What changes to the digital product passport for electronics in 2026?
At present, there is no legal obligation in force today for most electronics and ICT companies. What is changing, however, is the phase in which the regulation finds itself: the European Commission is working through the ESPR work plan 2025-2030 step by step, and the first concrete rules for subcategories within electronics are expected from 2027 onwards. 2026 is therefore primarily the year in which the contours become clearer, not the year in which the obligation comes into force.
For you as an entrepreneur, this means that there is no exact date, no fixed dataset and no definitive list of mandatory information for your products. What there is: a work plan in which the Commission indicates the order in which product groups come up, and signals about which subcategories within electronics and ICT are likely to be early in that order. That order and the associated rules are laid down in what the regulation calls "delegated acts": separate decisions worked out for each product group that flesh out the general ESPR regulation.
Where the ESPR work plan currently stands
The ESPR itself, the framework regulation, is fixed. What is not yet fixed is the implementation by product group: which data exactly must be in the passport, who must supply it, and from when. That implementation does not come all at once for all electronics, but product group by product group. The work plan provides an indicative order and an indicative period for this, and the Commission works through that order over the years towards concrete proposals.
This means that "the digital product passport for electronics" currently has no fixed date of entry into force. What does exist is an expectation: for most electronics and ICT categories, a delegated act will not be published before 2027, and the actual obligation to provide a passport usually lies a number of years after that. Hence the indication around 2030 that you see on this platform, with the clear caveat that this is not yet a firm date.
What a delegated act concretely means for you
A delegated act is the moment when abstract rules become concrete. Only then will it be clear which data on, for example, repair, origin of materials or energy consumption must be mandatory in the passport, and only then will it be clear who within the chain is responsible for supplying that data. Until that time, you can prepare yourself on the basis of the general lines from the regulation, but not on the basis of a definitive checklist.
This distinction between framework regulation and delegated act comes up repeatedly in the questions we receive, for example about who exactly qualifies as a supplier or which documents will be needed. For an overview of how these concepts relate to each other, and how we keep track of the official texts, you can refer to the overview of topics by situation.
What this means for your planning
Because the exact date and content are not yet set, it is for most companies now not a matter of "comply now", but rather "prepare now". Think about mapping where your product data comes from, who in your chain manages which information, and which suppliers you can ask about it. That work does not have to wait for the delegated act, and it saves time once it does exist.
Supervisory authorities in the Netherlands and the EU are expected to start enforcement only once the delegated acts and the associated deadlines are definitive. How that enforcement will look in practice cannot be predicted at this stage, and we deliberately leave this open; for questions about your own situation, the competent supervisory authority or a lawyer is the right point of contact.
What you can do now
A good starting point is a brief inventory: which products do you import or manufacture, which sub-category do they fall into, and what data do you already have on file about them. With a few questions you will immediately see an indication of where you stand, without needing an account. This way you will already know what information you need to have in order over the coming years, regardless of the exact date when the obligation comes into force.
We keep the ESPR work plan and the delegated acts for electronics and ICT up to date and update this page as soon as new, official texts are published. How we collect that information and keep it traceable back to the source can be found on the page about our working method.
Finally
The core of this year is therefore not a new obligation, but a more precise timeline. As soon as a delegated act for a sub-category within electronics or ICT is published, the date will appear here and in the knowledge base. If you are unsure whether your products will fall under an earlier or later category, check the frequently asked questions about the digital product passport or take the free quick-scan to see where you stand.