Which products will require Digital Product Passports?

Product categories and their status

Sources: Battery Article 77 and Commission working plan. Preparation examples are editorial implementation guidance, not prescribed field lists.

A category name is only a starting point

Regulatory scope may turn on definitions, intended use, composition, size, capacity or exclusions. Do not use a marketing category as the final classification. For intermediate materials, investigate whether a measure covers the material, certain downstream products, or both. A finished product containing steel is not automatically in the same scope as a regulated steel product.

Textiles and footwear need separate treatment

The Commission’s textile-apparel work is a defined priority. Do not extend an apparel adoption plan to every textile use or to footwear without checking scope. The working plan treats footwear separately for study. Track textile-apparel development.

How to prepare without guessing the law

Start with product master data, material records and supplier evidence you already need to operate responsibly. Record units, measurement methods, source dates and owners. Label anticipated fields so a future requirement can be adopted without presenting assumptions as current law.

A small pilot can expose identifier mismatches and data gaps. It should test adaptability and traceability, not claim regulatory compliance against an unpublished measure.

Monitor a specific category

Keep a category watchlist with preparatory studies, consultation documents, drafts, adopted acts and application dates in separate fields. Before announcing a customer deadline, verify the adopted instrument and exact scope. Use the timeline guide for the distinction between planning and application dates.