 2026/0265(COD), would move ESPR Article 65 (Commission minimum green procurement requirements binding on public buyers for product groups under ESPR delegated acts) and Article 74(3), point (b) (Member State exclusion of infringers from public procurement for a limited time) into a new Public Procurement Act as its Articles 54 and 26(1)(a). Its Article 92 lets public buyers require a declaration of conformity delivered through the Digital Product Passport as proof of meeting tender requirements. Parliament is in the preparatory phase, the Act would apply two years after adoption, and no ESPR date moves. Signaled

On the Legislative Observatory, the indicative Omnibus IV first-reading plenary date has slipped from 11 November, as reported here in July, to 23 November 2026 for both digitalization-strand files, 2025/0134(COD) on the regulation amending ESPR and 2025/0133(COD) on the directive. Both await Parliament's position in first reading, the last key event being committee approval of the trilogue text on 14 July 2026. No ESPR date moves, including the 19 July 2026 application, the DPP Registry, and the 18 February 2027 battery passport, so builds should not pause for Omnibus IV. Signaled

The CRMA amendment, procedure 2025/0385(COD), now has an indicative first-reading plenary date of 19 October 2026 on the Legislative Observatory, added after the 9 July 2026 referral back to committee, still the last recorded event. With no Parliament first-reading position or trilogue, letting a digital product passport satisfy the Article 28 permanent-magnet labeling duty remains a proposal. If the October vote adopts a position, trilogue can start and the DPP route becomes worth designing for. Signaled

Alongside the live DPP Registry, the Commission has published a User Guide for Economic Operators on organization enrollment and DPP registration, a testing environment with its own EU Login account, and a help desk (EC-HELPDESK-DPP@ec.europa.eu, +32 2 296 0431, 08:00 to 20:00 CET). Its Digital Product Passport pages, relaunched 17 July 2026, carry sector guidance for batteries, iron and steel, and textile apparel. No per-product registration duty applies yet, as passport duties bind by category with batteries first on 18 February 2027, but operators should enroll and exercise the sandbox now rather than first meet the enrollment workflow in February 2027. Locked

Commission guidance of 21 August 2026, Digital Batteries Passport data points by category, counts 71 battery passport data points, replacing an industry estimate of roughly 90 attributes as the only consolidated figure. Each point for electric vehicle, light means of transport, and industrial batteries is flagged mandatory, optional, conditional, or not required as of February 2027, with its legal source. The Commission states the document introduces no additional legal requirements and is not an authoritative interpretation, so it is the clearest available map, not the rule. Scope battery passport data collection for 18 February 2027 against this list rather than a vendor count. Signaled

Two Batteries Regulation delegated acts due by 18 August 2026 have not been adopted: the Article 7(3) maximum life cycle carbon footprint threshold for electric vehicle batteries, and the Article 8(1) methodology and documentation format for calculating and verifying recovered cobalt, lithium, nickel, and lead content. Both depend on the Article 7(1) carbon-footprint methodology act, overdue since 18 February 2024. Recycled-content documentation binds from the later of 18 August 2028 or 24 months after the Article 8 act enters into force, and the carbon threshold from the later of 18 February 2028 or 18 months after its own act. Keep building the recycled-content data trail now, since the battery passport needs the same supply-chain evidence on 18 February 2027. Signaled

The public consultation on iron and steel ecodesign requirements (initiative PLAN/2025/1517, a delegated regulation), lead category of the first Working Plan, ran from 20 May to 12 August 2026 and is closed on the Commission Have Your Say portal (read 13 August 2026). These first ESPR product rules remain targeted for adoption in Q4 2026, and no other Working Plan category has opened a consultation on an act. Makers, buyers, and importers of steel-intensive products should start collecting verified embodied-carbon and recycled-scrap-content data now, since the act will set only the format. Locked

Published acts are citable only by Official Journal number, so this Atlas now cites both Article 25 acts that way, with the old Commission draft numbers kept in the Article 25 deep dive for older memos. The derogations act, which most 2026 commentary still calls C(2026) 659, is Commission Delegated Regulation (EU) 2026/296 of 9 February 2026, published in the Official Journal on 22 April 2026, and the disclosure-format act, still widely called C(2026) 660, is Commission Implementing Regulation (EU) 2026/2 of the same date. The Article 24 disclosure format applies from 2 March 2027, not approximately February 2027 as previously given, so update compliance files, supplier contracts, and legal memos citing C(2026) 659 or C(2026) 660 and move disclosure readiness to that date. Locked

Commission Implementing Regulation (EU) 2026/1778, adopted 16 July and published in the Official Journal 17 July 2026, sets identity verification, registration, proof-of-registration, and data-retention rules for the EU Digital Product Passport Registry required under ESPR Article 13. It enters into force 6 August 2026, and the Registry went live to users on 20 July 2026, resolving the pending item tracked under consultation Ares(2026)4424976. Locked

Commission Implementing Decision (EU) 2026/1736 of 14 July 2026, published and in force 15 July 2026, cites the six horizontal DPP standards in the Official Journal: EN 18216, EN 18219, EN 18220, EN 18221, EN 18222, and EN 18223:2026. Under ESPR Article 41(2), a conforming digital product passport is now presumed to conform with the requirements in ESPR Articles 10 and 11, a step pending since the 26 May 2026 publication. EN 18239 and EN 18246 are not cited and remain a watch item, and no compliance deadline changes. Use the six as your DPP build specification and require conformity with them in platform and service provider contracts and RFPs; the DPP Standards and Presumption of Conformity deep dive covers what each governs. Locked

Omnibus IV will not be adopted this summer. Both digitalization-strand procedures, 2025/0133(COD) for the directive and 2025/0134(COD) for the regulation amending ESPR, cleared committee on 14 July 2026 and await Parliament's position in first reading, with the indicative plenary date, first 11 November 2026, moved to 23 November 2026 (see the 7 September 2026 entry). The strand covers electronic declarations of conformity, a digital contact requirement, and common specifications as an alternative route to harmonized standards, and it postpones no existing obligation, including the ESPR application date, the DPP Registry, and the 18 February 2027 battery passport, so DPP builds should not wait on it. Signaled

The CRMA amendment went backwards in July, which several trackers have missed. On 24 June 2026 the ITRE committee adopted rapporteur Mohammed Chahim's report 63 to 4 and voted 66 to 11 to open negotiations with Council, widely reported as a Parliament mandate, but plenary referred the matter back to committee on 9 July 2026 after a political group challenged it under Rule 72. Parliament has no first-reading position and trilogue has not started (as of 7 September 2026 the procedure file shows an indicative first-reading plenary date of 19 October 2026; see that entry). The proposed DPP route for the Article 28 permanent-magnet labeling duty and the shift of Article 24 identification of in-scope large companies from Member States to the Commission now face a longer timeline. Statutory dates of the CRMA as enacted are unchanged: 24 May 2027 for the Annex I and Annex II list review, and 1 January 2027 for the recycling-capacity benchmark delegated acts. Signaled

Two distinct and often confused ESPR obligations begin on 19 July 2026. The central DPP registry must be operational (Art. 13) as EU infrastructure indexing identifiers, not as a per-product registration deadline, since passport duties bind by category, batteries first on 18 February 2027. Separately, the Article 25 destruction ban on unsold apparel and footwear, with narrow documented derogations under Reg. (EU) 2026/296, starts applying to large enterprises alongside the Article 24 disclosure duty. The new Get Ready tab covers both, with a four-question self-assessment, how-to-proceed steps, and primary source documents. Locked

Battery card corrected and expanded after a cross-check against the EU Batteries Regulation (CELEX 32023R1542). The carbon-footprint declaration applies 12 months after the EV methodology act enters into force (statutory anchor 18 Feb 2025, floating), not in February 2027; 18 February 2027 is when it must be accessible via the battery passport. The card adds the Article 7 three-step ladder of declaration, performance classes, and a maximum lifecycle threshold gating market access. Due-diligence dates cite Reg (EU) 2025/1561 (Omnibus IV batteries strand, adopted 18 July 2025), with due diligence on 18 August 2027 and Commission guidance due 26 July 2026. The Omnibus IV digitalization strand (COM(2025) 504/503) reached provisional political agreement 9 June 2026, adoption pending. Locked

Germany is the first Member State with ESPR-specific penalties. The Gesetz zur Modernisierung der nationalen Umsetzung von europäischen Regelungen zum Ökodesign, zur Energieverbrauchskennzeichnung und zu weiteren Regelungen, whose Article 1 is the new Ökodesign-Gesetz, passed the Bundestag on 21 May 2026, was signed on 22 June 2026, and was published on 26 June 2026 as BGBl. Teil I 2026 Nr. 191. It enters into force on 1 November 2026 (Article 9), though section 3 (the ordinance-making power) and two amending articles have applied since 27 June 2026. Sections 1 to 15 and 18 transpose the OLD Ecodesign Directive 2009/125/EC, the package harmonizes the German market surveillance powers that enforce ESPR, and sections 16, 17, and 19 implement Regulation (EU) 2024/1781 directly. From 1 November 2026, section 19 (Bussgeldvorschriften zur Verordnung (EU) 2024/1781) makes destroying unsold consumer products contrary to Article 25(1), circumventing the ban contrary to Article 25(2), and failing the Article 24 disclosure duties administrative offenses, fined up to EUR 100,000 for unlawful destruction and EUR 10,000 for disclosure failures (section 19(3): Geldbusse bis zu hunderttausend Euro). Section 20 excludes anyone with a final fine of at least EUR 7,500 from German public procurement for up to three years. This supersedes our 10 August note that the fines were unconfirmed, and the half-million-euro ceiling in English-language trade press has no primary source. Holders of unsold apparel or footwear stock in the German market need derogation grounds and records in order before 1 November 2026. Locked

Atlas baseline verified against primary sources. Confirmed: 19 July 2026 registry deadline, 18 February 2027 battery passport, the two Article 25 acts (Reg. (EU) 2026/296 and Reg. (EU) 2026/2), and Detergents Regulation (EU) 2026/405. Locked

EV battery carbon-footprint methodology act remains in draft. The Omnibus IV digitalization strand (COM(2025) 504) is progressing and moves no DPP date; the adopted batteries strand, Reg (EU) 2025/1561, had already postponed due diligence to 18 August 2027. Signaled

The European Commission consulted industry until 27 May 2026 (ref. Ares(2026)4424976) on the draft Implementing Regulation for the EU Digital Product Passport Registry under ESPR Article 13, which indexes product unique identifiers and their economic operators, not passport content, and had to be operational by 19 July 2026. The act was adopted on 16 July 2026 as Commission Implementing Regulation (EU) 2026/1778, and the Registry went live to users on 20 July 2026 (see the 17 July 2026 entry). Signaled

CEN and CENELEC published the first six European DPP standards on 26 May 2026 under Commission Standardisation Request M/604, with definitive texts made available (DAV) on 27 May 2026: EN 18216 (data exchange protocols), EN 18219 (unique identifiers), EN 18220 (data carriers), EN 18221 (data storage, archiving and persistence), EN 18222 (lifecycle and search APIs), and EN 18223 (system interoperability). Their Official Journal citation, conferring presumption of conformity, followed on 14 July 2026 through Implementing Decision (EU) 2026/1736, in force 15 July 2026 (see the 15 July 2026 entry). EN 18239 (access rights and security) and EN 18246 (data authentication and integrity), approved by CEN on 17 August 2026 and published on 15 September 2026, were not cited in the Official Journal as of 30 September 2026. The DPP Standards and Presumption of Conformity deep dive covers what each governs. Locked

A Joint Research Centre preparatory study for the future ESPR delegated act proposes Digital Product Passport content for textile apparel of at least 80% textile fiber by weight. Its four data categories are product identification and classification, producer information, product information (fiber composition, mechanical durability, substances of concern, recycled content, and environmental footprint), and compliance documentation, with role-based access separating public data from data available only to parties with a legitimate interest or to regulators. The Commission proposal was then expected late 2026, but the Commission DPP timeline now gives Q4 2027 for adoption, so compliance is unlikely before mid-2029. Signaled

The Council of the EU adopted its negotiating position on a Commission proposal amending the Critical Raw Materials Act (Regulation (EU) 2024/1252) to move Article 24 identification of in-scope large companies from Member States to the Commission, let a digital product passport satisfy the Article 28 permanent-magnet labeling duty, and add measures to increase magnet recycling. The ITRE committee adopted the report of Mohammed Chahim (S&D, Netherlands), European Parliament rapporteur since 10 February 2026, on 24 June 2026, but its vote to open negotiations with Council was challenged in plenary under Rule 72 and referred back to committee on 9 July 2026. With no Parliament first-reading position or trilogue, reports of an agreed Parliament mandate are out of date. The existing CRMA statutory dates (24 May 2027 list review, 1 January 2027 recycling-benchmark delegated acts) remain Locked. Signaled