In what order do product categories get a mandatory passport?
The Commission determines the order via a work plan
Which product category receives a mandatory digital product passport when is not set out as a fixed list of dates in the EUMR itself. Regulation (EU) 2024/1781, the EUMR, is a framework law: it regulates how the system works, but for each product category, a separate delegated regulation to be published later will set out which requirements apply and from when. Article 18 of the EUMR requires the European Commission to determine that order on the basis of a work plan and a number of prioritisation criteria. Product categories with significant environmental impact, large sales volume within the EU, or that already fell under the old Ecodesign Directive (2009/125/EC) for energy-related products, are more likely to be prioritised under those criteria than categories for which little preparatory work has been done. The work plan is thus the instrument in which to see which product categories have the attention of the Commission at that time.
For whom this applies, and for whom it does not yet
This work plan and the prioritisation apply to manufacturers and importers of products that fall within the scope of the EUMR — in practice virtually all physical products placed on the EU market. The regulation itself excludes a limited number of categories, such as food, animal feed, medicines and living plants and animals. For those excluded categories, the question "when is it my turn" is therefore not relevant. More important for most entrepreneurs is a different distinction: the fact that the EUMR exists does not mean that a product passport is already mandatory. As long as no delegated regulation has been adopted for a product category, no passport obligation applies to that category — even if the product category is already mentioned in a work plan as a future focus point.
There is no fixed end date for all product categories
There is no single date on which the passport becomes mandatory for all products at once. Each product category receives its own delegated regulation, with its own timetable and its own transition period. What is established, however, is the way in which that timetable is drawn up: via the work plan of Article 18, which the Commission draws up and which sets out which product categories are given priority for further development. In the EUMR itself, in the first prioritisation, several product categories are already mentioned for which the Commission will take action first, such as textiles (in particular clothing and footwear) and furniture, alongside categories that have been on the agenda for longer under the old Ecodesign Directive. A concrete date on which the passport becomes mandatory for a specific product category can only be given once the delegated regulation for that category has been published. Until then, there is clarity on the order of priority, but not on the exact implementation date.
How this works out in practice
For anyone who wants to know where their own product group stands in this process, the practical sequence is as follows: first check whether your own product group is already mentioned in the Commission's current work plan or in a published delegated regulation. If the group is not listed, there is currently no legal obligation, but that says nothing about the future — the work plan is reviewed periodically and new groups can be added. If the group is listed as a future point of attention, the precise obligation has not yet been established, but it is the time to follow Commission announcements, because the delegated regulation with the actual requirements and the transition period follows thereafter. Product groups that already fell under the old Ecodesign Directive for energy-related products can expect a delegated regulation sooner than groups for which no preliminary process yet exists. And because the sequence is determined by environmental impact and sales volume within the EU, it is often clearer sooner for larger product groups with known environmental pressure than for smaller, less researched niche groups.
Where this is stated: Article 18 ESPR
This sequence and the criteria behind it follow from Article 18 of Regulation (EU) 2024/1781 (the ESPR), which obliges the Commission to prioritise and draw up a work plan for the implementation of product-specific requirements. The general explanation of the structure of the regulation, including the role of the work plan within the broader system of ecodesign for sustainable products, is available on the European Commission's website on the ESPR.
Anyone who wants to know whether their own product group is already in view should consult the Commission's current work plan and search for their own product group in it, and then follow announcements about delegated regulations as soon as these are in preparation for that group. As long as no delegated regulation has been published for your own product group, there is nothing to miss regarding a legal deadline — however, it may be useful to start thinking about which product data will be needed later, so that they do not have to be gathered afterwards.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), article 18 (prioritisation and planning)
- European Commission — ecodesign regulation for sustainable products
The regulation itself is on EUR-Lex. We provide references for each claim; you do not have to take our word for it.
What you must do concretely
What is expected of you
The ESPR itself does not yet require any product category to have a digital product passport. The regulation is a framework law: it governs how the European Commission designates product categories, on the basis of which criteria, and in which order it prioritises them. Only when a delegated act has been adopted for a product category — as explained on what is a delegated act and why does it determine what I have to do? — does a concrete obligation arise, with its own entry into force date and its own requirements. The order in which this happens is therefore not arbitrary, but follows from a prioritisation logic set out in Article 18 of the ESPR (Regulation (EU) 2024/1781).
Prioritisation based on environmental impact and sales volume
Article 18 sets out the criteria the Commission uses to determine which product categories come first: among other things, the environmental impact of the product category, the sales and trading volume within the EU, and the potential for improvement without this leading to disproportionate costs. For a company with 10 to 100 employees, this means in particular that the company's own product category is not assessed at random, but on the basis of how much environmental impact and market size that category represents within the EU as a whole. A product category with a large volume and high environmental pressure — think of textiles, furniture or electronics — is therefore placed higher on the list than a niche product category with limited distribution.
Work programmes as a planning tool
The Commission elaborates the prioritisation in work programmes, which set out for each period which product categories are being prepared for a delegated act. For a company, this means that the company's own sector is sometimes already mentioned in a work programme years before an obligation actually applies. This is a moment to follow what is happening, without action being required yet — it is preparatory, not an announcement of a deadline. On when does the digital product passport become mandatory for products? it is explained how that transition from work programme to concrete obligation takes place.
Consultation of stakeholders prior to a delegated act
Before a product category is finally included in a delegated act, consultation takes place with stakeholders, including sectoral organisations and businesses. For a company of this size, this is often the moment at which the company's own industry association puts forward positions on feasibility, costs and timelines. It is often not strictly necessary for an individual company to have its say here, but it is the moment at which the final requirements are still open to influence — once the delegated act is adopted, the content is fixed.
The order of product categories in the case of overlapping products
For products that may fall under more than one product category, the order in which categories are designated is relevant for planning. A manufacturer with a product that can be classified both as furniture and as an electronic device may find that one product category comes up for designation before the other. What that means in practice for such a product is set out on my product falls under multiple product categories — what does that mean?
Where things go wrong in practice
A common misconception is that the company's own product category "will take a while yet" because it is not mentioned in the first wave of work programmes. This is often correct in the short term, but the prioritisation in Article 18 is dynamic: new insights into environmental impact can bring a product category forward again.
Another situation is that companies confuse the announcement of a work programme with an actual obligation. The mention of a product category in a work programme means that preparation starts, not that requirements already apply — those only arise with the delegated act itself.
Companies with products in multiple product groups sometimes underestimate that each group receives its own timeline and its own requirements. The idea that "the passport" is a single moment when everything must happen at once does not hold: one product group may already be subject to an obligation while another is still in the prioritization phase.
Also, the role of the sector itself in the consultation phase is often overlooked. Companies that do not follow what their industry organization submits miss the moment when practical objections about feasibility can still influence the final design of the requirements.
A final pitfall is assuming that volume and environmental impact at EU level coincide with the company's own scale. A small or medium-sized company in a product group with a large European market volume — such as packaging or textiles — can still fall early in the prioritization, even if the company itself represents a limited share of that volume. What this concretely means for a small company is explained in does the product passport also apply to small companies?
What you can document
- An overview of the product groups in which the company's own products fall, including a brief explanation why — see also which product group does my product fall under? for the classification that serves as the starting point.
- A record of published work programmes and delegated acts affecting the company's own product groups, with dates of publication and any amendments.
- Notes on consultations in which the sector has participated, and what positions were submitted, to the extent known through the industry organization.
- An overview of products that fall into multiple product groups simultaneously, with the prioritization status for each group — relevant for composite products as elaborated in how many product passports does an e-bike need?
- A designated representative within the company who periodically checks whether there are new developments in prioritization, so that this does not depend on chance signals.
This is not legal advice. This page provides general information about the regulations that this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI on the basis of the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections are given priority.