how do I plan the implementation of the product passport in my organisation

Start with the date that is not yet fixed and work backwards

You build a timeline for the product passport from back to front: first the point at which the obligation for your own product category takes effect, and from there back to what can already be done now. For electronics and ICT equipment, that end date has not yet been determined — the ESPR works with delegated acts per product category, and these are expected for this sector at the earliest from 2027 onwards. This does not mean that planning is pointless, quite the opposite: precisely because the end date is moving, a timeline with margin and intermediate steps is more valuable than a timeline with one fixed deadline.

For electronics and ICT, not for batteries or other categories that are already further along

This planning concerns electronics and ICT equipment as intended under the ESPR, per subcategory. Other product groups that fall under the same regulation — for example batteries, textiles or furniture — each have their own delegated act with their own timeline, and that timeline may move faster or slower than that of electronics. Those with multiple product groups in their portfolio therefore plan per category separately, not one timeline for the entire company. Even within electronics and ICT, distinctions are made: the subcategories are prioritised and developed separately, so it is not given that all equipment from one manufacturer falls under the obligation at the same time. What this timeline also does not do: make a statement about how strictly a supervisory authority will check or what outcome an enforcement process will receive. That is the responsibility of the bodies that oversee it, not a planning document.

What is fixed and what is not

It is established that the ESPR provides a framework (including in Article 9 and Article 10) for what a digital product passport must contain and how it must be accessible, and that Article 18 describes a system for prioritising and planning product categories. It is also established that the European Commission will specify via delegated acts (Article 4 and Article 8) when and for which products the obligation applies in concrete terms. What is not fixed is the date for electronics and ICT itself: this only follows once the delegated act for this sector has been published. Until then, there is no legal obligation to already maintain a passport, but the preparation time provided for 2027 and the years thereafter in the work programme is not generous if you consider how many links — collecting data, setting up systems, engaging suppliers — are involved in practice before a functioning passport is in place.

How the timeline works in practice

The first step is not to wait for the delegated act, but to map now which product data already exist and where the gaps are — information about materials, origin, repair and recycling that will later need to be in the passport is often scattered across procurement, engineering and quality. An overview of what you can already do while the rules are not yet definitive indicates which steps make sense without you getting ahead of a text that could still change. The second step is to determine the scope: which product lines will later fall under electronics and ICT, and is it one or ten — if there are multiple lines, it is advisable to look early at how you arrange the product passport for all your product lines at the same time, because shared systems and processes deliver economies of scale. The third step is a rough cost estimate, for which an overview of what a digital product passport for electronics costs gives an initial direction, even though not every cost item can yet be determined with certainty. The fourth step, once the systems and data are in place, is to test — the overview how you test your passport before it is published describes what that entails. In parallel, the internal side runs: employees who will work with the passport, from procurement to customer service, need time to adapt to a new process, and a separate plan for how you train staff on the passport prevents this from becoming a bottleneck at the last moment. A general roadmap describing the order of all these steps is set out in how to tackle the digital product passport for electronics step by step. Anyone who structures these steps in blocks of a quarter or half year, using the publication of the delegated act as a fixed reference point that you adjust as soon as there is news, has a timeline that moves along without the plan having to be redrawn from scratch each time.

The legal basis for this planning

This approach follows directly from the structure of the ESPR itself. Article 9 and Article 10 of Regulation (EU) 2024/1781 describe what a digital product passport must be able to do in terms of content and technical capability, and this is the basis for determining what data a company must collect. Article 18 provides that the Commission prioritises product categories and draws up a work programme, which explains why electronics and ICT are not the first to be covered and why the date differs per category. Article 4 and Article 8 finally determine that the actual obligation, including the date of application and product scope, is laid down in each delegated act — and is therefore only known with certainty once that act is in place.

Companies wishing to start now would be best advised to begin with an inventory of their own product data and an initial rough planning in quarters, and to adjust that planning as soon as elektropas.com announces that the delegated act for electronics and ICT has been published.

What this is based on

The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.

What you must concretely do

What is expected of you

A timeline for the digital product passport is not a matter of putting a single deadline in your calendar. Regulation comes in phases, per product category, meaning that a timeline is actually a plan for several parts at the same time: collecting data, setting up systems, testing, and preparing staff. The obligations below do not all come into force on the same date, but preparation for them usually begins at roughly the same time.

Knowing which category applies and when it is due

Article 18 of the ESPR (Regulation (EU) 2024/1781) governs the prioritisation and scheduling of product groups. Not all electronics and ICT equipment will receive a delegated act at the same time; the Commission will elaborate this per product subcategory. For a company of 10 to 100 employees, this means that the first step in the timeline is not "start building" but to find out which category their own products fall under and whether a work programme or delegated act is already being prepared for that category. Anyone who does not know this is planning in the dark. A good starting point for this is set out on the page on whether the digital product passport applies to their own electronics.

Knowing what will eventually have to be in the passport

Article 8 of the ESPR determines what the delegated acts per product group will set out: what information, in what form, and with what access rights. Article 10 sets general requirements for the passport itself, such as linking to a unique identification and accessibility via a data carrier. For planning purposes, this means that a company cannot wait until the exact content is determined before it starts collecting data. Many data items — origin of materials, repair data, warranty information — are already recorded today, but often scattered across different departments or suppliers. Mapping this can already begin regardless of the final delegated act.

Ensuring that the passport is actually linked to the product

Article 9 requires a digital product passport that is accessible via a data carrier (usually a QR code) for the entire lifetime of the product. For a mid-sized company, this is organisationally the most demanding step: the passport must not only exist, it must also remain in existence and accessible, even if the company switches systems or a product line is phased out. Hosting and long-term availability should therefore be included in the timeline as an ongoing item, not as a one-off action.

Know when your obligation becomes concrete

Article 4 gives the Commission the power to adopt delegated acts; this takes place per product group and at a time that is not yet determined for every category. For planning purposes, this may be the most challenging step: building a timeline around a date that has not yet been published. What is possible, however, is a timeline with a fixed preparation phase and a flexible end date that is adjusted as soon as the delegated act for your category appears.

Where things go wrong in practice

A frequently heard pitfall is that companies wait for the final delegated act before taking action, while data preparation — which takes the most time — does not depend on it. By the time the rules become concrete, no foundation has been laid.

A second situation is that planning is built around IT only: a system for the passport is procured, but no one has thought about who will fill in, verify and maintain the data. Without that internal agreement, the timeline stalls as soon as the system is ready, but the content is not.

A third situation is underestimating multiple product lines. Companies that assume one pilot product often discover too late that other lines have different suppliers, different materials and therefore different lead times for data collection. This requires an approach that plans per line instead of one timeline for the entire assortment, as described in handling the product passport for multiple product lines at once.

A fourth pitfall is that no room is reserved in the timeline for testing. A passport that has never been walked through by anyone outside the project team risks errors coming to light only after go-live. There is an approach described to prevent this on the page about testing the passport before it is published.

A fifth situation is that the people who will work with the passport — customer service, returns and repair department, procurement — are only informed after everything has been built. A timeline that treats training as a closing item instead of a fixed component often leads to delays in the final phase, precisely when the pressure to launch is highest.

What you can document

An overview per product line of the applicable category and the status of the associated action plan or delegated act, with a fixed review date to keep this overview current.
An inventory of which data are already available (in procurement, quality, production) and which are still missing, including who is responsible for supplementing them.
A plan with a fixed preparation phase that does not depend on the publication date of the delegated act, and a flexible follow-up process that is adjusted as soon as that date becomes known.
Agreements on hosting and long-term availability of the passport, including what happens in case of system change or discontinuation of a product line.
A test plan with involvement of people outside the project team, prior to go-live.
A training schedule for the departments that will work with the passport, as detailed on the page about training employees on the product passport.
A step-by-step plan that establishes the sequence of the above items, for which the approach described in the step-by-step approach to the product passport can serve as a basis.

This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something not correct? Let us know — corrections take priority.