Once the European Commission publishes the delegated act for your product category, a transition period will run before the digital product passport becomes mandatory. The exact length of that period varies by product group and will be set out in the act itself at the time of its publication. For electronics and ICT equipment, this has not yet been published; the regulation's work plan names 2025-2030 as the period in which delegated acts per sub-category are expected, with the first from 2027 onwards.
What can be said is this: the time you need to actually have the passport ready is usually longer than companies expect beforehand. Not because the process itself is complicated, but because gathering the right data from suppliers, manufacturers and internal departments often takes more effort than the publication date of the rules suggests.
What the regulation already sets out on the timeline
The ESPR, the European regulation that makes the digital product passport possible, works with a framework act that is completed for each product group. This is done through delegated acts: separate decisions in which the Commission sets out which data for that specific product category are mandatory, from when, and with what transition period for companies that already have products on the market. The work plan names the order in which product groups come up, but the exact date and the length of the transition period are only fixed once the act for that group has been published.
For those who now want to know how the regulation is structured and what the terms mean exactly, the knowledge base has researched the subject matter an overview that will be updated with the publication of new acts.
What is not yet settled
It is tempting to name a figure now for "how much time you get", but that figure simply does not yet exist for electronics and ICT equipment. Other product groups that are further along in the process show that the transition period can vary by category and that the Commission takes account of the complexity of the supply chain. A reasonable assumption is that a longer and more international chain entails more preparation time, but that is a pattern, not a guarantee for your specific situation.
Once the delegated act for your product category has been published, the date and transition period will be stated here. Until then, caution with concrete deadlines is warranted, even if you have already come across them elsewhere.
Where the lead time gets stuck in practice
Companies that have already prepared themselves usually do not get stuck on the legal text itself, but on three practical points. First: data that lies with a supplier or subcontractor and cannot simply be requested, especially if that party is located outside the EU. Second: unclear responsibility within your own company for providing and keeping the data up to date, especially when procurement, quality and compliance operate separately. Third: underestimating the time needed to verify data before they enter a passport, because a passport with outdated or incorrect data provides little value.
These three points apply regardless of the exact date when the obligation comes into force. Those who gain clarity on this now will save time once the act for their own product group is published. A good starting point is to determine what role your company plays in the chain, as this partly determines which data you yourself must provide and which you need from others.
What you can already prepare now
Without jumping ahead of a date that is not yet fixed, you can nevertheless start mapping which product data you already have, which is missing, and from whom you would need to request it. This is not a prior obligation, but it is the step that takes the most time once the clock does start running. Supervisory authorities in the Netherlands and the EU check afterwards whether the data in the passport is correct and up-to-date, not how quickly a company has collected them, but a late start increases the risk of hasty work.
To see how your own situation relates to the regulation, you can get an indication in a few questions of where you stand. If you first want to know where the information on elektropas.com comes from and how it is maintained, that is explained on the page that explains how the information is created.
For your own situation, with the precise consequences for your products and your contracts, a lawyer or the competent supervisory authority remains the appropriate point of contact. Elektropas.com describes the regulation and keeps track of when new data and deadlines are published, but does not make statements about individual cases.
If you want to assess yourself how far you have come and what still needs to happen for your product group, take the free quick-scan or browse through the topics in the knowledge bank. Answers to frequently asked questions about the passport can also be found on the overview of frequently asked questions.